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Cesar Ruvalcaba [EH] <br /> From: Witul, Janice <Witul.Janice@epa.gov> <br /> Sent: Friday, June 15, 2018 4:47 PM <br /> To: Cesar Ruvalcaba [EH] <br /> Subject: RE: SPCC impracticability determination review request - San Joaquin County <br /> Environmental Health <br /> Cesar— <br /> Sorry I haven't been back in touch much, and I'm heading out of the office now until June 28. 1 spoke with our Oil <br /> Program at HQ about Bullfrog Landing and got the following suggestion.There has been a modification to the tanks <br /> since they were installed—sometime after 2007, given the imagery date of the street view in Google Earth—reducing <br /> the six vents to three (see the pictures I took, below, of the three vents and then a closeup of the venting <br /> arrangement). This may require that the tanks be brought up to the fire code in place at the time of the modification. <br /> From the letter dated February 17, 2015,Vic Solari was going by information he received, not based on an inspection. If <br /> the tanks have to be up to a code of sometime in the last 10 years,they have more than SPCC issues to address. <br /> I did get the Contingency Plan this week, but haven't had a chance to review it. At the very least,there is little <br /> inspection of the secondary containment (boom) being performed, and the fact that at ANY time/tide the boom doesn't <br /> reach the shore means there really isn't secondary containment. <br /> 01z <br /> BAIY <br /> ..,r •�.Is�«, �M =r'iY'4.�t.r ! ' .,� _ Sri <br /> - <br />