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Garcia-Mejia, Gabriela [EHD] From: Jordan Johnson <jordan Johnson@vpps.net> Sent: Thursday, March 30, 2023 12:08 PM To: Garcia-Mejia, Gabriela [EHD] Cc: Ed Ward; Grant Crum;Will Harp; Mike Eliason Subject: RE: APSA and HW inspection reports for 166 Frank West Hello Gabriela, have received your requests regarding the return to compliance for our Stockton facility. For your reference I have copied the requests followed by the response below. Please feel free to contact me with any further questions. HW 502-The HW tank inspection form you referenced only addresses weekly inspections not daily. Please provide me with documentation that shows daily hazardous waste tank inspections are being done. Response- Our facility is a small quantity hazardous waste generator(SQG).According to hazardous waste regulations found in 40 CFR 262.16(3)(iv), a SQG can inspect the tank weekly if the tank has full secondary containment.We have indicated on the training form that our waste oil container has full secondary containment- it is a double walled tank located in a wash bay connected to an oil water separator. Our understanding is that weekly inspections allowed under 40 CFR 262.16(3)(iv) meet the inspection requirements identified in 40 CFR 262.16(3)(iii) and daily inspections are not required. APSA 301-The SPCC plan included still lists manual sight tank gauging for tanks 1-6 instead of the 'red trac' remote liquid level sensor that was observed during the inspection. Please provide me the page of the SPCC plan where the change has been made. Response- Upon further review of the Redtrac equipment, it was determined they are primarily used for inventory control and not applicable for overfill prevention.The sensors are unable to provide constant real-time updates,which is why they have not been added as SPCC Plan overfill prevention.The SPCC sections covering tank overfill prevention (pg 3, 14) are current. In essence, the tanks are either equipped with a liquid level gauge visible by the delivery driver or a second attendant is present monitoring and relaying the liquid level info to the tank truck operator during tank fill. Respectfully, Jordan Johnson Safety and Regulatory Specialist Valley Pacific Petroleum Services, Inc. -----Original Message----- From: Garcia-Mejia, Gabriela [EHD] <ggarcia-mejia@sjgov.org> Sent: Wednesday, March 29, 2023 4:12 PM To:Jordan Johnson<jordan.johnson@vpps.net> Cc: Ed Ward <ed.ward@vpps.net>; Grant Crum <grant.crum@vpps.net>; Will Harp<will.harp@vpps.net>; Mike Eliason <mike.eliason@vpps.net> Subject: RE:APSA and HW inspection reports for 166 Frank West 1