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Ruvalcaba, Cesar From: Ruvalcaba,Cesar Sent: Tuesday, May 7,2019 1:33 PM To: 'Chelsea Bossenbroek' Cc: Ron Jackson; Paul Craft Subject: RE: SPCC Plan for San Joaquin County Environmental Health Attachments: SP001 6th edition checklists (7).cl SPCC Guidance for Regional Inspectors -...mple Bulk Storage Plan(November 201 20190507132746921.pdf Hi Chelsea, Thank you for sending the SPCC plans. Combined both plans seem to meet most of the requirements.A more thorough review will be conducted during next inspection. There is a little concern that the original plan is addressing sections of the regulations that are meant for self- certification,sections labeled as§112.6.Your facility does not qualify and should not address these sections.As long as the required sections and discussions are addressed this won't be a big deal,this will be verified during next inspection. What is of concern though,is that the inspection on the tanks is not addressed as required by regulations.The regulations call for an industry standard to be utilized,approved by the Professional Engineer(P.E.)based on several factors of the tanks and facility. Based on the tanks that are on site,the typical industry standard would be the Steel Tank Institute SP-001 standard. Whichever standard the P.E.thinks is best,the frequency of inspections,types of inspections and qualifications of the inspector should be discussed in the plan. Currently there is no industry standard selected for the tanks.This may not be the only issue with the plan,as stated above,a detailed review of the plan was not conducted. I have included a sample SPCC plan,provided by the EPA and a discussion of the industry standards. Both items come the EPA's SPCC Guidance For Regional Inspectors and can be found at the following link bUs://www.e aa.gov/oil- sp:lUs-prevention-and- rereparedness-regulations/spcc-guidance-regional-inspectors I have also included inspection checklists from the STI standard, which may be used until a standard is selected by the RE FREE classes presented by NES Inc. are available to all San Joaquin County Hazardous Waste, Underground Storage Tank, and Aboveground Petroleum Storage Facility Business Owners and Operators. List and schedule of classes can be found here. Tha n you, Cesar Ruvalcaba San Joaquin County Environmental Health Department Environmental Health Specialist 1868 East Hazelton Ave Stockton,CA 95205 $ (209)953-6213 1 A (209)464-01381 ® cruvalcabaPsigov.org SAN ICAQUIN 1