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Ruvalcaba, Cesar From: Ruvalcaba, Cesar Sent: Wednesday, May 1, 2019 2:20 PM To: 'Martin Jeppeson' Subject: RE: SPCCC - PR0528393- 2323 W PORT RD G Hi Martin, I have reviewed parts of the SPCC plan that seem to address the open violations. The cross reference was utilized to help find the appropriate sections. Based on the review, none of the remaining open violations have been closed.The plan in some instances seems to have the same issues as when the inspection was conducted. Since the deficiency letter has been mailed out there is a charge of$152 per hour for review of return to compliance. Keeping this in mind, as mentioned in your response,you can come into the office and discuss the plan but the time would be chargeable. I tried to include notes as to why the violations have not been addressed. If you would prefer to come into the office, contact me to set up a date and time. Going through the provided cross reference I noticed that that section 112.8(c)(11) is not addressed in the plan.This section addresses secondary containment of mobile or portable containers.According the plan the facility has 55 gallon drums. Per EPA these drums fall under the mobile/portable container category. #601 - Failure of Plan to fulfill basic requirements including a cross-referencing section. The cross reference section is not complete or directs the user to incorrect page numbers. For example section 112.(c)(11) is not addressed. This section addresses secondary containment of mobile or portable containers. According the SPCC plan the facility has 55 gallons drums, which are mobile/portable containers. Another example is section 112.8(c)(2), the cross reference directs to pages 4 and 5. The discussion is on pages 2 and 3, from what I can tell. #613 - Failure to provide appropriate secondary containment, diversionary structures or equipment. It is still unclear as to what the secondary containment is for the 110 gallon tank. The amended SPCC plan states the following "One generator (G-2) has an integrated fuel tank, the second (G-1)has an external fuel tank that is inside of secondary containment, Most likely failure mode would result from operator error during refueling, with an estimated spill quantity of less than five gallons." This does not address the regulations, which states in part 112.7(c) The entire containment system, including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system, such as a tank, will not escape the containment system before cleanup occurs and 112.8 (c)(2) Construct all bulk storage tank installations (except mobile refuelers and other non-transportation-related tank trucks) so that you provide a secondary means of containment for the entire capacity of the largest single container and sufficient freeboard to contain precipitation. You must ensure that diked areas are sufficiently impervious to contain discharged oil. Dikes, containment curbs, and pits are commonly employed for this purpose. You may also use an alternative system consisting of a drainage trench enclosure that must be arranged so that any discharge will terminate and be safely confined in a facility catchment basin or holding pond. The engineer should also certify that the diked area for the 20,000 gallon tank is sufficiently impervious to contain discharged oil, since the dike is soil. Also, the 55 gallon drums do not appear to have secondary containment addressed. 1