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Ruvalcaba, Cesar <br /> From: Ruvalcaba,Cesar <br /> Sent: Thursday, October 31,2019 2:14 PM <br /> To: 'Paul Hamilton' <br /> Cc: Bobir Hassanov; safety <br /> Subject: RE: APSA/SPCC inspection report- 19501 N HWY 99 - PR0528459 <br /> Attachments: SPCC_Tier_II_Qualified_Facility.pdf <br /> Mr. Hamilton, <br /> I am unable to close any of the violations. <br /> Here is a brief explanation as to why: <br /> Violation#102 Failed to Prepare a written SPCC Plan in accordance with CFR Part 112. <br /> Although the facility will be at 10,000 gallons of total storage capacity,once the 500 gallon tank is properly closed,the <br /> facility still needs an SPCC plan.Any facility with over 1,320 gallons of total storage capacity of petroleum products is <br /> required to have an SPCC plan. Because the facility has a single tank that is larger than 5,000 gallons it qualifies for a <br /> Tier 11 SPCC plan.Tier 11 plans are self-certified,there is a template available,which I have attached. If there is a deviation <br /> from the requirements of the regulations,the deviation does need to be certified by a professional engineer. I have <br /> included some guidance from the EPA on this matter,it can be found here. Submit the completed Tier 11 template for <br /> review. <br /> San Diego County has some trainings on developing Tier I plans,these plans are a bit different from Tier 11 plans,but it <br /> may give you some guidance <br /> https://www.sandiegocounty.gov/content/sdc/deh/hazmat/hmd apsa/hmd tier 1 template course.html <br /> Qualified Facility Applicability <br /> If the facility total aboveground ail storage capacity is 10,000 gallons or less... <br /> And... And the facility has... Then the facility is a: <br /> No individual Tier l Qualified Facility. <br /> Int he threeyea <br /> hars dnorethergesto naviaertified, aboveground oil Complete and self-eertlfy Plan tempi <br /> the facility has had no discharges to navigable containersgreater G to 40 CFR part112)in lieu ofafullF <br /> waters or adjoining shorelines as described below: than 5,000 gallons; Plan or other self-cerOfed SPCC P Ian <br /> • Asir gle discharge of oil greater than 1,090 <br /> gallons,or <br /> • Two discharges of oil each greater than 42 Anyindividual Tier 11 Qualified Facility: <br /> gallonswithin any 12-month period. aboveground oil Prepare a mlf-certified Plan in acmrc <br /> container greaterthan applicable requirementsof§112.7 ar <br /> 5,009 gallons; or C of the rule,in lieu of a PE-certifle <br /> Violation#105—Failure to Properly close tanks when making a claim of Permanently closed. <br /> Based on the pictures and the provided statement the 500 gallon tank is still missing the date of closure.Add the date of <br /> closure to the tank <br /> The regulation states the following <br /> 1 <br />