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Ruvalcaba, Cesar From: Ruvalcaba,Cesar Sent: Wednesday, May 8, 2019 3:54 PM To: 'Garth Williams' Cc: 'Sarah C.Williams' Subject: FW: Return to Compliance APSA/SPCC - 1477 TILLIE LEWIS DR- PR0523160 Garth, I have received and reviewed the return to compliance that was submitted on April 30,2019.The remaining violations continue to be open for the following reasons. There were changes to the SPCC plan made that are considered technical amendments.Technical amendments to the SPCC plan require the certification of a Professional Engineer. Submit the certification of the Professional Engineer for the technical changes. Violation#301 The section labeled as 40 CFR 112.8(c)(11)still does not address regulation in full. Section 112.8(c)(11)states 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. The provided portion of the plan does not address secondary means of containment or secondary containment capacity for the mobile or portable containers. Violation#710 The SPCC plan does not address the appropriate qualifications for personnel performing tests and inspections,the frequency and type of testing and inspections per industry standards. Page 25 and 31 seem to address the inspections of the tanks.There is not enough information for the facility to follow the STI standard. Below are some suggestions.This is not a comprehensive list of items that may need to be addressed. The formal (by certified inspector)inspection frequency is set at five years: • Is this for all tanks? • Is the frequency 5 years because of the category of the tanks? If so,additional testing must be addressed as required by the STI standard.A five year testing frequency can be associated with a category 2 or category 3 tank.Additional required testing and frequencies must be addressed by the plan. The five 5 cycle can also apply to Feld erected tanks,additional requirements for these type of tanks should be addressed. The SPCC plan deviates from the STI SP-001 Standard: • The SPCC plan only calls for monthly inspections for the facility.The STI standard calls for monthly and annual inspections using their inspection criteria. • What are the qualifications of the personnel conducting the facility inspections? • The provided"Certified Non-Destructive Ultrasonic Testing' by itself does not meet the requirements of the STI standard of a certified inspection. Mr. Reeves has been made aware by the Steel Tank Institute(STI)that the "Certified Non-Destructive Ultrasonic Testing" does not meet the standards of the reports required under the STI SP-001. 1