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Baker, Lydia <br /> From: Michael Collins <mcollins@foodexp.com> <br /> Sent: Monday, April 13, 2020 4:50 PM <br /> To: Baker, Lydia; Kevin Keeney;Justin Keeney; Lindsay Keeney-Derryberry <br /> Cc: greeves455@aol.com <br /> Subject: RE: Return to Compliance <br /> Attachments: SPCC Plan 2020-04-13.pdf <br /> Importance: High <br /> Hi Lydia I will get with Gary to add the secondary containment. In regards to the 55 gallon drums that is correct we <br /> reduced to products that were in 55 gallon drums to 5 gallon buckets and disposed/ recycled the 55 gallon drums. 3 of <br /> which were just about empty and had been here for years. <br /> For the Testing I will get with Gary and see if he can be more specific and I will send any updated pages as I get them <br /> from him to satisfy the Monthly and Annually Inspections. <br /> Here is a copy of the entire SPCC binder as well as it is currently. <br /> Thanks, <br /> FOOD EXPRESS, INC. <br /> Michael Collins <br /> Terminal Manager <br /> P 209-858-2142 <br /> F 209-858-2418 <br /> From: Baker, Lydia [mailto:lbaker@sjgov.org] <br /> Sent: Monday,April 13, 2020 11:18 AM <br /> To: Michael Collins<mcollins@foodexp.com>; Kevin Keeney<kkeeney@foodexp.com>;Justin Keeney <br /> <jtkeeney@foodexp.com>; Lindsay Keeney-Derryberry<Ikeeney@foodexp.com> <br /> Cc:greeves455@aol.com <br /> Subject: RE: Return to Compliance <br /> Hello Michael, <br /> Based on what you sent me I cannot close out those two open violations. Please send me a copy of the entire certified <br /> SPCC plan. <br /> 612-The pages provided do not discuss the secondary containment for the used oil and new oil tanks. Page 29 states <br /> that there are no mobile/portable containers (55 gallon drums) but Cesar observed 55 gallon drums on site. Are the 55 <br /> gallon drums gone now? <br /> 710-Page 29 says the STI SP001 standard will be used. The section only discusses monthly inspections. SP001 standard <br /> requires annual inspections as well as formal external inspections for some tanks. These items are not discussed in the <br /> pages provided. If you are deviating from an industry standard then a PE must certify an environmentally equivalent <br /> alternative in the SPCC Plan.The Plan must provide the reason for the deviation, describe the alternative approach, and <br /> explain how it achieves environmental protection equivalent to the applicable industry standard. <br /> 1 <br />