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Ruvalcaba, Cesar <br /> From: Ruvalcaba,Cesar <br /> Sent: Tuesday,August 13,2019 1:59 PM <br /> To: 'Joseph Gigli <br /> Subject: RE: Gigli s Lathrop (SPCC) - PR0527892 <br /> Attachments: WRRDA Factsheet.pdf, APSA Farm Fact Sheet.pdf <br /> Hi Joseph, <br /> There are exemptions for farm facilities under California Regulations or Aboveground Petroleum Storage Act(APSA)and <br /> Spill Prevention,Control,&Countermeasure(SPCC)regulations(federal). I have attached a pamphlet from the federal <br /> perspective and the state perspective. <br /> It all depends on what the qualifying petroleum product is used for. I was under the impression that the tanks were for <br /> the fueling and maintenance of trucks and squeezes and that the facility buys and sells hay and is not devoted to <br /> farming.The trucks and squeezes would not be part of an farm operation as defined in regulations.The facility falls <br /> under two other programs within our department and none classify the facility as a farm. <br /> APSA regulations defer to the SPCC regulations for the definition of a farm-"a facility on a tract of land devoted to the <br /> production of crops or raising of animals,including fish,which produced and sold,or normally would have produced and <br /> sold,$1,000 or more of agricultural products during a year." <br /> If you feel the facility meets the definition of a farm,let me know why you feel that is. Provide a list of all activities that <br /> the facility performs,including those that may not fall under farming. Include a description of the full business activities <br /> of Gigli Hay. This will be discussed with management. <br /> It is possible that even though the facility may be a farm,a P.E certified SPCC plan may still be required under the federal <br /> regulations because the storage capacity exceeds 6,000 gallons. <br /> Thank you, <br /> Cesar Ruvalcaba <br /> San Joaquin County Environmental Health Department Environmental Health Specialist <br /> 1868 East Hazelton Ave <br /> Stockton,CA 95205 <br /> Office:(209)953-6213 Fax: (209)464-0138 Email:cruvalcaba@sjgov.org <br /> —Original Message— <br /> From:Joseph Gigli<jgigli24@gmaiLcom> <br /> Sent:Tuesday,August 13,2019 10:22 AM <br /> To: Ruvalcaba,Cesar<cruvalcaba@sjgov.org> <br /> Subject:Gigli's Lathrop(SPCC) <br /> In having a conversation with my insurance agent a few days ago, I told him about the county requiring an SPCC plan. <br /> He told me to do a little research because he thought ag was exempt,especially because we are farming here. I aske <br /> Greg at Ground zero about this exempt and he thought I should talk to you before he proceeded. <br /> 1 <br />