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Cesar Ruvalcaba [EH] From: Cesar Ruvalcaba [EH] Sent: Thursday, March 28, 2019 4:18 PM To: '4P@vaztrucking.com' Subject: Return to compliance review APSA inspection - San Joaquin County Environmental Health Department - PR0515786 Hi Debbie, I have reviewed the SPCC plan which has been submitted to address the violation associated last Aboveground Petroleum Storage Act(APSA) inspection. Below are some of my observations on what the plan is lacking or does not fully discuss.There may be other sections which are not addressed or nor fully addressed. I would suggest that the plan writer review the regulations to ensure all applicable aspects are covered. I sample plan developed by the USA EPA can be found here (read disclaimer on first page) and guidance on SPCC can be found here Section 112.3(d)(1) • Required attestations by the engineer • (i)That he is familiar with the requirements of this part; • (ii)That he or his agent has visited and examined the facility; • (iii)That the Plan has been prepared in accordance with good engineering practice, including consideration of applicable industry standards, and with the requirements of this part; • (iv)That procedures for required inspections and testing have been established; and • (v)That the Plan is adequate for the facility. Section 112.7 • -The Plan does not follow the sequence outlined in the Code of Federal Regulations and a cross-reference is not provided. Section 112.7 (a)(1) • discussion of your facility's conformance with the requirements listed in part 112.7 Section 112.7 (a)(3)(ii) • Discharge prevention measures including procedures for routine handling of products (loading, unloading, and facility transfers, etc.); Section 112.7 (a)(3)(vi) • Contact list and phone numbers for the facility response coordinator, National Response Center, cleanup contractors with whom you have an agreement for response, and all appropriate Federal, State, and local agencies who must be contacted in case of a discharge.This includes the California Office of Emergency services spill report phone number. Section 112.7 (a)(4) • Unless you have submitted a response plan provide information and procedures in your Plan to enable a person reporting a discharge to relate information on the exact address or location and phone number of the facility; the date and time of the discharge,the type of material discharged; estimates of the total quantity discharged; estimates of the quantity discharged;the source of the discharge; a description of all affected media;the cause of the discharge; any damages or injuries caused by the discharge; actions being used to stop, remove, and mitigate the effects of the discharge;whether an evacuation may be needed; and,the names of individuals and/or organizations who have also been contacted. Section 112.7(g) • Describe in your Plan how you secure and control access to the oil handling, processing and storage areas; secure master flow and drain valves; prevent unauthorized access to starter controls on oil pumps; secure out-of 1