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Ruvalcaba, Cesar <br /> From: Michael Collins <mcollins@foodexp.com> <br /> Sent: Friday,June 28,2019 10:44 AM <br /> To: Ruvalcaba,Cesar <br /> Cc: 'Garrison Reeves; Justin Keeney <br /> Subject: RE: SPCC Plan updates <br /> Thanks Cesar! I'll get with Gary and get page 18 added as well as see what we need to do about the door issue for the <br /> secondary containment. I'll also have Gary help with violation 11710 as well. I appreciate your help and will talk to you <br /> soon in regards to how we are going to get these corrected so that we can be back to compliance.Thanks! <br /> Gary Please give me a call as soon as you have a free moment so that we can discuss next steps.Thanks. <br /> FOOD EXPRESS,INC. <br /> Michael Collins <br /> Terminal Manager <br /> P 209-858-2142 <br /> F 209-858-2418 <br /> From: Ruvalcaba, Cesar [mailto:cruvalcaba@sjgov.org] <br /> Sent: Friday,June 28, 2019 9:54 AM <br /> To: Michael Collins<mcollins@foodexp.com> <br /> Cc: 'Garrison Reeves'<greeves455@aoLmm>;Justin Keeney<jtkeeney@foodexp.mm> <br /> Subject: RE: SPCC Plan updates <br /> Michael, <br /> The latest return to compliance has been reviewed. The violations remain open. Below is a brief explanation <br /> as to why. Feel free to contact me with questions or concerns. <br /> Violation 11612 <br /> Based on the provided portions of the SPCC plan, the new oil and used oil tanks are located inside the shop <br /> and concrete flooring and the shop walls and floor provide containment for any spill or release from the <br /> tanks. The section of the SPCC plan titled Capacity of the Secondary Containment Area 40 CFR 112.8(c)(2) <br /> states that "the secondary containment area must have the capacity to contain the entire volume of the <br /> largest tank.This is addressed within this Plan at 40 CFR 112.7(a)(3)(iii), page 18).The 112 Diesel tank <br /> containment sufficient for holding a fuel release and the oil tanks in the shop will be contained by the shop <br /> walls and floor." <br /> Page 18 of the SPCC plan was not provided.Also,based on pictures on file for the facility from previous inspections, <br /> there is a door in the shop. If the walls are the secondary containment,the door would need to be addressed since this <br /> would be a breach in the secondary containment. <br /> Violation A 710 <br /> The SPCC plan states the following"The systems are inspected monthly for leaks, stains and spills of 112 <br /> Diesel as required by the SPCC plan and CFR 40 112.7. Inspections are performed by trained staff and done <br /> 1 <br />