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you must also inspect the container's <br /> supports and foundations.In addition, <br /> you must frequently inspect the outside <br /> of the container for signs of deterioration, <br /> discharges,or accumulation <br /> of oil inside diked areas.Records of inspections <br /> and tests kept under usual <br /> and customary business practices satisfy <br /> the recordkeeping requirements of <br /> this paragraph. <br /> Please let me know if there are additional questions or if further clarificaitio is needed. <br /> FREE classes presented by NES Inc. are available to all San Joaquin County Hazardous Waste, Underground Storage Tank, <br /> and Aboveground Petroleum Storage Facility Business Owners and Operators. List and schedule of classes can be found <br /> here. <br /> Thank you, <br /> Cesar Ruvalcaba <br /> San Joaquin County Environmental Health Department <br /> Environmental Health Specialist <br /> 1868 East Hazelton Ave <br /> Stockton, CA 95205 <br /> 2 (209)953-6213 1 u (209) 464-01381 & cruvalcaba@sicehd.com W <br /> SANdOAQUIN <br /> C C)u NTv— <br /> �rr <br /> From: Chong Lee<chong.lee@fedex.com> <br /> Sent:Thursday,January 3, 2019 4:35 PM <br /> To: Cesar Ruvalcaba [EH] <cruvalcaba@sicehd.com> <br /> Subject: FedEx Freight <br /> Hi Cesar, <br /> Good talking to you, and I appreciate you taking the time to discuss your inspection results with me. <br /> With regards to item 710, inspections of ASTs are discussed in page 11—12 (attached) of our SPCC plan. As indicated in <br /> this section, rational for why "environmental equivalence" is applicable to this site is discussed, and includes reference <br /> to: SPCC Guidance for Regional Inspector,Version 1.0, November 28, 2005, Office of Emergency Management, EPA 550- <br /> B-05-001. Given that our tanks are all "shop built" containers that are smaller than 30,000 gallon, and elevated,the <br /> Professional Engineer who certified this plan has determined that visual inspections provides equal environmental <br /> protection. Thus, reference to an industry testing/inspection standards is not needed for our plan. <br /> I would appreciate it if you could review the attached, particularly the highlighted sections,then reconsider whether <br /> violation 710 is still applicable. <br /> Thanks, <br /> Chong <br /> 408-654-3112 <br /> 3 <br />