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SANJOAQUIN —C Ol,!rJ T Y— Gnorn ess gros hero From: Ruvalcaba,Cesar Sent:Thursday,October 31,2019 1:12 PM To:'Davis Winters'<dwinters@panellatruckina.com> Subject: RE: Inspection Report-PR0527046 Hi Davis, The SPCC plan has been reviewed. Most of the violations have been addressed. There are a couple of violations that need a written statement of clarification. Violation#706 requires a written statement that assures the department that all holes in the concrete wall used for secondary containment have been addressed. Violation#718,it is unclear what the secondary containment will be for the mobile or portable containers. This is what the SPCC plan states for the section dealing with this violation 5.2.12.Mobile and Portable Containers-40 CPR 112.8(c)(11) The facility utilizes several mobile oil tanks,waste oil tanks and diesel fuel tank in the service of trucks.The ASTs are utilized in the repair shop area and are stored inside on concrete paving overnight and are closed at all times;unless oil filling or removal is conducted and overseen by a trained Facility personnel. This is what the regulation states: (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. The SPCC plan,table 8,seems to suggest that the Maintenance and Main Shop buildings will be secondary containment for the 100 gallon waste-oil tanks.The plan used to call for secondary containment pallets for the 55 gallon drums,now it has been amended,per table 8, so that secondary containment is spill kits. If this is correct let me know or if not let me know what the secondary containment is for the 100 gallon tanks and the 55 gallon drums. Attached is a list of the violations that remain open. Once the statement is received for#706 it can be closed. Depending on what secondary containment is for#718,that may be addressed as well. Also,you may want to revisit Appendix A,Substantial Harm Determination form.Question 1 is marked as Yes.This would trigger requirements to submit paperwork to the US EPA.This is self-certification and you can make changes to the questionnaire. Here is how the regulation is written and what must be done if question one is marked as Yes. A facility that has the potential to cause substantial harm to the environment in the event of a discharge must prepare and submit a facility-specific response plan to EPA in accordance with appendix F to this part.A description of the screening criteria for the substantial harm flowchart is provided below: 2.1 Non-Transportation-Related Facilities With a Total Oil Storage Capacity Greater Than or Equal to 42,000 Gallons Where Operations Include Over-Water Transfers of Oil.A non-transportation-related facility with a total oil storage capacity greater than or equal to 42,000 gallons that transfers oil over water to or from vessels must submit 2