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Outlook <br /> 3028 Navy Drive - Inspection Reports Follow Up <br /> From Jenna Kube <Jenna.Kube@trinityconsultants.com> <br /> Date Tue 7/23/2024 5:09 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 /> 3 attachments(1 MB) <br /> HW RTC.pdf, PR0528381 - 3028 Navy Drive HW.pdf; Used Oil Picture.PNG; <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 /> 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 /> 2. 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 /> 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 /> I appreciate your time and consideration. Please feel free to reach out if you have any questions or concerns. If <br /> you prefer, we can set up some time to discuss over a call. <br /> Thank you, <br /> 7enna Kube <br /> Senior Consultant <br /> M 720.879.1670 <br /> 7919 Folsom Blvd, Suite 320, Sacramento, CA 95826 <br /> Email: jenna.kubeCcbtrinityconsultants.com <br /> TO n it <br /> Consultants <br />