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0012-1 _� Cunha Trucking, Inc. 40 CFR 112.7 The Facility's Conformance with the Requirements of 40 CFR 112.7(a)(1) & (2) Cunha Trucking, Inc. has elected to maintain their aboveground oil product storage in two areas within fuel and oil product structures. Cunha Trucking, Inc. has taken reasonable steps to comply with 40 CFR 112.7 requirements. In each stage of their operational growth attention has been taken to account for the effects of the production and steps have been taken to ensure that methods to divert any hazardous material liquid releases to selected areas thus enabling a sensible and manageable clean up using procedures that can address the situation allowing for a quick and efficient response. The main fuel storage operation is conducted west of the main building. The#2 Diesel fuel tank is securely mounted on concrete with steel concrete anchors. All fueling is controlled and conducted by personnel from Cunha Trucking, Inc. staff. There is no public access to the fuel storage area. Containment for Oil Products consists of: 40 CFR 112.7(a)(3)(i) • 12,000 Gallon Double Wall UL 2085 #2 Diesel Fuel Storage Tank • 550 Gallon Single Wall Used Oil Tank inside a larger containment vessel • 350 Gallon Double Wall Motor Oil Tank inside the shop • Up to 4 55 Gallon Heavy Oil drums contained within the shop on a Containment Pallet with varied amounts of Transmission Fluid and Gear Oil from 0 to 55 gallons per drum Total Oil Product storage for Cunha Trucking, Inc. is approximately 13,120 Gallons. The facility is located along East Madruga Road and limited access to the facility is established by controlled fencing and a dead-end road. Vehicular traffic has limited access in or around the #2 Diesel fuel tank area. The exterior of the fuel and oil storage systems is monitored throughout the operation and any spill will be addressed quickly. Drivers delivering fuel to the 42 Diesel Fuel Storage Tank understand their obligation in controlling fuel spills. As part of the continuous Release Detection Method for compliance with 40 CFR 112.7 and the Steel Tank Institute Annual inspections of the #2 Diesel fuel storage systems are recorded within the SPCC Plan under Appendix B & C. The Used oil is stored just North East of the shop in an open area within a steel containment structure. Transfer of used oil from the shop the Used Oil tank is done by hand in buckets and a pneumatic transfer is used. The storage areas for the 55-gallon drums are also monitored and the inspections are recorded in Appendix B & C. All shipments of new oils are conducted by certified and trained personnel who understand the delivery requirements and have the training to respond to a release of oil products. Metal thickness testing is required on the tanks due to their construction consisting of a carbon steel wall. Testing was performed on October 3, 2018. A release of oil products into the environment will most likely be through the delivery or dispensing of fuels and/or oils into or out of the controlled settings. Should a catastrophic spill occur, such as rupture of the diesel tank, there would be up to 12000 gallons of diesel fuel flowing in all directions from the tank until berms or other methods are used to contain it. Gary Reeves. LLC 9