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1500 East Madruga Road PR0515717 <br /> March 8, 2022 Program: APSA <br /> PHOTO 1: SPCC plan states that motor oil tank is single wall. Motor oil tank was double walled. SPCC plan lists "several" 55 gallon drums. SPCC plan <br /> lists secondary containment for some containers as the shop. Shop was observed with entrances that slope outside and cracks in concrete. <br /> Cunha Trucking, Inc. <br /> 40 CFR 112.7 <br /> The Facility s Conformance with the Requirements of 40 CFR 112.7(a)(1)&(2) <br /> Cunha Trucking,Inc.has elected to maintain their aboveground oil product storage in two <br /> areas within fuel and oil product structures.Cunha Trucking,Inc.has taken reasonable steps to <br /> comply with 40 CFR 112.7 requirements.In each stage of thew operational growth attention has <br /> been taken to account for the effects of the production and steps have been taken to ensure that <br /> methods to divert any hazardous material liquid releases to selected areas thus enabling a sensible <br /> and manageable clean up using procedures that can address the situation allowing for a quick and <br /> efficient response.The main fuel storage operation is conducted west of the main building.The#2 <br /> Diesel fuel tank is securely mounted on concrete with steel concrete anchors.All fueling is <br /> controlled and conducted by personnel from Cunha Trucking,Inc.staff.There is no public access <br /> to the fuel storage area. <br /> Containment for Oil Products consists of 40 CFR 112.7(a)(3)(i): <br /> • 12,000 Gallon Double Wall UL 2085#2 Diesel Fuel Storage Tank <br /> • 550 Gallon Single Wall Used Oil Tank inside containment <br /> • 350 Gallon Single Wall Motor Oil Tank contained within the shop <br /> • 2—55 Gallon Heavy Oildrums contained within the shop <br /> ' • Several 55-gallon oil product drums within the shop area and outside the shop <br /> Total Oil Product storage for Cunha Trucking,Inc.is approximately 13,300 Gallons. <br /> The facility is located along East Madruga Road and limited access to the facility is <br /> established by controlled fencing and a dead-end road.Vehicular traffic has limited access in or <br /> around the#2 Diesel fuel tank area The exterior of the fuel and oil storage systems is monitored <br /> throughout the operation and any spill will be addressed quickly.Drivers delivering fuel to the 42 <br /> Diesel Fuel Storage Tank understand their obligation in controlling fuel spills.As part of the <br /> continuous Release Detection Method for compliance with 40 CFR 112.7 and the Steel Tank <br /> Institute monthly inspections of the#2 Diesel fuel storage systems are recorded within the SPCC <br /> Plan under Appendix B&C.The Used oil is stored just West of the shop in an open area within a <br /> steel containment structure.The shop is the secondary containment for the 350-gallon new motor <br /> oil tank.Transfer of used oil from the shop the Used Oil tank is done by hand in buckets and a <br /> pneumatic transfer is used.The storage areas for the 55-gallon drums is also monitored and the <br /> inspections are recorded in Appendix B&C.All shipments of new oils are conducted by certified <br /> and trained personnel who understand the delivery requirements and have the training to respond <br /> to a release of oil products. Metal thickness testing is required on the tanks due to their <br /> construction consisting of a carbon steel wall. Testing was performed on October 3,2018.A <br /> release of oil products into the environment will most likely be through the delivery or dispensing <br /> of fuels and/or oils into or out of the controlled settings. <br /> r � <br /> Gary Reeves,LLC 9 <br /> Lydia Baker, SR. REHS Page 1 of 15 <br />