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Baker, Lydia From: Baker, Lydia Sent: Thursday, May 23, 2019 11:41 AM To: 'Burgin, Andy C (Fresno) USA' Cc: Marshall, Terry A (Fresno) USA Subject: APSA Inspection Attachments: Amended APSA Calaveras Materials Tracy.pdf Hello Andy, Please see the attached amended inspection report. The boilerplate text was updated to remove the "checklist provided the day of inspection" section and I corrected the spelling of your last name. After discussion with my supervisor and the other APSA inspector in our department the two violations (#712 &#715)will be not be removed from the inspection report. The 30 days for the Return to Compliance will begin today. I do realize that these corrections may take longer than 30 days. If you anticipate that it will take longer please submit all the completed corrections along with what you are working on and an estimated completion date. Here is my response regarding your questions and request to remove the two violations: For#712: You are right in stating that the Federal, state or local codes, regulations or ordinances do not require the Steel Tank Institute's (STI) SP-001 standard.The federal regulations do require an industry standard be used to make the determination of who, when and how the tanks will be inspected, based on the tanks size, configuration and design. 40 CFR 112.8(c)(6)-Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs.You must determine,in accordance with industry standards,the appropriate qualifications for personnel performing tests and inspections,the frequency and type of testing and inspections,which take into account container size,configuration,and design(such as containers that are: shop-built,field-erected,skid-mounted,elevated,equipped with a liner,double-walled,or partially buried).Examples of these integrity tests include,but are not limited to:visual inspection,hydrostatic testing,radiographic testing,ultrasonic testing,acoustic emissions testing,or other systems of non-destructive testing.You must keep comparison records and you must also inspect the container's supports and foundations.In addition,you must frequently inspect the outside of the container for signs of deterioration,discharges,or accumulation of oil inside diked areas. Records of inspections and tests kept under usual and customary business practices satisfy the recordkeeping requirements of this paragraph. Your facility's SPCC plan cites the SP001 standard for the inspection testing and scheduling. The county is not requiring you to use that standard. The county is requiring you to follow: HSC 25270.4.5.(a)Except as provided in subdivision(b),the owner or operator of a storage tank at a tank facility subject to this chapter shall prepare a spill prevention control and countermeasure plan applying good engineering practices to prevent petroleum releases using the same format required by Part 112(commencing with Section 112.1)of Subchapter D of Chapter I of Title 40 of the Code of Federal Regulations,including owners and operators of tank facilities not subject to the general provisions in Section 112.1 of those regulations.An owner or operator specified in this subdivision shall conduct periodic inspections of the storage tank to ensure compliance with Part 112(commencing with Section 112.1)of Subchapter D of Chapter I of Title 40 of the Code of Federal Regulations. In implementing the spill prevention control and countermeasure plan,an owner or operator specified in this subdivision shall fully comply with the latest version of the regulations contained in Part 112(commencing with Section 112.1)of Subchapter D of Chapter I of Title 40 of the Code of Federal Regulations. If your site does not want to use that standard then the SPCC plan needs to be amended to reflect the current procedures, policies and practices at your facility. You stated that SP001 is not a standard but a test method. Per the EPA SPCC Guidance Document for Regional Inspectors, page 281 (https://www.epa.gov/sites/production/files/2014- 04/documents/spcc guidance fulltext 2014.pdf): The necessary qualifications for personnel conducting the inspections are outlined in tank inspection standards such as API 653 and STI SP001. The same guidance document also states on page 300: