Laserfiche WebLink
Ruvalcaba, Cesar <br /> From: Naidu, Muniappa <br /> Sent: Wednesday,January 8, 2020 12:44 PM <br /> To: Ruvalcaba,Cesar <br /> Cc: Memo, Elena K. <br /> Subject: RE: Atlantic Aviation APSA- FA0007770 and FA0016555 <br /> Could they add something in the comment section to reflect what they are trying to do—just a thought. <br /> Muniappa Naidu <br /> Program Coordinator <br /> San Joaquin County Environmental Health Department <br /> Phone: (209) 468-3439 <br /> Fax: (209) 468-3433 <br /> mnaiduOSOClov.ora <br /> Please note that my email address has changed: mnaiduOsicov.orc <br /> From: Ruvalcaba,Cesar<cruvalcaba@sjgov.org> <br /> Sent: Wednesday,January 8,2020 12:06 PM <br /> To: Manzo, Elena K.<emanzo@sjgov.org> <br /> Cc: Naidu, Muniappa<Mnaidu@sjgov.org> <br /> Subject: RE:Atlantic Aviation APSA-FA0007770 and FA0016555 <br /> I don't think there was a change at the facility,but I am waiting for a call back from them to verify. What I think <br /> happened is that when we were going through CERS someone noticed that they had marked yes for the APSA program <br /> in CERS for the HQ facility and that we did not have an open APSA program for them.An APSA program was then <br /> created. If the facility,hasn't made any changes to the operation of the tanks and I inactivate them,this will most likely <br /> happen again in the future. Someone will notice that CERS and our program inventory do not match up and add them. <br /> Not sure what the workaround for this would be. But in the meantime that is just my theory, I will know more once I get <br /> a call back. <br /> Thanks-Cesar <br /> From: Manzo, Elena K.<emanzoCnlsiaov.ora> <br /> Sent:Thursday,January 2,2020 9:26 AM <br /> To: Ruvalcaba,Cesar<cruvalcaba@siaov.ora> <br /> Cc: Naidu, Muniappa<MnaiduCnlsiaov.ora> <br /> Subject: RE:Atlantic Aviation APSA-FA0007770 and FA0016555 <br /> Hi Cesar, <br /> I'd agree with you,based on the definition of facility in 112.2,the two separate site locations can be considered a single <br /> facility provided that the owner identified that two separate buildings as a single facility and they are adequately <br /> covered under their SPCC plan: "Facility means any mobile or fixed, onshore or offshore building,property,Parcel,lease, <br /> structure,installation,equipment,pipe,or pipeline(other than a vessel or a public vessel)used in oil well drilling <br /> operations, oil production,oil refining,ail storage"ail gathering, oil EMgssina,ail transfer,ail distribution, and oil waste <br /> treatment or in which oil is used, as described in appendixA to this part. The boundaries of a facilit depend on several <br /> site-specific factors,including but not limited to, the ownership or operation of buildings,structures, and equipment on <br /> 1 <br />