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Thank you, Mike Zimmerman From: Ruvalcaba,Cesar<cruvalcabaCrusigov.org> Sent:Thursday,September 19,20194:31 PM To: Michael Zimmerman<Michael.ZimmermanCcDMCLaneFS.com>;Gary Reeves<garyiDgaryreeyesllc org> Subject: RE: McLane Trucking-PR0515468 ** STOP.THINE.External Email** Michael and Gary, As required by regulations,a facility that has a storage capacity of over 10,000 gallons of APSA regulated petroleum product needs to have a plan which is certified by a professional engineer(PE).The submitted plan has not been shown to be certified by a professional engineer and therefore the violations cannot be closed. Provide an SPCC plan which shows PE certification. As for requesting the plan,it is done to verify that the facility is in compliance after violations are identified.This SPCC plan submission is part of the return to compliance. Below are some violations that have not yet been corrected and could not be corrected even with a PE certification. There were also some new issues from the revision of the SPCC plan. Violation 8603-Failed to adequately describe the physical layout of the facility in the Plan. The facility diagram is still not complete. It is missing a 150 gallon diesel tank. Regulation states"... include a facility diagram,which must mark the location and contents of each fixed oil storage container and the storage area where mobile or portable containers are located.The facility diagram must identify the location of and mark as"exempt' underground tanks that are otherwise exempted from the requirements of this part under§112.1(d)(4).The facility diagram must also include all transfer stations and connecting pipes,including intra- facility gathering lines that are otherwise exempted from the requirements of this part under§112.1(d)(11)._" Violation 8618-Failed to keep records of procedures,inspections,or integrity tests for three years. The SPCC plan does not mention what the industry standard used for integrity testing of the tanks will be.The previous version of the plan stated the Steel Tank Institutes(STI)SP-001 standard was the standard being used. Now the plan only indicates that a standard is being used but the standard is not identified. It is also stated in the SPCC plan that industry standards testing was performed by a certified SP001 inspector on April 16,2019. Without the standard identified by the engineer it is not possible to know what the inspection/testing should consist of. Once an industry standard is identified and the appropriate qualifications for personnel performing tests and inspections and the frequency an type of testing and inspections is specified in the SPCC plan,a statement assuring the department that all required resting and inspections will be conducted per the SPCC plan should be submitted. Here is what the regulations states on the standards. "Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs. You must determine, in accordance with industry standards,the appropriate qualifications for personnel performing tests and inspections,the frequency and type of testing and inspections, which take into account container size, configuration, and design..." New issues found while trying to locate some of the discussions: Section labeled as Mobile or Portable Oil Storage Con@iners 40 CFR 112.8(c)(11) states McLane Company has no mobile and/or portable oil storage containers within their oil product management system. 3