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Hi Michelle, <br />Let me know if you have any questions, thanks! <br />2 <br />San Joaquin County Environmental Health Department <br />1868 E. Hazelton Avenue, Stockton, CA. 95205 <br />www.siqov.org/ehd <br />From: Sammons, Lynsey [EHD] <lsammons@sjgov.org> <br />Sent: Wednesday, July 31, 2024 9:26 AM <br />To: Michelle Post <michelle.post@californiamaterials.com> <br />Cc: Saeed, Haza [EHD] <hsaeed@sjgov.org> <br />Subject: RE: CP22-AST Corrective Actions <br />Regarding the APSA inspection for the ASTs on site, we're almost there. Again, just a few issues to close out the last few <br />items. I've closed out #s 3, 30, 32, 51, 52, and 79. There are four that have not been fully addressed or possibly just need <br />some clarification. Please see below: <br />• #13 - Is the facility claiming environmental equivalence for overfill prevention? In section 4.7 on page 27 the <br />updated SPCC plan states, "As allowed by 40 CFR Part 112.7(a)(2), overfill protection may be achieved via an <br />alternate method to achieve equivalent environmental protection. At CMAT overfill protection is achieved <br />procedurally." However, overfill is not mentioned at all in section 4.6 on the same page, which is the section on <br />environmental equivalence. This section only mentions secondary containment for the 55-gallon drums in the <br />shop and does not address the two topics identified in the inspection report (overfill prevention and integrity <br />testing). It looks like the updated plan specifies that integrity testing will now be accomplished via industry <br />standard instead of environmental equivalence so that topic is fine. If, however, the facility is still claiming <br />environmental equivalence for overfill prevention, it should be described, or at least referenced in the <br />environmental equivalence section. <br />• #15 - The RTC certification form states that "the drums documented on this violation have been drained and <br />removed from the facility". Where were these drums drained into? Can you provide records of proper disposal? <br />• #16 - The diagram is still missing labels for the loading/unloading areas. This label is required by 40 CFR 112, the <br />federal SPCC Rule regulations. <br />• #57 - I see the monthly inspection reports that you've been doing since we were on site, which is great. In <br />addition to the monthly inspections, in your RTC statement for this item, please also indicate the facility's plan <br />for annual inspections and records of annual inspections. <br />Lynsey Sammons <br />Environmental Health Specialist <br />Cell: (209)616-3067 <br />Office: (209) 468-3420 <br />CMAT <br />AGGREGATES • TRUCKING