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1 Presto, Carol [EHD] From:Presto, Carol [EHD] Sent:Monday, March 30, 2026 1:06 PM To:'Lopez, Nicasio'; Alaniz, John [EHD] Cc:Corren, Nikolas@CDCR; Brown, Pat@CDCR; Saetern, Kristina Gaen [EHD] Subject:RE: CHCF Certified SPCC Plan and Return to compliance documents Follow Up Flag:Follow up Flag Status:Completed Good Afternoon Nicasio, Thank you for the submittal of the SPCC Plan. I’ve reviewed the plan and submitted RTC document. Below is a summary of open violations showing what has been closed and what is still open. I’ve also copied Kristina Saetern who you’ve spoken with while I was on leave who will be following up on the APSA RTC. Summary of open items below: #03 – CLOSED #10 – CLOSED #11 – Plan does not follow order of the regulations and a cross reference was not included. For example, in the regulations impracticability discussion is112.7(d) followed by inspections with written procedures in112.7 (e). In the SPCC Plan, Demonstration of Impracticability §112.7(d) is in section 5.2.9 but inspections §112.7(e) are not discussed until section 10 of the SPCC Plan. Therefore, not following the sequence specific in the regulations. When plans don’t follow the sequence they require a cross reference section which was not included in the SPCC Plan. Please review the whole plan and ensure an accurate cross reference is included. In addition the SPCC Plan makes inaccurate references for example: In Section 5.2.6 states that Secondary containment provided for ASTs is discussed in 5.2.9 but 5.2.9 is Demonstration of Impracticability. Section 5.2.8 Aboveground Tanks states that tanks are double walled as described in Table 3.1 but that Table 3.1 is not found in the plan. #15 – CLOSED #16 – New and used oil storage containers are not shown on the maps on pages 30-35 in the SPCC Plan as indicated in the submitted RTC document. Page 30 of the SPCC Plan is not legible. Piping is not shown for the 8,000-gallon gasoline AST and 2,000-gallon diesel AST as requested on the inspection report. #17 – Section 5.2.3 discusses generators in CHCF but does not discuss generators in NCYCC. Discharge prevention measures need to be included for generators in NCYCC. Section 7.3 Spill Prevention has a paragraph titled “CHCF – Spill Discovery and Response Procedures” but not one for NCYCC. #18 – Section 8 Petroleum Spill Contingency Plan discusses actions for the fueling station and the generators but does not provide information for non-generator area petroleum tanks/containers, such as the used oil drum. #20 – Evacuations were not included as part of the Spill Incident Report Form in section 8.2 or on the actual form in Appendix D.