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<br /> EX IXBXNEXTAL BEBfRXAL TeIeAX`me QA IILS
<br /> BUT
<br /> LBIX G BRIE HIS XIC
<br /> BATEBIL6 TESTING m
<br /> JUN 10,2019
<br /> Mr.Neal VoDkofsky vIaemailvotkofskyratci-leasino.rom
<br /> O.H.S Safety Spec'Iel'Ist
<br /> 14581 Merrill Ave.
<br /> Fontana,Callfodrin 92335
<br /> RE Proposal to Prepare an SPCC Plan
<br /> TO Lesson,Facility
<br /> 2150 W.Charter Way
<br /> Stockton,Celttorner 95208
<br /> ATC Proposal No.054-2019-0 054
<br /> Bear Mr.Volikofsky:
<br /> ATC Group Services LLC(ATC)is pleased to provide HAS propotal in reeponae to your request for preparation of a SPCC Plan for the
<br /> above-referenced bcaton(fill
<br /> ltly).
<br /> BACKGROUND
<br /> In 1988-1989,Two large oil spills,Includl no a 3.8 million gallon oil spill In Pennsylvania and an 11.3 million gallon spill from the grouudlng
<br /> of the Exxon Valdez In Alaska resulted In the development of the oil Spill Prevention, Control, and Countermeasure (SPCC)
<br /> Regulations passed in 1990.Thew regulations are found in Title 40,Pad 112 of the Cade of Federal Regulations(aka 40 CFR Pan
<br /> 112).
<br /> 40 CFR Part 112 requires the preparation and implementation dan SPCC Plan for any non-transportation-related facility,which,due
<br /> to its location,coulI reasonably be expected to dlwhare oil In quantities that may he harmful as defined In 40 CFR Pad 110 ant that
<br /> has the capacity to store oil In volumes greater than or equal to:
<br /> 1,320 gallons In total aboveground storage(counting only containers' with an oil storage capacity of 55 Milo.or more;
<br /> eluding equipment containing oil for ancillary purposes)or
<br /> 42,000 gallons in total completely buned storage(not counting completely buried containers that are currently subject to all of
<br /> the technical requirements of 40 CFR280 or all of the technical requirements m a State program approved under 40 CFR Pan
<br /> 281).
<br /> The purpose man SPCC Plan Is toevaluate and minimize the potential broil discharges from the facility. The SPCC Plan document
<br /> Is designed to complement existing federal and state lams,regulations,rules,standards,policies,and procedures e4ainlng to wfety
<br /> standards,fhe prevention,and pollution prevention ant must address all relevant spill prevention, control, ant countermeasures
<br /> necessaryat the facility.
<br /> Although the regulation Identified facilities with oil greater than 1,320 gallons needed an SPCC,historically enforcement of the SPCC
<br /> regulations was focused on the largest oil storage facilities that mainly serviced the oil needs of oil refineries and airports and other
<br /> handlers of large amounts ofoil. Until the last couple myears and for all but the largest facilities,little effective regulatory attention
<br /> was paid to SPCC Plans except for local agencies checking that facilities storing over 1,320 gallons of oil had an SPCC Plan.
<br /> In 201 the situation in California began to change when Assembly Bill 1130 transferred the responsibility for the Implementation,
<br /> inspection,enforcement,and administration from the California Water Resources Board to the California Unified Program Agencies
<br /> (CUPAs)and overseen by the California State Fire Marshal's Office(CalFhe).Since that time,more and local CUPA Inspectors have
<br /> been trained In SPCCIAPSA by Cal Fire. Consequently,more facilities are being required to complete SPCCs for the That time and
<br /> increased the detail and documentation are bang required In an SPCC. In addition, local agencies are tracking compliance and
<br /> imposing fines and penalties on qualified facilities with Insufficient or absent SPCCs.
<br /> SPCC REOURED INFORMATION
<br /> • Detailed description of all storage of oil and oil containing Products;
<br /> • Detailed information relating to the construction of aboveground storage tanks;
<br /> • Detailed description of gauges used to determine the degree of fullness,overfill protection 4evoes,ant description of
<br /> other associated piping or dispensers,and other oil contain ing equl grenq
<br /> • Detailed description of sized secondary containment structures and examination of their adequecy,wren used;
<br /> • Detailed desert pilon of the oil Now path at the faal Illy,(synonymous with storm water drainage);
<br /> • Evidence of canned In spectlon(and occasionally nondestructive testing)for all aboveground storage tanks 5,001
<br /> gallons In size or greater;
<br /> • Identification Internal emergency response perwnel provided the authority to provide resources In the event of a
<br /> spill;
<br /> • Description of the regular parodic inspections soil storage conte ded;
<br /> • Description of the regular periodic training of facility Personnel that regularly and occasionally hamle the oh;
<br /> • I formation relating to any oil spore within the panobus 12 mentis;add
<br /> • A Cal porn la reglsfered profess'Ional engineer(P.EJ oversee the preparation of ant certify the SPCC Plan.
<br /> SCOPE OF SERVICES
<br /> A California registered professional engineer(RE.)will oversee the preparation ofthe SPCC Plan and certify,the final Plan as requl red
<br /> by 40 CFR 112.3(4).
<br /> The process col beg In with an ATC rep ulatory and oil storage special)ct concluding anon site visit During this site visit,ATC will meet
<br /> with a person familiar wth oil storage at the site with ATC performing a review of all oil containing ASTs or other oil storage containers
<br /> to gather all readily available Information needed for completion of the SPCC Plan.Client responsibilities include,but are int limited
<br /> to providing timely access to the proe4Y, up-todate container and fscillty Information, a description d any eatabl'Ishe4 release
<br /> response procedures ant any other Information determined to he moll for the completion of the SPCC Plan.
<br /> Imes-9 arovB bud QdSTv ane wmwB rases lam,ws).,—ane vide,
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