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Ruvalcaba, Cesar From: Ruvalcaba,Cesar Sent: Tuesday,October 1,2019 11:12 AM To: 'Michael Zimmerman' Cc: Gary Reeves Subject: RE: McLane Trucking - PR0515468 Attachments: SP001 6th edition checklists (7).docx; SP001 6th edition checklists(4).pdf, Report.pdf Michael, My apologies for the late response. I was unexpectedly out of the office all of last week. Most of the violations have been addressed.There is one more violation from the original violations that has not been fully addressed. It seems like the plan writer has chosen to follow the STI SP-001 standard for inspections and testing. The Standard calls for monthly and annual inspections by the facility.The SPCC plan only calls for monthly inspections and does not mention the annual inspections.Attached are the SP-001 inspection checklists and below is the STI requirement. 6.5 The owner's inspector is to complete or update the STI SP001 Monthly Inspection Checklist or equivalent each month.Take note of instructions on the checklist. Note special conditions. 6.6 The owner's inspector is to complete the STI SP001 Annual Inspection Checklist or equivalent each year. Take note of instructions on the checklist. Note special conditions. 6.7 For portable containers, the owner's inspector is to complete only the STI SP001 Portable Container Monthly Inspection Checklist or equivalent each month. Take note of the instructions on the checklist. Note special conditions. There is a new in office violation that has been issued.The file titled"SPCC addendum 9-20-19" states that the 150 gallon portable 112 diesel fuel tank is maintained within the yard and has no secondary containment. It is unclear whether or not the 55 gallon drums have a prevention system that is in compliance with CFR 112.7(c)(see below)and will be verified during the next inspection.The 150 gallon container is clearly out of compliance and secondary containment must be provided as per regulations. CFR 112.8(c)(11) "Position or locate mobile or portable oil storage containers to prevent a discharge as described in §112.1(b). Except for mobile refuelers and other non-transportation-related tank trucks, you must furnish a secondary means of containment, such as a dike or catchment basin, sufficient to contain the capacity of the largest single compartment or container with sufficient freeboard to contain precipitation."Or as allowed by CFR 112.7(d). Here is some more on the appropriateness for secondary containment from the regulations CFR 112.7(c) Provide appropriate containment and/or diversionary structures or equipment to prevent a discharge as described in §112.1(b), except as provided in paragraph (k)of this section for qualified oil-filled operational equipment, and except as provided in §112.9(d)(3)for flowlines and intra-facility gathering lines at an oil production facility.The entire containment system, including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system, such as a tank,will not escape the containment system before cleanup occurs. In determining the method,design, and capacity for secondary containment,you need only to address the typical failure mode, and the most likely quantity of oil that would be discharged. Secondary containment may be either active or passive in design.At a minimum,you must use one of the following prevention systems or its equivalent: (1) For onshore facilities: (i) Dikes, berms,or retaining walls sufficiently impervious to contain oil; 1