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Ruvalcaba, Cesar From: Ruvalcaba,Cesar Sent: Wednesday,July 24,2019 2:50 PM To: 'Aron Kludt' Cc: Stephen Kludt Subject: RE: return to compliance-PR0527768 Attachments: Industry Standard Guidance.pdf, Mobile_Portable Containers.pdf, Open Violations.pdf Hi Aron, The return to compliance for APSA/SPCC has been reviewed. One violation has been closed based on the provided statements.A list of updated open violations is provided.The"tank testing info"file was corrupted and couldn't be opened. Most of the violations may require an amendment to the SPCC plan. Most of the amendments may fall under the technical amendment category and will require certification by a registered Professional Engineer(PE). Violation#603-Failed to adequately describe the physical layout of the facility In the Plan. - Referring to the attachments of page 9,warehouse and tank& piping which address the UST tanks and piping in question along with layout of the facility. I did want to ask if we have to write "exempt' on the location of the UST tanks since they are clearly marked"UST" and anyone doing an inspection would know they don't fall under AST? Unfortunately the regulations are very specific in this matter,resubmit a facility diagram that marks USTs as"exempt". One of the maps also seems to be missing the kerosene and racing fuel UST. The location of the sued oil tank may be incorrect in one of the diagrams. Below is what the regulations states: Describe in your Plan the physical layout of the facility and include a facility diagram, which must mark the location and contents of each fixed oil storage container and the storage area where mobile or portable containers are located. The facility diagram must identify the location of and mark as "exempt"underground tanks that are otherwise exempted from the requirements of this part under§112.1(d)(4).The facility diagram must also include all transfer stations and connecting pipes, including intra-facility gathering lines that are otherwise exempted from the requirements of this part Violation#626- Loading/unloading rack containment system not adequate to contain spill. - Referring to page 9 again it states Zone 1 which contains the area discussed has a capacity of 56,000 gallons which is well above the largest compartment getting loaded on a truck. There is a closed control valve within Zone 1 that would also stop the flow of product before reaching the oil/Water separator. There are interlock brake systems on all of our trucks that activates once piping is connected keeping them from moving until everything is disconnected. The SPCC plan needs to address the required sections of the regulations.The discussion on page 29 of the provided SPCC plan,titled 'Tank Truck Loading/Unloading Area Containment 40 CFR 112.7(h)"does not satisfy the requirements of that section.This section seems to imply that the oil water separator is the secondary containment for loading rack. It does not address the capacity of the oil water separator and the engineer does not certify that the maximum capacity of any single compartment of a tank car or tank truck loaded or unloaded at the facility would be able to be contained by the oil water separator. There were also three man holes in the area of the loading racks, these are not addressed in the SPCC plan. Would material not collect in those sumps?What is there? The addition of the missing components will need to be certified by a professional engineer. Code of Federal Regulations 112.7 (h) Facility tank car and tank truck loading/unloading rack (excluding offshore facilities). (1)Where loading/unloading rack drainage does not flow into a catchment basin or treatment facility designed to handle discharges, use a quick drainage system for tank car or tank truck loading/unloading racks. You must design any containment system to hold at least the maximum capacity of any single compartment of a tank car or tank truck loaded or unloaded at the facility. (2) Provide an interlocked warning light or physical barrier system,warning signs,wheel chocks or vehicle brake interlock system in the area adjacent to a loading/unloading rack,to prevent vehicles from departing before complete disconnection of flexible or fixed oil transfer lines. 1