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Ruvalcaba, Cesar From: Ruvalcaba,Cesar Sent: Friday,June 21,2019 8:22 AM To: 'Azevedo,Steve' Subject: RE: APSA/SPCC inspection report- 24717 E BRANDT RD - PR0515597 Attachments: Violation 603 guidance.pdf,Violation 711 guidance.pdf, Open Violations.pdf Mr.Azevedo, The return to compliance for the facility at 24717 E. Brandt Rd (Clements Plant)has been reviewed.There are some questions and comments on the SPCC plan that will need to be addressed before the violations can be closed.The entire plan was not reviewed in detail,the table of contents was used to locate the proper code section and how it was addressed in the plan. • Violation 630 : Failure to provide general secondary containment or alternative for oil4illed operational equipment. Response provided : Oil-filled operational equipment is only required to have general secondary containment according to CFR 112.7(c).As such,active spill countermeasures are in place at the site to meet the requirements for general secondary containment.The SPCC has been updated to reflect this. SPCC plan discussion:page 11 Table 2 lists general secondary as the containment option for the crusher oil AST's. Discussion of CFR 112.7(c)does not discuss secondary containment for the crusher oil AST's. (This is where is should be, this is the general containment section) Discussion of CFR 112.8(c)(2) Page 19 section 15.2 does not contain discussion of secondary containment for the crusher oil AST. (and it shouldn't,this is sized secondary containment section) Comments:Although the response is correct,the change in the SPCC plan was unable to be verified.There is a table that mentions containment forthe crusher is general but no description of what the containment is. See the attached guidance from the EPA,note this paragraph"the Plan preparer must include enough detail in the SPCC Plan to describe the efficacy of the measures used to comply with the general secondary containment requirements in§112.7(c)."There is also an exemption that can be used,as long as certain criteria is met,it is referenced in 112.7(k) • Violation 711:Failed to perform scheduled tank tests or inspections by appropriately qualified Personnel. Response provided:Concrete, Inc.has adopted the industry standard inspection schedule of the STI SP-001,has eliminated the environmental equivalence wording in the SPCC Plan, and has updated the SPCC with a summary of the tanks at the facility and their inspection frequencies. SPCC plan discussion:The SPCC plan appears to have been amend to include all tanks on the mobile refue le r to follow STI SP-001 guidelines. Comments:The latest edition of the SP001 standard, 6'^edition January 2018, defines Portable Containers as follows "A closed AST having a liquid capacity equal to or greater than 55 U.S.gallons and not intended for fixed installation.This definition does not include a mobile storage container on a vehicle,or one being towed,that is used to store and transport liquids for transfer into or from vehicles,mobile equipment,or another storage container.This definition also does not include storage containers used for onboard propulsion of a vehicle."This definition would exclude the tanks 1