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Lydia From: Burgin, Andy C (Fresno) USA<andy.burgin@lehighhanson.com> Sent: Monday, May 20, 2019 3:45 PM To: Baker, Lydia <Ibaker@sigov.org> Cc: Marshall,Terry A (Fresno) USA<Terry.Marshall@lehighhanson.com> Subject: Re: Full Inspection Reports Hello Lydia, Thank you for the inspection photos and reports. We are working on a detailed response, including correction actions statements, as necessary. With that said we do have a few statements/questions. 1) Your statement in the "Overall Inspection Comments:" states "An inspection checklist was provided to the facility operator on the day of inspection. The EHD has written the complete report which replaces the initial checklist." Can you clarify this as no documentation was provided on the day of the inspection. I did digitally sign a document that I believed was the full inspection report. You said that you would email that copy on 5/20/18. 1 have still not received the signed copy. I would prefer the comments reflected the situation more clearly. 2) We discussed some of these additional violations while you were on site and I believed that we had reached an agreement as to why these are not violations.There appears to have been some changes after the site visit and therefore we are not in a position to sign without additional information. To address these potential additional violations added after the inspection, I have listed each one out with a response and a suggested corrective action that we can discuss further. As these items have not been fully addressed during the inspection the 30 day compliance period should start once we have reached a resolution on these additional items. We respectfully request you adjust your compliance system calendar to reflect this. ASPA 712 The SPCC does include a deviation statement in Section 1.2. As stated in our meeting, SP001 is confusing and is not site specific, as it is meant to cover all types of tanks/vessels and any type of material that can be stored in a steel tank, this confusion causes misjudgment or inaction on site tank inspectors.The point of the SPCC is to write a site specific plan to address site specific items. In most cases the standard form in SP001 test method is overreaching and not applicable (this is why all items on the SP001 form includes an N/A choice), by removing these items and shorting the form you provide better compliance and more thought out inspection procedures. SP001 is not an industry standard it is a test method.There is no regulation that requires SP001 to be used.The forms used do meet industry standard which is to evaluate the tank/vessel for signs of leaks or potential corrosion. SP001 was developed in 2011,the standard for inspecting tanks has been around for 20-30 years before this test method was available. Suggested corrective action: County to provide code that list SP001 or equivalent as a specific requirement in spill plan inspections. Either federal,state, or local code shall suffice. If no code is available, it is recommended that the County not require items that are not enforceable by code, and therefore not preview to code enforcement. ASPA 715 Section 112.38(c)(8)(v) states "You must regularly test liquid level sensing devices to ensure proper operation." SP001 only checks "proper operation" on an annual basis, by asking questions all which can be answered using "Not Applicable" as a valid answer. The monthly SP001 only checks for damage, which is covered by a tank damage question in the alternative logs. There is no reason to clarify difference between damage to the tank or damage to an attachment to the tank as the SP001 log does. During the inspection the gauge was observed and appeared to not be damaged and be in working condition as our logs indicate. 2