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3 <br /> On page 14 under the heading Superficial RunoƯ the SPCC Plan does state that storm drain covers are to <br />be used in the event of a major spill and during transfer operations. But then again on page 17 under the <br />heading Routine Handling of Products, there is no mention of use of storm drain covers during transfer <br />operations. <br /> The RTC statement for item #24 says that the fuel truck drivers have adequate equipment on their trucks <br />for this purpose. Do the spill kits discussed in the RTC statement for item #52 that have been added at the <br />site have storm drain covers in them? Or is the facility relying on the materials of the fuel delivery drivers? <br />Use of the driver’s materials is not mentioned anywhere in the SPCC Plan that I can see. Please clarify this <br />in the updated SPCC Plan. <br /> <br />#20 – On page 22 of the updated plan: <br /> California EMA is still listed, but this agency is now called CalOES <br /> CA Dept of Fish & Game is listed, but this agency is now called Fish & Wildlife. <br /> The phone numbers for Regional Water Quality Control Board and the CA Dept of Fish & Game still list the <br />Cal Spill Reporting number, I believe this is what you were referring to and needed to confirm to finalize the <br />updated SPCC Plan. <br /> <br />#29 – Resolved <br /> <br />#30 – Resolved <br /> <br />#32 – Resolved <br /> <br />#52 – While the statement provided is related to this item, it does not adequately address the violation. The return <br />to compliance statement should indicate that going forward records of drainage from diked areas will be <br />maintained on site for three years (include any pertinent information like where those records will be kept since it <br />is an unmanned site). <br /> <br />#56 – I see the work order for 3/28/18 – is this the correct record for the integrity test? I don’t see results from the <br />types of testing methods I would expect to see from typical integrity testing (hydrostatic, radiographic, ultrasonic, <br />acoustic emissions, etc.) <br /> <br />#57 – It’s good to see that you were able to find some monthly inspection records for the tank. I do have some <br />concerns since it doesn’t look like the open drain valve or the damaged pipe support were observed in any of these <br />inspections. However, for the RTC what I really need is a statement indicating that going forward monthly <br />inspections will be conducted and records kept on site for three years (include any pertinent information like <br />where records will be kept). Also, the updated SPCC Plan states that the inspection checklist in Attachment B <br />should be used for monthly checks, but the checklist is not actually included with the plan. <br /> <br />#68 – Resolved <br /> <br />#74 – CERS submittal is missing APSA element <br /> <br />Please let me know if you have any questions. <br /> <br />Best, <br /> <br />Lynsey Sammons <br />Environmental Health Specialist <br />Cell: (209) 616-3067 <br />Office: (209) 468-3420 <br /> <br />San Joaquin County Environmental Health Department