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Ruvalcaba, Cesar From: Ruvalcaba,Cesar Sent: Thursday, June 13,2019 3:37 PM To: 'Martin Jeppeson' Subject: RE: 2019 SPCC PIAN DRAFT- PR0528393 Hi Martin, None of the violations could be closed.The SPCC plan needs to be certified most of the changes are considered technical. Below are some observations on the SPCC plan and the open violations. Comments on the plan Violation#601 -Failure of Plan to fulfill basic requirements including a cross-referencing section. The cross-referencing section may need to be revised. I tried using it to make the review process go a little faster but the page numbers in the cross referencing do not match up with the discussion. For example,per the cross-referencing table section 112.8(c)(2)which covers secondary containment is discussed on pages 4 and 5. Page 4 and 5 are dedicated to spill prevention response and tests and inspections.There is no mention of secondary containment on those pages.Also section 112.(c)(11)is not addressed.This section addresses secondary containment of mobile or portable containers. There may be other issues with the cross-reference. Violation#623-Plan failed to address security of site and valves,lock out/tag out,and lighting. The regulations states the following on lighting—address the appropriateness of security lighting to both prevent acts of vandalism and assist in the discovery of oil discharges. Violation#710- Plan failed to adequately discuss procedures to test or inspect each container for integrity. The SPCC plan still fails to follow the STI-SP001 standard.The plan only calls for monthly inspections. SP-001 has specific monthly and annual inspections to be conducted by the facility. Under the SP-001 standard,tanks can fall under 3 different categories and inspection types and frequencies by a certified inspector vary based on the category.The Engineer should list the inspection frequency based on the category of the tanks,if formal certified inspections are required for the tanks under SP-001. qualifications of personnel performing the tests and inspections,per the SP-001 standard,are not discussed. If the 20,000 gallon tank is due for a certified inspection under the SP-001 standards,the testing/inspection should be conducted and results provided to our office. It seems that a PE,SE evaluated the tank on 01/02/2019 under API 650 guidelines. Was this individual also a certified STI SP-001 inspector or an API 653 inspector with an adjunct STI SP001 certification? If s, provided the inspection report. Is the tank being inspected under API 653 standards? If so this would need to be addressed in the plan. Furthermore the included inspection checklist references API standard 653. The regulation states: . The qualifications of personnel performing tests and inspections, frequency and type of testing and inspections that take into account container size,configuration, and design shall be determined in accordance with industry standards. Violation#726-Plan failed to adequately describe overfill prevention methods for each container. It appears that only the 20,000 gallon diesel tank is addressed.The requirements is for any APSA regulated tank to have one of the following and the overfill prevention method to be addressed in the SPCC plan. (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. 1