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Baker, Lydia <br /> From: Sarah C. Williams <SCwilliams@WilliamsTankLines.com> <br /> Sent: Thursday, April 30, 2020 9:26 AM <br /> To: Baker, Lydia; Mark Lill; David Ray; Garth Williams <br /> Cc: Gary Reeves <br /> Subject: RE: [External Email]RE: [External Email]FW: Return to Compliance <br /> Attachments: WTL Certification Page.pdf <br /> Good morning Lydia, <br /> Attached is the Engineer certification page you requested for Violation#301. <br /> Documentation pertaining to#701 you should have received or will be receiving from Mr. Reeves. <br /> -Sarah <br /> From: Baker, Lydia <Ibaker@sjgov.org> <br /> Sent: Monday,April 27, 2020 10:51 AM <br /> To: Sarah C. Williams<SCwilliams@WilliamsTankLines.com>; Mark Lill <mark@williamstanklines.com>; David Ray <br /> <David@Will iamsTankLines.com>; Garth Williams<gwilliams@WilliamsTankLines.com> <br /> Cc: Gary Reeves<gary@garyreevesllc.org> <br /> Subject: [External Email]RE: [External Email]FW: Return to Compliance <br /> Hello Sarah, <br /> I reviewed what you sent over and I am unable to close out the open violations. Here is what I need to close out the <br /> violations: <br /> #301-Please provide a copy of the Professional Engineer certification page. <br /> #701-The pages provided do not fully discuss the testing/inspection procedures as required by the regulations. The <br /> regulation states: <br /> 40 CFR 112.8(c)(6) Test each aboveground container for integrity on a regular schedule, and whenever you make <br /> material repairs. The frequency of and type of testing must take into account container size and design (such as <br /> floating roof, skid-mounted, elevated, or partially buried). You must combine visual inspection with another <br /> testing technique such as hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, <br /> or another system of non-destructive shell testing. You must keep comparison records and you must also inspect <br /> the container's supports and foundations. In addition, you must frequently inspect the outside of the container <br /> for signs of deterioration, discharges, or accumulation of oil inside diked areas. Records of inspections and tests <br /> kept under usual and customary business practices will suffice for purposes of this paragraph <br /> From reading the provided pages here are the questions I have: <br /> -Which STI standard are you using? <br /> -What about testing/inspection of the other containers? <br /> -What about visual inspections done by facility personnel? <br /> If possible I would like a copy of the entire SPCC plan so that I can review it. The above items may be covered in other <br /> sections. If you have any questions or need assistance please let me know. <br /> 1 <br />