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to contest the tank, provide a manufacturer statement confirming the used oil tank can be used as a <br /> portable container. <br /> b. In addition,the violation #33 will stand. Per 40 CFR 262.16(b).(2).(iv),and 22 CCR § 66265.174, <br /> containers are subject to weekly inspections. We apologize for any misunderstanding regarding the <br /> use of the word "Tank" in this section. <br /> Best, <br /> Kristina Saetern <br /> Environmental Health Specialist <br /> San Joaquin County Environmental Health Department <br /> 1868 E. Hazelton Avenue Stockton, CA 95205 <br /> P: (209) 616—3045 1 E: ksaetern@sjgov.org <br /> www.sjgov.org EHD <br /> S OAQUI <br /> COUNTY— <br /> Greatness grows here. <br /> From:Jenna Kube<Jenna.Kube@trinityconsultants.com> <br /> Sent:Tuesday,July 23, 2024 5:08 PM <br /> To: Saetern, Kristina Gaen [EHD] <ksaetern@sjgov.org> <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 /> Subject: 3028 Navy Drive - Inspection Reports Follow Up <br /> Hello Kristina, <br /> I am reaching out on behalf of my client, Pelican Renewables, to follow up with some questions following the <br /> receipt of the San Joaquin County CUPA inspection reports. <br /> My questions are as follows: <br /> 4. 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 /> 5. There are some items that may not be closed by the stated return to compliance date (Aug 5th). As noted in <br /> 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 /> 6. 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 />