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Ruvalcaba, Cesar From: Ruvalcaba,Cesar Sent: Wednesday,July 10,2019 1:54 PM To: 'DPaul'; Gary delCarlo Subject: RE: Haley Flying Service- PR0515798 Paul, Just a quick note A. Since the facility has capacity of over 10,000 gallons of petroleum product,it does not qualify for Tier 11 template.The Tier 11 template was designed for facilities that have less than 10,000 gallons of capacity but have a single tank that is larger than 5,000 gallons and is meant for self-certification by the facility.The facility, because of its capacity does not qualify as a Tier 11 facility and requires a certification from a Professional Engineer(P,E.)for the entire plan. CFR sections 112.7 and 112.8,as well as 112.1 through 112.5. need to be addressed in the SPCC plan. The regulations can befound here.Sample P.E Certified plan,developed bythe EPA,can be found here,when we spoke on the phone I thought you were referring to this sample plan. The sample plan is part of the SPCC Guidance for regional inspectors,which can be found here. B. For the overfill prevention,here is what the regulations states Engineer or update each container installation in accordance with good engineering practice to avoid discharges.You must provide at least one of the following devices: (i) High liquid level alarms with an audible or visual signal at a constantly attended operation or surveillance station. In smaller facilities an audible air vent may suffice. (ii) High liquid level pump cutoff devices set to stop flow at a predetermined container content level. (iii) Direct audible or code signal communication between the container gauger and the pumping station. (iv)A fast response system for determining the liquid level of each bulk storage container such as digital computers, telepulse,or direct vision gauges. If you use this alternative, a person must be present to monitor gauges and the overall filling of bulk storage containers. (v)You must regularly test liquid level sensing devices to ensure proper operation. C. The industry standard is ultimately selected by the certifying engineer. If the SPCC plan states that the facility will utilize the STI SP001 standard,then the facility must follow the standard as written.The standard has specific requirements,one of them being using their inspection frequency and inspection list criteria or the equivalent. D. If there are no changes to the facility that affect the SPCC plan,the plan can be evaluated every 5 years.Also per the STI SP-001 inspection frequency by a certified inspector,depending on what category the tanks fall under and the size of the tanks,the frequency maybe 5, 10 or 20 years. I would recommend stating what category the tanks fall under,according to the STI SP-001. Depending on the category,additional testing may be required. I would also recommend giving a reason if an inspection frequency more aggressive than the STI SP-001 standard is recommended.Are there certain issues or concerns with the tanks that may prompt more frequent inspections? Here is what the regulations state for the industry standards- ...You must determine, in accordance with industry standards,the appropriate qualifications for personnel performing tests and inspections,the frequency and type of testing and inspections,which take into account container size,configuration, and design... t