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Cesar Ruvalcaba [EH] <br /> From: Witul, Janice <Witul.Janice@epa.gov> <br /> Sent: Tuesday, May 15, 2018 3:14 PM <br /> To: Cesar Ruvalcaba [EH] <br /> Cc: Reich, Peter <br /> Subject: RE: SPCC impracticability determination review request - San Joaquin County <br /> Environmental Health <br /> Cesar— <br /> It looks like the issue has been covered pretty thoroughly, although there is an error in addressing it as 40 CFR <br /> 112.7(a)(2) (which is environmental equivalence) rather than 112.7(d)for impracticability, but <br /> I'd prefer to see the site/tanks for myself, as well as the testing documentation. We're looking more closely at marinas <br /> now, so I'd try to see a few others in that area too. <br /> Not sure if you'd want to go also; if so, we can coordinate our availability. <br /> Janice Witul - US EPA R9 <br /> Oil Program <br /> 75 Hawthorne St., ENF-3-2 <br /> San Francisco CA 94105 <br /> 415 972 3089 <br /> fax 415 947 3519 <br /> Report oil or <br /> chemFcal spills at <br /> 800-424-8802 <br /> 144111111111111W <br /> From: Cesar Ruvalcaba [EH] [ma ilto:cruvaIca ba@sjcehd.com] <br /> Sent: Monday, May 14, 2018 2:39 PM <br /> To: Reich, Peter<Reich.Pete r@epa.gov>; Witul,Janice<Witul.Janice@epa.gov>;ADAMS, CONNOR <br /> <Adams.Connor@epa.gov> <br /> Subject:SPCC impracticability determination review request-San Joaquin County Environmental Health <br /> Hi Everyone, <br /> I hope everyone is doing well. I am writing you to get your opinion on a facility in San Joaquin County that has made an <br /> impracticability determination. The facility is a marina, with six single walled gasoline tanks (4 x 1000 gallons and 2 x <br /> 500 gallons) is located at 17251 Bacon Island Rd in Stockton, CA. I have not been out to the site but past inspection notes <br /> describe the facility as the tanks being placed on a non-liquid tight wood deck on the water side of the levee. Our facility <br /> file dates back to 2008 but per County Fire personnel facility dates back to 1960's.The facility has submitted, per past <br /> inspection notes, a PE certified hybrid SPCC plan. Attached you will find the certified portion of the plan, what is believed <br /> to be "appendix K", an older facility map and an overview of the location from google maps. Our department would like <br /> to request your opinion on the impracticability determination made. If you require any other documentation or <br /> information, let me know and I will try and get it for you. <br />