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July 3, 2019 <br /> Ms. Lydia Baker, REHS <br /> San Joaquin County Environmental Health Department <br /> 1868 E. Hazelton Avenue <br /> Stockton, California 95205 <br /> Re: RESPONSE TO ABOVEGROUND PETROLEUM STORAGE ACT INSPECTION <br /> REPORT—711 MATERIALS, 2714 STAGECOACH RD, STOCKTON, CA 95215 (CERS <br /> ID: 10184763) <br /> Dear Ms. Baker, <br /> 711 Materials has prepared this letter in response to the San Joaquin County Environmental <br /> Health Department (SJCEHD) Aboveground Petroleum Storage Act Inspection Report, dated <br /> June 04, 2019. In order to facilitate review of 711 Materials' responses and actions taken to <br /> address violations noted by the SJCEHD, this letter is formatted with the SJCEHD remarks in <br /> italics and facility responses immediately following. <br /> Item # 301: <br /> CFR 112.5(a) Failed to amend Plan as necessary. <br /> One silver, approximately 100-gallon diesel tank was observed in the truck wash area. The <br /> tank had diesel in it at the time of the inspection. This tank was not included in the SPCC plan. <br /> The Spill Prevention, Control, and Countermeasure (SPCC) Plan must be amended when <br /> there is a change in the facility design, construction, operation, or maintenance that materially <br /> affects its potential for a discharge, within 6 months of the change, and implemented as soon <br /> as possible, not later than 6 months following preparation of the amendment. Immediately <br /> ensure the SPCC Plan accurately represents the procedures and policies currently in place <br /> at the facility and submit proof to the EHD. <br /> This is a minor violation. <br /> 711 Materials Response: <br /> The tank observed in the truck wash area during the inspection on June 4t" was a gas tank <br /> that had been removed from a truck temporarily for maintenance being performed on the truck <br /> itself. The tank is a "motive power container"as defined in 40 CFR 112.2 and is excluded from <br /> the aggregate aboveground storage capacity of the facility as allowed by 40 CFR <br /> 112.1(d)(2)(ii). The tank has since been reinstalled on the vehicle and is no longer in the truck <br /> wash area as documented in the following picture. Additionally, as this tank was never <br /> intended to be for the storage of fuel or oil at the facility, it has not been added to the facility's <br /> SPCC Plan at this time. In the future, should the 711 Materials procure additional oil storage <br /> tanks for use on site, the SPCC Plan will be amended within 6 months to include such <br /> changes. <br />