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Cesar Ruvalcaba [EH] <br /> From: Witul, Janice <Witul.Janice@epa.gov> <br /> Sent: Tuesday, March 19, 2019 9:21 PM <br /> To: Garrison Reeves <br /> Cc: Cesar Ruvalcaba [EH] <br /> Subject: RE: Union Point SPCC Plan <br /> Importance: High <br /> The Plan is much improved, but there are still issues to be addressed, as follows: <br /> Page 3 -The definition for oil shown here should be removed or modified so that it is consistent with the definitions at <br /> 40 CFR 112.2 for Non-petroleum oil and Oil. <br /> Page 7 - #5 in the Certification should end with "the last 5 years" instead of'the pat 5 years' as it currently shows. <br /> Page 9—Plan states "Metal thickness testing required on the Gasoline tank due to its construction consisting of a carbon <br /> steel wall." Why is this required? Usually a steel AST of this size is not required to have metal thickness testing unless it <br /> does not have continuous release detection capability or secondary containment, both of which this tank has. <br /> Page 12 #5 still reads "hand break";while this is not critical, if it were corrected to hand brake or emergency brake, <br /> there would be no misunderstanding this direction. <br /> Page 13—(b) under Discharge Prevention Measures—there are still no details about buried piping, but a statement was <br /> added about buried tanks. <br /> Page 14 bottom—no details have been provided regarding the secure area and vehicle escort. <br /> Page 23—What is the Industry Standard referenced here that requires "Integrity testing for each fuel oil product <br /> tank"? <br /> Page 27-Section 40 CFR 112.7(h) is only applicable to transfer racks. General containment at the facility would be <br /> appropriately addressed under 40 CFR 112.7(c), and 112.8(b)(3),(4) -for a facility without a transfer rack. <br /> Page 29 Integrity Testing-The regulatory requirement is to inspect or test based on industry standards, and a tank <br /> of this size and configuration does not require testing per the Steel Tank Institute SP001. What is the STI standard <br /> referenced here? <br /> Page 31—facility diagram is required to show transfer areas and piping. <br /> Page 32 - Freeboard for precipitation is an actual value, not just wording that can be inserted. As explained in the July <br /> 17, 2002 Federal Register(67 FR 47117), the preferred standard is the amount from a 25-year, 24-hour storm <br /> event. Local precipitation frequency estimates are easily accessible via the internet. <br /> Please do not hesitate to contact me for any clarification required. <br /> Janice Witul - US EPA R9 <br /> 1 <br />