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Ruvalcaba, Cesar <br /> From: DPaul <spccorp@hotmaii.com> <br /> Sent: Thursday, October 10, 2019 9:38 AM <br /> To: Ruvalcaba, Cesar;Gary delCarlo;Todd McWhorter <br /> Subject: Re: Haley's Flying Service submittal(s) - PR0515798 <br /> Cesar: <br /> Just completed a productive and positive telecon with Ms.Janice Witul of Region IX US EPA----she is sending <br /> me some additional reference material which she wishes incorporated into our DRAFT spcc plan. We are <br /> further scheduled for a telecon with her @ 1:15pm on Tuesday, 10/15 to reconcile the balance of the issues <br /> you have enumerated. Hope this meets your timeline requirement. <br /> Paul <br /> SPC Corp <br /> From: Ruvalcaba,Cesar<cruvalcaba@sjgov.org> <br /> Sent: Wednesday, October 9,2019 12:55 PM <br /> To: DPaul<spccorp@hotmail.com> <br /> Cc:Gary Del Carlo<hfstracyca@msn.com> <br /> Subject: RE: Haley's Flying Service submittal(s)-PR0515798 <br /> Paul, <br /> I have consulted with the US EPA Region 9 SPCC inspector regarding the hybrid plan for inspection of the tanks. Haley's <br /> Flying Service is under the jurisdiction of the EPA based on its proximity to water. Under state regulations,the plan <br /> certified by a Professional Engineer, can only be cited for not being implemented or for not following the regulations. <br /> The USA EPA has broader authority, even when the plan is certified by a Professional Engineer. <br /> The USA EPA Region 9 does not seem to think that the hybrid plan is adequate for the inspection of the tanks.You can <br /> contact Inspector Janice Witul from EPA Region 9 if needed. Her contact information is <br /> Witul. anlce@ epa.goV <br /> (415)972-3089 <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 /> Thankyou, <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 (209)464-0138 1 LJ cruvalcabaPsiaov.ore <br /> 1 <br />