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Manzo, Elena K.[EHD] From: Witul,Janice <Witul.Janice@epa.gov> Sent: Thursday,April 8,2021 3:51 PM To: cloud 1956@me.com Cc: Manzo,Elena K.[EHD] Subject: EPA SPCC requirements Attachments: Wimpy's Marina Photo Log.pdf,Wimpy's Marina Report.pdf Importance: High CAUTION:This email is originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Gerry— Not sure you had received this information pertaining to the October inspection and a vapor test on the tank. At the October 28 inspection,there was no SPCC Plan available for the fuel tank at the Marina, and no indication that routine inspections in accordance with industry/tank manufacturer's specifications are being conducted. I'm also attaching the Oil Program report and photo log that were sent electronically in November. As I mentioned when we spoke yesterday, and noted below,the local agency may be able to advise you on Plan preparation and implementation. Just to note, EPA has a penalty policy that allows for lower penalty amounts when facilities come into compliance in a timely manner. v/r, Janice Witul US EPA R9 Oil Program 75 Hawthorne St., ECAD-3-2 San Francisco CA 94105 415 972 3089 From:Witul,Janice Sent:Thursday, November 12, 2020 1:42 PM To:Wimpy's Marina <wimpysmarina@gmail.com> Cc: Elena K. Manzo [EH] <emanzo@sjcehd.com> Subject: EPA SPCC requirements. Importance: High Jim &Gerry— The document you provided was a pressure test for compliance with the local Air Pollution Control District regulations. The federal Oil Pollution Prevention regulations require inspections of the tank, valves and vents, as well as interstitial space monitoring, to be performed monthly by a knowledgeable person, along with a more comprehensive yearly inspection—and documenting the results. The knowledgeable person could be a site employee who is familiar with facility operations,fuel characteristics,the tank/tank system and inspection requirements, or another individual designated by the tank owner. Older and/or larger tanks require formal inspections which must be conducted by certified inspectors. The F921 designation on the Marina's tank indicates it was manufactured in accordance with the Steel Tank Institute (STI) requirements, with a double-wall integral secondary containment to meet EPA SPCC requirements. Accordingly, inspections for the tank would be performed in accordance with STI's Standard for the Inspection of Aboveground I