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Mr.Jeppeson, <br /> I have reviewed the return to compliance for the APSA/SPCC inspection. I was not able to close all violations based on <br /> the statements provided. Please provide a copy of the amended, certified SPCC plan. Many of the proposed changes <br /> are considered technical changes that will need certification from a Professional Engineer. <br /> Item 601— I have included an excerpt from an SPCC example plan provided by the US EPA.This is only an example.The <br /> full example SPCC plan can be found here, under Appendix D-Sample Bulk Storage Facility Plan <br /> Item 604- Ensure plan is amended to reflect the change of the removal of the tank. If the tank is to remain on site it <br /> must meet the requirements of a permanently closed tank. Requirements are attached. <br /> Item 613— Ensure plan is amended to reflect change in tanks, once installed. Plan should also address all requirements <br /> of a bulk storage tank (secondary containment, overfill protection, etc.) <br /> Item 623—Ensure there is a discussion of the lighting as required per SPCC regulations CFR 112. 1 have included <br /> guidance on this as well.The regulations requires to address the appropriateness of security lighting to both prevent <br /> acts of vandalism and assist in the discovery of oil discharges. You may reference the report on lighting which has been <br /> called out in the return to compliance. Any documents referenced would have to be onsite during the APSA/SPCC <br /> inspection. <br /> 706—Will need to review amended and certified SPCC plan <br /> 710—The SPCC plan calls for STI SP-001 standards to be followed for inspection and not API 650 guidelines. Forward a <br /> copy of the inspection report conducted under API 650. If the certifying engineer for the SPCC plan has changed the <br /> testing/inspection standard for the tank(s)forward the amended plan to verify that API 653 standards are what is <br /> called for and what the revised inspection schedule will be for the tank(s). It is possible that some tanks fall under the <br /> STI SP-001 standard and others under the API 653.The engineer will have to certify that the tanks are being <br /> inspected/tested under the correct standards and provide frequency of inspection/testing. <br /> 726—This will have to be part of the SPCC plan discussion. Can be verified once certified SPCC plan is received for <br /> review. <br /> Let me know if there are any questions. <br /> 2 <br />