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J.R.Simplot Company <br /> Simplot. P.O Box 27,Boise,Idaho <br /> 837070027 <br /> CEIVD <br /> 8 August 2018 <br /> AUG 10 2018San Joaquin County �NVIRONtV1ENTAl HEALTH <br /> Environmental Health Department <br /> 1868 East Hazelton Avenue PERMIT/SERVICER <br /> Stockton, CA 95205-6232 <br /> SUBJECT: SIMPLOT STOCKTON NOTICE TO ABATE &AMENDED SQG <br /> HAZARDOUS WASTE INSPECTION REPORT OF 5 APRIL 2016 <br /> This letter is in response to your Notice to Abate ID# PR0539280, your amended <br /> Small Quantity Hazardous Waste Generator Inspection report dated April 5, <br /> 2016, and your e-mail dated January 8, 2018, from Aaron Hang to John Pallen, <br /> for our Stockton facility located at 4863 Carpenter Road. <br /> We continue to maintain that the eight sump structures are excluded from the <br /> definition of "underground storage tanks". These structures are used to collect <br /> the flow of surface water run-off resulting from precipitation or industrial <br /> wastewater. By definition, the term "underground storage tank" does not include <br /> storm drains and storm water or wastewater collection systems. (California <br /> Health & Safety Code Section 25281(y)(1)(C) and 23 California Code of <br /> Regulations 2621(a)(10)). <br /> 23 CCR 2611 further defines "storm water or wastewater collection system" to <br /> mean piping, pumps, conduits and any other equipment necessary to collect and <br /> transport the flow of surface water run-off resulting from precipitation, or <br /> domestic, commercial, or industrial wastewater to and from retention areas or <br /> any areas where treatment is designated to occur. (emphasis added). Thus, a <br /> collection system is deemed to include equipment to collect storm water or <br /> wastewater. <br /> 23 CCR 2621(a)(7) also specifically excludes sumps, pits, ponds and lagoons <br /> from the definition of underground storage tank. There seems to be some <br /> confusion on when a below-grade depression is a storage tank rather than a <br /> sump. 23 CCR 2611 defines a "sump" as a "depression in the ground which <br /> lacks independent structural integrity and depends on surrounding earthen <br /> material for structural support of fluid containment." <br /> The eight stainless steel sump structures at our Stockton facility are sunk below <br /> ground and lined on all sides with concrete. The stainless steel protects the <br /> concrete from degradation caused by fertilizer materials. Together the stainless <br /> steel and concrete assure containment and are easier to inspect and <br /> maintain. The double containment allows us to visually inspect the annular <br /> space between the two pans so that we can confirm the exterior sump is <br /> i .� i i i a i a. � a. .. i i .r .�. i i i <br /> iiiia:iiiii-A- _A:. .: .: :.�.:r:iiiiiiitiiiitii.�:.�:ii� <br />