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the some site and types of activity at the site. Contiguous or non-contiguous buildings,properties,parcels,leases, structures,installations,pipes,or pipelines under the ownership or operation of the sameep rson may be considered separate facilities. Only this definition governs whether a facift is subject to this part." So if we can confirm with the owner/operator that the addition of a new FA was not triggered by some change they elected to do we can inactivate it,if the owner confirms that they decided to do so for some reason(leased etc.),we should get them inspected as a separate facilities. Please let me know if that answered your question and please let me know the outcome. Elena From: Ruvalcaba,Cesar<cruvalcaba@siaov.ora> Sent: Monday, December 30,2019 2:42 PM To: Manzo, Elena K.<emanzoPsiaov.ora> Cc: Naidu, Muniappa<MnaiduPsiaov.ora> Subject:Atlantic Aviation APSA- FA0007770 and FA0016555 Hi Elena, I pulled a fresh list for APSA to see what is due for the year. I came across some businesses that have never been inspected that I am looking into.The first one is Atlantic Aviation,which caught my attention since I distinctly remember doing this inspection. I was able to figure out that the facility has two FA numbers since they store product at two different locations at the airport.Their headquarters and shop, FA0007770 6364 Lindbergh St,stores various APSA related tanks along with mobile refuelers. The aviation gas and jet A fuel tanks, FA0016555 5000 Sikorsky St., are located away from the area which I why they have two FA numbers and two CERS ID's. When I did the inspection the SPCC plan was for both the tanks and the HQ/Shop. Both areas were inspected as one since at the time there was only one FA number with an active APSA program. One report was left and decencies for the plan and the sites noted. In December of 2018 someone filled out a pink form to create an APSA PR number for the HQ/shop area.That is the only paper in Laserfiche and there are no narrative entities.There is another APSA PR number for the HQ/Shop that is inactive.This new PR number under FA0007770 is showing up as a facility that has not been inspected,although the inspection was done under the PR number for FA0016555. How would you like to go about this?Should the newly created PR number be deleted,since there is already an inactive PR APSA number for that site?Will this site be regulated as two separate facilities and therefore require two separate inspections using the same SPCC plan?Although the tanks are not contiguous,under SPCC EPA interpretation has much leeway than HM BP and HW. I've attached the EPA discussion on this. Let me know how you would like me to proceed. Below is the rational I used to not consider the"facility'two separate facilities under APSA/SPCC. This is from the attachments taken from the SPCC guidance for Regional Inspectors Definition of Facility The 2008 amendments modified the definition of the term"facility' under§112.2 and clarified that this definition alone governs the applicability of 40 CFR part 112.The amendments also clarified that the owner or operator has the discretion to identify which contiguous or non-contiguous buildings,properties,parcels,leases,structures,installations, pipes or pipelines make up the facility.The amendments also clarified that a facility owner/operator may determine that s/he is no longer subject to the SPCC requirements. However,the revisions note that owners and operators may not 2