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IKtcAette “PmC <br />Safety / Compliance <br />California Materials, INC <br />3736 S. Hwy 99 <br />Stockton, CA 95215 <br />Cell - 209-715-0094 <br />Office - 209-472-7422 Ex.25 <br />Hi Michelle, <br />5 <br />Regarding the ARSA 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 />CMAT <br />AGGREGATES • TRUCKING <br />From: Sammons, Lynsey [EHD] <lsammons(5)sigov.org> <br />Sent: Wednesday, July 31, 2024 9:26 AM <br />To: Michelle Post <michelle.post@californiamaterials.com> <br />Cc: Saeed, Haza [EHD] <hsaeed@sigov.org> <br />Subject: RE: CP22-AST Corrective Actions