COMPLIANCE INFO - Laserfiche WebLink

Home Browse Search

In closing, we are maintaining a "tight schedule" to get this matter resolved promptly as we wish the project to be finalized in accordance with your directives. Thank you. D.Paul McWhorter,CEO SPC Corporation From: Ruvalcaba,Cesar<cruvalcabaC@si¢ov.or¢> Sent: Monday,July 22,2019 11:40 AM To: DPaul<spccorpC@hotn il.com> Cc: Gary delCarlo<hfstracvcaComsn.com> Subject: RE: Return To Compliance-DRAFT submittal for Haley Flying Service Hi Paul, The submitted SPCC plan seems to be a template that has not been completed. None of the violations have been closed. Based on the provided photos,there are some comments for the nurse tanks.The nurse tanks,or mobile refuelers,may not be exempt if they meet certain conditions. I have included some EPA guidance on the matter. The APSA/SPCC regulations will apply to mobile refuelers/Nurse tanks/Tank trucks,which hold APSA regulated product in APSA regulated quantities.You can reference the following paragraph in the SPCC guidance attached,provided by the EPA. If I remember correctly,the diesel nurse tanks had diesel in them or had the possibility of being parked with diesel in them. Tank trucks that are used in interstate or intrastate commerce can also be regulated if they are operating in a fixed, non-transportation mode. For example, if a home heating oil truck makes its deliveries, returns to the facility, and parks overnight with a partly filled fuel tank,it is subject to the SPCC rule if it, or the facility has a capacity above the threshold amount(see Section 2.7), and there is a reasonable expectation of discharge to navigable waters or adjoining shorelines.P 37 P However, if the home heating oil truck's fuel tank contains no oil when it is parked at the facility, other than any residual oil present in an emptied vehicle,it would be regulated only by DOT. Additional guidance can be found in the attached documents. A comment on the SPCC plan,it is stated that"Federal guidelines require the tanks to be inspected weekly; California CUPAs,under CA AboveGround Petroleum Storage Act(APSA)currently pending publication,require monthly inspections'. Under APSA and SPCC regulations,the regulatory agencies do not set any tank inspection frequencies.The inspection frequencies and types of inspections are set by the industry standard,which is approved by the professional engineer.According to section 4.4.2, Inspections and Tests(40 CFR 112.8(c)(6),of the provided Draft SPCC plan,this will be per STI SP-001,but as stated earlier,the submitted draft SPCC plan seems to be a template that has not been completed for the facility. FREE classes presented by NES Inc. are available to all San Joaquin County Hazardous Waste, Underground Storage Tank, and Aboveground Petroleum Storage Facility Business Owners and Operators. List and schedule of classes can be found here. Tha n you, Cesar Ruvalcaba San Joaquin County Environmental Health Department Environmental Health Specialist 1868 East Hazelton Ave Stockton,CA 95205 $ (209)953-6213 1 A (209)464-01381 ® cruvalcaba@si¢ov.or¢ 4