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For the 55 gallon drums that would be regulated under Aboveground Petroleum Storage Act(APSA),the <br /> drums are considered bulk storage containers and would need a discussion included for all requirements <br /> for tanks. <br /> Using the provided cross reference, I was unable to identify what the secondary containment would be <br /> for APSA regulated drums and table 2-2 does not seem to address the APSA regulated drums. There <br /> may be other areas where a discussion would be needed but was not provided in the plan. Any APSA <br /> regulated bulk storage container must meet the requirements of bulk storage containers under 40 CFR. <br /> FREE classes presented by NES Inc. are available to all San Joaquin County Hazardous <br /> Waste, Underground Storage Tank, and Aboveground Petroleum Storage Facility Business Owners and <br /> Operators. List and schedule of classes can be found 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) 953-62131 A (209) 464-0138 cruvalcaba@slcehd.com 2 <br /> r <br /> .}AI'IS OAQUIN <br /> -CCUNTY- <br /> t��T �arePtnCss IOrYS �S@rr. <br /> From:William Reeck<wreeck@ionescovey.com> <br /> Sent:Tuesday,January 8, 2019 10:12 AM <br /> To: Cesar Ruvalcaba [EH] <cruvaIca ba@sicehd.com> <br /> Cc:Joey Cupp<Joey.Cupp@pilottravelcenters.com>; Bret Covey<bret@ionescovey.com>; Gregory <br /> Smith <gsmith@ionescovey.com>; Alan Fass<alanfass@dynamis-inc.com>; Miluska Cioffi <br /> <Miluska.Cioffi@pilottravelcenters.com> <br /> Subject: Response - Pilot 617 Lodi Notice of Violation <br /> Inspector Ruvalcaba, <br /> This email is in response to the Notice of Violation issued to Pilot 617— Lodi, located at 15237 N. <br /> Thornton Rd, Lodi CA 95242. In response to the Violation and instructions from the inspector's office, <br /> the following action has been taken: <br /> Violation 301—Per instructions from the inspector's office, the site's Spill Prevention, Control and <br /> Countermeasure (SPCC) plan has been updated to account for(6) 55-gallon hazardous waste drums. <br /> Please find attached revised SPCC plan. A copy of this plan will also be available in store for access. <br /> Please find attached signed return to compliance. If you have any questions, please feel free to reach <br /> out to me. <br /> Thank you, <br /> 6 <br />