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Thank you very much for providing the SPCC plan for your facility. I have the following comments that need to be <br /> addressed: <br /> 1) Figure 3 of your SPCC plan doesn't show any connecting piping- is there any piping connected to the tank or is the <br /> equipment filled directly from the tank via fill hose? <br /> a. (per 40 CFR: (3) Describe in your Plan the physical layout of the facility and include a facility <br /> diagram, which must mark the location and contents of each fixed oil storage container and the storage <br /> area where mobile or portable containers are located.The facility diagram must identify the location of <br /> and mark as "exempt" underground tanks that are otherwise exempted from the requirements of this <br /> part under§ 112.1(d)(4).The facility diagram must also include all transfer stations and connecting <br /> pipes, including intra-facility gathering lines that are otherwise exempted from the requirements of this <br /> part under§ 112.1(d)(11). We added transfer piping to the figure. <br /> 2) Page 12 of your plan number 6); indicated that integrity inspection requirements are listed in section 1.5—no <br /> requirements are listed in that section. We have changed the reference of section 1.5 to section 1.6. <br /> 3) Also, section 2.3- 112.8(c) didn't identify the qualifications for personnel performing tests and inspections (which is <br /> supposed to be addressed in this section). We have changed the reference of section 1.5 to section 1.6 on page 12, <br /> section 2.3, number 6 (same edit as above). <br /> Please send me the revised pages at your earliest <br /> convenience. Please don't hesitate to call me if you have <br /> any questions. <br /> Sincerely, <br /> Elena K. Manzo, Lead Sr. REHS, SANsJOAOUIN <br /> San Joaquin County COUNTY- <br /> Environmental <br /> TYEnvironmental Health Department <br /> 1868 E. Hazelton Ave. <br /> Stockton, CA 95205-6232 <br /> Voice: (209) 953-7699 <br /> 2 <br />