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Cc: Matt Nickum <mnickum@vftrans.com> Subject: RE: SPCC Hi Eric, Apologies for the delay and thank you for getting everything submitted. I was able to review all the RTC forms and supporting documentation. Please see my notes below about what is still needed to close out the remaining violations. Additionally, I reviewed and processed the facility's most recent CERS submittal. The feedback on CERS should provide additional clarification about what is needed for the site map for the HMBP inspection (item 11 below). Please feel free to pick up the SPCC Plan whenever is convenient for you, after you have a chance to review my notes below give me a call and we can talk about next steps. Hazardous Materials Business Plan (HMBP) inspection: • 3 - Resolved, will be verified at the next inspection. • 5 - Resolved. • 11 -Site map is missing required information. Please refer to the regulation guidance section on the original inspection report. Also, see CERS. Small Quantity Generator, Hazardous Waste (SQG HW) inspection: • 2 -Provide info on the training. Was it an organization/class? Who provided training? The sign in sheet looks specific to the SPCC Plan. Hazardous Waste is a separate and distinct training, I don't see mention of it on this form. • 11 - RTC form states the STIHL motomix was "disposed of correctly". Provide more info. Is it on one of the submitted disposal records? • 21 - Resolved. However, the copy submitted is almost impossible to read. You can look these up on DTSC's website, the version they have is clear so if the copy you have is unreadable you can print out a new copy from DTSC. • 23 - Resolved. • 48 -This is required to be posted on site. Please send photo verification. Aboveground Petroleum Storage Act (APSA) inspection: 11 items closed, 4 remain open. • 7 - Resolved. • 10 - Resolved. • 15 - Resolved. • 16 - Resolved. • 20 - Resolved. • 24 - RTC form says there should be pictures of spill kits included but I don't see any pictures. Please clarify/provide photos that materials mentioned on page 16 ("absorbent materials, pads, and/or booms") have been provided. • 30 - Resolved. • 31 -Resolved. • 32 - Resolved. • 42 - Resolved. • 48 -Appendix F was not included in the printed copy but was in the PDF you emailed. Is this copy considered the facility's copy? If so, appendix F needs to be added. Please clarify. • 52 - Resolved. • 57 - Received last 3 annual inspections but no monthly inspection. Provide update on when monthly inspections are scheduled to start/completed checklist from first monthly inspection. • 59 - Resolved. 2