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SLR International Corporation, 17701 Cowan, Suite 210, Irvine, CA 92614 <br />949 553 8417 slrconsulting.com <br />Memorandum <br />April 27, 2021 <br />To: Haza Saeed <br />Lead Sr. Registered Environmental Health Specialist <br />San Joaquin County Environmental Health Department <br />1868 E. Hazelton Ave <br />Stockton CA 95205 <br />Re: Savage Services <br />HMBP Exemption at Stockton Transloading Facility <br />Dear Mr. Saeed, <br />This memo provides a summary of the findings identified during a Hazardous Material Business Plan <br />(HMBP) Applicability Assessment for Savage Services Stockton Transload facility performed by <br />SLR Consulting (SLR). <br />In April 2021 Savage Services requested SLR to complete a HMBP Applicability Assessment for a <br />future Transload facility to be located in Stockton, California. During the review of the facility’s <br />planned operations SLR became aware that the facility would not conduct storage of hazardous <br />materials on site. Storage, in this case, does not include the storage of hazardous materials incidental to <br />transportation, as defined in Title 49 of the Code of Federal Regulations, with regard to the inventory <br />requirements of California Health and Safety Code Section 25506. <br />The facility will only be transloading hazardous materials (biodiesel, renewable diesel, molten sulfur, <br />and fly ash) between tanker trucks and rail cars which will be designated as in transit. Therefore, the <br />site is exempt from having to prepare a HMBP per the Transportation Exemption in the California Health <br />and Safety Code Section 25506. <br />To confirm the above statements, on April 15, 2021, SLR contacted the San Joaquin County <br />Environmental Health Department (SJCEHD) for an official determination. Attachment 1 details the <br />confirmation of the facility’s exemption by the SJCEHD. Attachment 2 includes documents and text <br />referenced by the SJCEHD.