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1 <br />Garcia-Mejia, Gabriela [EHD] <br />From:Jordan Johnson <jordan.johnson@vpps.net> <br />Sent:Thursday, March 30, 2023 12:08 PM <br />To:Garcia-Mejia, Gabriela [EHD] <br />Cc:Ed Ward; Grant Crum; Will Harp; Mike Eliason <br />Subject:RE: APSA and HW inspection reports for 166 Frank West <br />Hello Gabriela, <br /> <br />I have received your requests regarding the return to compliance for our Stockton facility. For your reference I have <br />copied the requests followed by the response below. Please feel free to contact me with any further ques Ɵons. <br /> <br />HW <br />502-The HW tank inspecƟon form you referenced only addresses weekly inspecƟons not daily. Please provide me with <br />documentaƟon that shows daily hazardous waste tank inspecƟons are being done. <br /> <br />Response - Our facility is a small quanƟty hazardous waste generator (SQG). According to hazardous waste regulaƟons <br />found in 40 CFR 262.16(3)(iv), a SQG can inspect the tank weekly if the tank has full secondary containment. We have <br />indicated on the training form that our waste oil container has full secondary containment - it is a double walled tank <br />located in a wash bay connected to an oil water separator. Our understanding is that weekly inspec Ɵons allowed under <br />40 CFR 262.16(3)(iv) meet the inspecƟon requirements idenƟfied in 40 CFR 262.16(3)(iii) and daily inspecƟons are not <br />required. <br /> <br />APSA <br />301-The SPCC plan included sƟll lists manual sight tank gauging for tanks 1-6 instead of the 'red trac' remote liquid level <br />sensor that was observed during the inspecƟon. Please provide me the page of the SPCC plan where the change has <br />been made. <br /> <br />Response - Upon further review of the Redtrac equipment, it was determined they are primarily used for inventory <br />control and not applicable for overfill prevenƟon. The sensors are unable to provide constant real-Ɵme updates, which is <br />why they have not been added as SPCC Plan overfill prevenƟon. The SPCC secƟons covering tank overfill prevenƟon (pg <br />3, 14) are current. In essence, the tanks are either equipped with a liquid level gauge visible by the delivery driver or a <br />second aƩendant is present monitoring and relaying the liquid level info to the tank truck operator during tank fill. <br /> <br /> <br />Respecƞully, <br /> <br />Jordan Johnson <br />Safety and Regulatory Specialist <br />Valley Pacific Petroleum Services, Inc. <br /> <br />-----Original Message----- <br />From: Garcia-Mejia, Gabriela [EHD] <ggarcia-mejia@sjgov.org> <br />Sent: Wednesday, March 29, 2023 4:12 PM <br />To: Jordan Johnson <jordan.johnson@vpps.net> <br />Cc: Ed Ward <ed.ward@vpps.net>; Grant Crum <grant.crum@vpps.net>; Will Harp <will.harp@vpps.net>; Mike Eliason <br /><mike.eliason@vpps.net> <br />Subject: RE: APSA and HW inspecƟon reports for 166 Frank West <br />