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Ruvalcaba, Cesar From: Ruvalcaba,Cesar Sent: Friday, May 24, 2019 2:23 PM To: 'Michael Collins' Cc: Justin Keeney, 'GReeves455@aol.com' Subject: RE: APSA/SPCC inspection report- 1250 E. Madruga Rd - PR0515716 Attachments: Industry Standards.pdf, SP001 6th eddion checklists (7).docx Hi Michael, I have reviewed the return to compliance for the facility at 1250 E. Madruga Rd. I have included comments as to why some violations remain open. An updated list of open violations is attached. Violation p 609 I've scanned in the new pages that talks about reporting with updated contact info from Gary. This violation was closed.A small change is needed though.The Local CUPA is the San Joaquin County Environmental Health Department and not the Public Health Services Department.This is considered a non-technical change and can be done by the facility without a professional engineer certification. Violation 1J 612 Gary stated that we don't need Secondary containment because of the new location of the used oil tank. He said the building satisfies the need for Secondary Containment. A couple things with this.This would be something that needs to be addressed in the SPCC plan.This would be a technical amendment and would need to be certified by a registered Professional Engineer.The included cross reference shows that the secondary containment of the tanks is discussed on page 23 and page 28.These pages were not submitted for review and an Professional Engineer amendment has not been provided. There are two SPCC regulations that address secondary containment for tanks.The SPCC plan must address the requirements in the regulations and be certified by a professional engineer.Also any time a tank is removed or added the SPCC plan must be amended to reflect the change and the amendment certified by a Professional Engineer. The regulations for secondary containment are as follow: The first is found in section 112.7 General requirements for Spill Prevention,Control,and Countermeasure Plans. 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; (ii) Curbing or drip pans; (iii) Sumps and collection t