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SA TC-0 <br /> Su 1phuric Acid Trading Company,In c. <br /> June 13, 2020 <br /> TO: Garrett Backus, San Joaquin County Environmental Department <br /> FROM: SATCO, Stockton Terminal, Carey MacConnell; Mike Peterson <br /> RE: Statement Regarding Hazard Material Inspection Report <br /> The SATCO Stockton Terminal is a new start up facility at the Port of Stockton. During the inception, design <br /> and build of this terminal we engaged with multiple contractors who we considered experts in their field of <br /> environmental requirements. <br /> 1. We engaged with an Environmental firm that developed our CUPA, HMBP, set us up in S.M.A.R.T and <br /> CERES. <br /> 2. For clarity purposes around reporting requirements and timelines we followed the direction of this <br /> firm. Please see correspondence dated March 2, 2020 and March 13, 2020 regarding the direction we <br /> were given. <br /> March 2, 2020: "Per our call Section 302 of EPCRA relates to emergency planning. This section requires you to have your <br /> emergency contingency plan which is part of your existing CUPA plan. <br /> Section 304 of EPCRA relates to reporting of accidental releases of EHSs and hazardous substances defined in CERCLA. If <br /> you have a release over reportable quantities, that's when a notification to the agency is required. <br /> CUPA updates are required annually to CERS. Please let me know when SATCO has had a chance to review our cost <br /> estimate for additional CUPA support." Written by our Environmental Consultant <br /> March 13 2020 "Even though Trinity consultants had indicated that we have until July 2020 to update our Cupa plan and <br /> hazardous material inventory as per emails below and several phone calls between SATCO(Pete, Rogerio, Carey and 1)and <br /> them, 1 have reached out today to CERS(San Joaquin county and reviewed with them the update requirements. Mr. Haza <br /> Saeed(Lead Sr Environmental Health specialties)of San Joaquin county, indicated plans are to be updated or verified every <br /> year between nov-1 and Jan 15th(this time period was reviewed with Trinity and it was indicated that we are ok for year <br /> 2020). He helped me to update the system on CERS and indicated SATCO will not see any issue as resulted of this <br /> update. He indicated that they are working on their backlog and we may hear from them within 1-2 months from now. He <br /> indicated that otherstates do this by March 1 but not California"Written by our past Terminal Manager <br /> We share this to make sure you understand we are focused on following and complying with all regulations and <br /> honestly believed we were meeting the requirements. <br /> Also included in this packet from our inspection on June 15th: <br /> • HW Return to compliance Form <br /> • Updated Emergency Site Map (completed by FROG Environmental) <br /> • Updated section of SATCO's internal Emergency Response Plan,which includes the table of content and <br /> Section 10, Reporting requirements. <br /> • Employee Retraining on Reporting Requirements <br /> Thankyou <br /> Carey MacConnell Mike Peterson <br /> Operations Manager Stockton Terminal Manager <br /> SATCO SATCO <br /> cmacconnell@satcoinc.net mpeterson@satcoinc.net <br />