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SAVAGE _ <br /> March 25, 2022 <br /> Ms. Elena Manzo <br /> San Joaquin County Environmental Health Department <br /> 1868 E Hazelton Ave, Stockton, CA 95205 <br /> Subject: SPCC and California APSA Applicability-Savage Services Stockton Transload Facility <br /> This correspondence discusses the applicability of the federal Spill Prevention Control and <br /> Countermeasures(SPCC)rule and the California Aboveground Petroleum Storage Act(APSA)to the Savage <br /> Stockton Transload facility. Savage has investigated the applicability of the SPCC rule to transloading <br /> activities at multiple sites across the US. Following is information about our current process, and a <br /> summary of our findings. The petroleum products at our transload facilities, including Stockton, are <br /> considered in transportation. They are managed within a U.S. Department of Transportation (US DOT) <br /> regulated transportation-related facility. Therefore, these petroleum products are not subject to the <br /> requirements of the SPCC rule and the California APSA. <br /> SITE DESCRIPTION <br /> Savage Services (Savage) provides transportation, logistics, materials handling, and other industrial <br /> services for Customers' supply chain needs. Savage operates a transload facility located at 1033 Stokes <br /> Avenue, Stockton, CA 95215. The facility transloads a variety of petroleum products with mobile racks to <br /> meet customer demands including aviation gasoline, E85 gasoline, unleaded aviation gasoline, ethanol <br /> biodiesel, and renewable diesel. Savage also transloads other non-petroleum based products including <br /> molten sulfur and flyash. <br /> Savage has obtained an air permit for the facility through work with Johnathan Yoshimura of the San <br /> Joaquin Air Pollution Control District and has submitted a Hazardous Materials Business Plan for the <br /> Operation. <br /> PROCESS DISCUSSION <br /> Figures 1a and 1b present overhead images of the site(current boundaries and proposed expansion)while <br /> Figure 2 presents a detailed site drawing of the Stockton transloading facility as currently configured. <br /> Railcars are brought to the facility by Stockton Terminal & Eastern railroad and temporarily staged while <br /> awaiting loading or unloading. The majority of transfers involve transferring liquid bulk products from <br /> railcars to trucks. Each railcar holds approximately four truckloads of product. <br /> When Savage receives an order from a customer, Savage coordinates railcar delivery with a trucking <br /> service. A tanker truck then arrives at a scheduled loading date and time. Trucks arriving at the terminal <br /> either(1)cross the Operation's truck scale to obtain a light/tare weight,and the driver reports to Savage's <br /> Savage Services Corporation • 901 W. Legacy Center Way• Midvale, Utah 84047 • 801-944-6600 • www.savageservices.com <br />