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J . R . Simplot Company <br /> 5 (In p ' O t . P. O . Box 28955 <br /> Fresno , California <br /> 93729 - 8955 <br /> GROWER SOLUTIONS ( 559 ) 439 - 3900 Business <br /> ( 559 ) 439 - 5728 Fax <br /> 12 April 2016 <br /> �d <br /> San Joaquin County /ROAM �p1�` <br /> Environmental Health <br /> East HazeltonA Department <br /> r <br /> pFR�siTi�F�� y�C <br /> Stockton , CA 95205 -6232 <br /> Atten : Elena Manzo <br /> SUBJECT : SIMPL OT STOCKTON INSPECTION REPORT CERv ID 10138539 <br /> This letter , which is an update of the letter sent on 18 March 2016 , addresses violations <br /> listed in your "Aboveground Petroleum Storage Act Inspection Report" for the inspection <br /> conducted on 26 February 2016 at our Stockton facility , located at 4863 Carpenter <br /> Road . Updated information for each of the listed violations is provided below : <br /> • 101 — " Failed to prepare and implement a written SPCC Plan in accordance with <br /> CFR Part 112 " : As stated in the previous letter, Simplot has hired HDR to rewrite <br /> the existing facility SPCC plan and to assist in its implementation . The revised <br /> SPCC plan will be certified by a professional engineer . Simplot expects to be <br /> completed with this project by 31 May 2016 . <br /> • 601 — " Plan that does not follow the sequence specified in this section lacks a <br /> cross - referencinq section " : The revised SPCC plan will include a cross- reference <br /> matrix . <br /> • 603 — " Plan failed to discuss equivalent environmental protection if applicable <br /> The revised SPCC plan will specify updated integrity testing requirements that <br /> are in full conformance with 40 CFR 112 . If environmentally equivalent <br /> measures are used , they will be described in the plan as required by 40 CFR <br /> 112 . 7 ( a ) (2 ) , <br /> • 604 — " No facility diagram or didn 't show location and contents of containers <br /> transfer stations , and pipes " : The revised SPCC plan will contain an updated <br /> facility diagram that meets the requirements of 40 CFR 112 . 7 ( a) ( 3) . <br /> • 713 — " Failed to perform scheduled tank tests and inspections by appropriately <br /> qualified personnel " : The revised SPCC plan will include updated integrity <br /> testing procedures based on applicable industry standards . Steel tanks will be <br /> inspected and tested according to the Steel Tank Institute Standard for the <br /> Inspection of Aboveground Storage Tanks , STI SP001 , and plastic tanks will be <br /> inspected and tested according to the New York Department of Environmental <br /> Conservation Inspection of Plastic Tanks , DER- 16 . Facility personnel will be <br /> trained on how to properly conduct tests and inspections . <br /> ",,, y y i J. .►. i 1 i i .1. .1. y .1, i i �. d. .t. a .r i i i .r i 1 1 d. .6 1 d. i .1. d. t i 1 1 .b %& 1 .►. .& d. d. %& 1 .1. .L N& i + i i r. i J <br /> ti i .ti i i.lji i i:.byJ.yl:.ti i i`i i+i+J:i J.+i iyb+.1:.L.b.byi i.biiyl:i+.b+.byJ.+J:i.l <br /> v <br />