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Mr.Ruvalcaba July 19,2019 Page 2 • Item 620:CFR 112.7(f)(2)Failure to designate a person accountable for discharge prevention. Please refer to Page i of the SPCC Plan.The Management Responsibility statement assigns responsibility for discharge prevention at the AAFES facility. • Item 715:CFR 112.8(c)(8)(v)Failure to regularly test liquid level sensing devices to ensure proper operation. Appendix B of the SPCC Plan contains inspection checklists derived from STI SP001.Tank liquid level sensing devices are inspected monthly(Item#s 2,7 and 8)and annually(Item#s 15 and 18). Additionally,tank#3 is equipped with a Veeder Root TLS 350 system,which monitors inventory level, provides high-level alarm notification,and provides interstitial monitoring.It performs a tank test and a self-diagnostic every Sunday night.These records are kept for 3 years. • Item 717.•CFR 112.8(c)(10)Failure to promptly correct visible discharges and/or remove accumulations of oil in diked areas.Diesel fuel at the dispenser base nearest Tank#3(12,000-gallon diesel fuel)was cleaned up to prevent migration offsite.Small spill near dispensing stations was cleaned immediately. • Item 718:CFR 112.8(c)(11)Failure to locate properly or provide sufficient secondary containment for mobile/portable containers.The 55-gallon drums of new oil in Building 586 and outside the maintenance shop are now stored on spill pallets that provide containment for the capacity of the drum(as depicted on Figure 5 in Appendix A of the SPCC Plan),I Commented[GT3]:Need to verify with Eddie this has been done. • Item 720:CFR 112.8(d)(1)Failure to provide corrosion protection for buried piping.Section 3.4.2 of the SPCC Plan has been revised to address underground piping between Tank#3 and the associated fuel dispensers.Underground piping is fiberglass-enclosed,galvanized steel pipe.The pipe is fitted with Schrader valves so the annual area can be pressurized to check for leaks.Transition sumps are equipped with electronic leak detection sensors.Personnel check function of the leak detection alarm,and they check the piping transition sumps for leaks monthly.Figure 4 in Appendix A of the SPCC Plan has been modified to depict the underground piping. • Item 723:CFR 112.8(d)(4)Failure to regularly inspect aboveground valves,piping,and appurtenances. Appendix B of the SPCC Plan contains inspection checklists derived from STI SP001.Valves,piping and appurtenances are inspected monthly(Item#s 1-2,5,7-10,and 17)and annually(Item#s 10-17). If you have any questions regarding this response please contact me at 209-234-3711 or jacksondamon@aafes.com Sincerely, Damon Jackson AAFES Loss Prevention Manager cc: