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on the mobile refueler from the standard.There maybe other standards that apply to the mobile refueler. Seethe <br /> attached guidance from the EPA. <br /> • Violation 718:Failed to locate properly or provide sufficient secondary containment for mob!le/portablecontainers. <br /> Response provided:The drums are stored in two locations at the facility, have been accurately listed on the inventory and placed in <br /> secondary containment.The SPCC Plan and site map have been updated accordingly to address both the tanks and the drums.: <br /> SPCC plan discussion:The SPCC plan seems to address secondary containment for the drums in the "Shop Lube Area' <br /> but not for the"Shop Fueling Area" Per section 15.2 of the SPCC plan which discusses 112.8(c)(2) pg 19"Secondary <br /> containment for the lubricant and waste oil storage shed along the east wall of the shop is provided by a six <br /> inch concrete curb and individual open containers under the waste oil.There is no secondary containment <br /> beyond the concrete curb under either 500 gallon lubricant single wall AST."This seems to be the Shop Lube <br /> Area. Section 15.9 of the SPCC plan which discusses 112.8(c)(11)states"Storage of product in mobile or portable <br /> containers is conducted at the CONCRETE INC., DBA KNIFE RIVER. An onsite product delivery truck is <br /> parked adjacent to the fueling area. Product may remain in the DOT approved vehicle mounted tank.The truck <br /> parking area drainage is retained onsite.A trailer mounted portable fuel AST is stored on site and may be used <br /> for temporary pumping tasks at various locations." (Per EPA guidance 55 gallon drums are mobile/portable <br /> containers). <br /> Comments:The secondary containment for the drums in the maintenance shop(Shop Fueling Area?)does not seem to <br /> be addressed. <br /> If the plan does have the discussions or you feel that the response fulfills the requirements of the regulations,let me <br /> know an I can take a closer look at the plan. Let me know which sections of the plan have the proper discussions. <br /> The complete EPA guidance document can be found here. I have also included an update list of open violations. <br /> Feel free to contact me with any questions. <br /> FREE classes presented by N ES l nc. are available to all San Joaquin County Hazardous Waste, U nderground Storage Tank, <br /> and Aboveground Petroleum Storage Facility Business Owners and Operators. List and schedule of classes can be found <br /> here. <br /> Thank you, <br /> Cesar Ruvalcaba <br /> San Joaquin County Environmental Health Department <br /> Environmental Health Specialist <br /> 1868 East Hazelton Ave <br /> Stockton,CA 95205 <br /> $ (209)953-6213 1 A (209)464-01381 ® cruvalcaba(a@siaov.ora <br /> 2 <br />