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Ruvalcaba, Cesar <br /> From: Paul Hamilton <phamiRon@caltreight.com> <br /> Sent: Friday, November 8, 2019 11:08 AM <br /> To: Ruvalcaba,Cesar <br /> Cc: Bobir Hassanov; safety <br /> Subject: RE: APSA/SPCC inspection report- 19501 N HWY 99 - PR0528459 <br /> Attachments: 20191107_085744.jpg; 20191107_085752.jpg <br /> Hello Cesar, <br /> Do I need to upload these images into the online system as well,or can you process them for us? I will complete the <br /> SPCC and upload it asap. <br /> Thank you, <br /> Paul Hamilton <br /> Director of Transportation <br /> CALIFORNIA FREIGHT <br /> 209.599.5024 direct/fax <br /> phamilton@calfreight.com <br /> From: Ruvalcaba,Cesar<cruvalcaba@sjgov.org> <br /> Sent:Thursday,October 31,2019 2:14 PM <br /> To: Paul Hamilton<phamilton@calfreight.com> <br /> Cc: Bobir Hassanov<bhassanov@calfreight.com>;safety<safety@calfreight.com> <br /> Subject: RE:APSA/SPCC inspection report-19501 N H WY 99-PR0529459 <br /> Mr. Hamilton, <br /> I am unable to close any of the violations. <br /> Here is a brief explanation as to why: <br /> Violation#102 Failed to Prepare a written SPCC Plan in accordance with CFR Part 112. <br /> Although the facility will be at 10,000 gallons of total storage capacity, once the 500 gallon tank is properly closed,the <br /> facility still needs an SPCC plan.Any facility with over 1,320 gallons of total storage capacity of petroleum products is <br /> required to have an SPCC plan. Because the facility has a single tank that is larger than 5,000 gallons it qualifies for a <br /> Tier 11 SPCC plan.Tier 11 plans are self-certified,there is a template available,which I have attached. If there is a deviation <br /> from the requirements of the regulations,the deviation does need to be certified by a professional engineer. I have <br /> included some guidance from the EPA on this matter,it can be found here. Submit the completed Tier 11 template for <br /> review. <br /> San Diego County has some trainings on developing Tier I plans,these plans are a bit different from Tier 11 plans,but it <br /> may give you some guidance <br /> haps://www.sandiegocounty.gov/content/sdc/deh/hazmat/hmd apsa/hmd tier 1 template course.html <br /> I <br />