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Cesar Ruvalcaba [EH] <br /> From: Bob Buckley <bbuckley@wgr-sw.com> <br /> Sent: Thursday,January 10, 2019 10:42 AM <br /> To: Cesar Ruvalcaba [EH] <br /> Cc: Henry Sr. Rotor <br /> Subject: Re:Alegre Trucking: CUPA Inspection on 10-05-2018 (Return to Compliance <br /> Certification and Supporting Documents) <br /> Hello Cesar, <br /> Attached is the final version of the SPCC Plan with PE Certification. <br /> Also, regarding your comment about the Overfill Protection, I have one comment. Although not <br /> specifically mentioned, the Overfill Protection, applies to all applicable tanks at the Alegre Facility <br /> including the Synblend tank. This verbiage has always been adequate for the facility. <br /> Thank you, <br /> Bob Buckley <br /> http://download.wgr-sw.com/documents/5c379192ab4bb-Frank-C-Alegre-SPCC-Plan-O 1-10-2019.pdf <br /> Bob Buckley <br /> Senior Compliance Specialist <br /> WGR Southwest, Inc. <br /> 11780 N. Hwy. 99 <br /> Lodi, CA 95240 <br /> (209) 334-5363 Ext. 108 <br /> On 11/19/2018 2:08 PM, Cesar Ruvalcaba [EH] wrote: <br /> Hi Bob, <br /> The submitted return to compliance and SPCC plan addressed most of the violations.The only remaining <br /> violation is the one dealing with certification of the SPCC plan. Once the plan is certified by the P.E. <br /> forward the plan or link to the plan and that will resolve the last violation. <br /> I did not review the whole plan. In reading the portions of the plan that dealt with the violations, I <br /> noticed that the newly added 240 gallon synblend tank is not addressed in the overfill section. It seems <br /> only the gasoline, diesel and used oil tanks are addressed in the overfill protection section of the SPCC <br /> plan. Ensure that all SPCC regulated tanks are addressed for overfill. I've included guidance from the EPA <br /> on the subject. <br /> Also, the return to compliance stated that EPA region 9 made the determination that the tanks were <br /> permanently manifolded. Would it be possible to be forwarded the decision by the EPA, if it was a <br /> written decision. Please note that is only a request. <br /> i <br />