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Ruvalcaba, Cesar From: Ruvalcaba,Cesar Sent: Monday,August 19, 2019 1:05 PM To: 'Martin Jeppeson' Subject: RE: 2019 SPCC PIAN DRAFT- PR0528393 Attachments: Open Violations.pdf Hi Martin, The latest SPCC plan has been reviewed.There are several violations that have been closed,but there are a couple that remain open.Attached is an updated list of the open violations and below are comments on why the violations would not be closed. Violation#710-Plan failed to adequately discuss procedures to test or Inspect each container for Integrity. The SPCC plan states that"Table 5.5,SP-001 identifies a formal external inspection every twenty(20)years.The most recent inspection occurred on November 5,2009 and was conducted by Pacific Tank&Construction,Inc."An STI SP-001 certified inspection report was not provided at the time of the inspection. Provide the 11/05/2009 inspection report that shows the tank referred to in the plan was tested/inspected to industry standards by Pacific Tank&Construction, Inc. or report that meets the requirements of the STI SP-001 standard. 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. Tanks not addressed are bulk storage containers(I 10 gallon diesel tank,210 gallon diesel tank, 55 gallon waste oil drum)The compressors tall under operational equipment. (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, lelepulse, 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. Feel free to contact me with any questions. 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. 1