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Outlook <br /> Re: 3028 Navy Drive - Inspection Reports Follow Up <br /> From Saetern, Kristina Gaen [EHD] <ksaetern@sjgov.org> <br /> Date Wed 7/24/2024 3:54 PM <br /> To Jenna Kube <Jenna.Kube@trinityconsultants.com> <br /> Cc Paul Koehler <paul.koehler@pelicanrenewables.com>; Edker McCullough <br /> <Edker.McCullough@pelicanrenewables.com>;Jeff Adkins <JAdkins@trinityconsultants.com>; Stephen Cao <br /> <scao@trinityconsultants.com> <br /> (� 1 attachment(39 MB) <br /> Photos.pdf; <br /> Hello, <br /> To answer your questions my response is in blue. <br /> My questions are as follows: <br /> 1. Would you be able to provide any pictures that were taken during your site visit?We would like to be able <br /> to provide clear pictures of closure for each of the applicable items, and ensure the facility is addressing the <br /> specific containers and items noted in the inspection reports (for HMBP, APSA, and Hazardous Waste). <br /> a. Attached are photos from the 2024 inspection. <br /> 2.There are some items that may not be closed by the stated return to compliance date (Aug 5th).As noted <br /> in the HW report, there is a wasp/bee infestation in the container accumulation area that is preventing <br /> personnel from inspecting the area and is preventing a waste vendor from packing and shipping the waste <br /> for disposal.The facility is in the process of contacting an exterminator to handle the issue, but it is unlikely <br /> that the extermination and subsequent shipment of waste containers will occur prior to the RTC date. Can <br /> you please confirm that it would be sufficient for the facility to provide the plan of action to close the <br /> applicable finding items and the anticipated date of closure on the RTC forms? <br /> a. Return the RTC with an anticipated date of closure. The violations will be remained open until the <br /> corrections are completed. <br /> 3. We are seeking your concurrence that the hazardous waste tank for used oil noted in the HW report (items <br /> #32 and#33) is not considered a "tank" upon review of the regulatory definitions (found at 22 CCR <br /> 66260.10) and is instead classified as a container. The definition of"tank" includes a "stationary device..."; <br /> however, Pelican's used oil tank is portable (i.e., not fixed in place and not connected to any system, <br /> ancillary equipment, or containment system—picture attached). Would you please let me know if you <br /> agree with this interpretation or if we are looking at the wrong piece of equipment? <br /> a. Per the code section from DTSC "A stationary device, designed to contain an accumulation of <br /> hazardous waste constructed primarily of non-earthen materials (e.g.,wood, concrete, steel, plastic) <br /> which provide structural support. [22 CCR section 66260.10] Note:Devices designed to allow <br /> attached"hard-piping"are considered to be tanks because this indicates that they are not <br /> intended to be moved while in use."This tank does have a hard-piping connection. If you would like <br />