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2 <br />nrichards@InterstateOil.com <br />www.interstateoil.com <br /> <br />Disclaimer: This email, including attachments, is covered by the Electronic Communications Privacy Act, 18 U.S.C. 2510-2521, and is legally privileged and <br />confidential. If you are not the addressee named above, you are hereby notified that any dissemination, distribution, copying or taking any action based upon this <br />communication is strictly prohibited. If you have received this communication in error, please notify the sender immediately by reply email and delete this message <br />and any attachments from your computer. <br /> <br />From: Sammons, Lynsey [EHD] <lsammons@sjgov.org> <br />Sent: Thursday, August 29, 2024 11:38 AM <br />To: Nicholas Richards <nrichards@interstateoil.com> <br />Cc: Saeed, Haza [EHD] <hsaeed@sjgov.org>; Dominic Dacay <ddacay@interstateoil.com> <br />Subject: RE: PR0530044 - 4900 Mariposa Rd - 6-14-24 - APSA Inspection Report <br /> <br />CAUTION: [External Email] - This email originated from outside InterState Oil Company's email system. <br /> <br />Good morning Nick, <br /> <br />I haven’t seen an update come through, were you able to get confirmation on your reporting procedures and <br />finalize the SPCC Plan? <br /> <br />I’ve reviewed the RTC documents you submitted and was able to close 6 violations. However, 11 remain open. A <br />few can be addressed with just a modified RTC statement so I’ve included an updated blank copy of the RTC <br />certification form. Here is a status update on each violation including what is still needed for those items not <br />adequately addressed: <br /> <br />#3 – Pending resolution of items 10, 17, 24, 41, 52, 56, 57 and 74 <br /> <br />#10 – The statement provided does not adequately address the violation. I do see that the plan has been reviewed <br />and is now dated July 1, 2024. However, the return to compliance statement should indicate that going forward 5- <br />year reviews will be conducted as required and described in the SPCC Plan. <br /> <br />#11 – Resolved <br /> <br />#14 & 41 – I’m not sure why item #14 didn’t show up on your RTC certification form, but it is on the actual <br />inspection report. Some issues related to this item have been addressed but still needed is the site’s proximity to <br />navigable waters. Additionally, to resolve both items #14 & 41 clarification is needed on where drainage from the <br />AST secondary containment goes after being manually released into the dry well basin using the drain valve. <br /> <br />#16 – Resolved <br /> <br />#17, 24, & 41 – The issue of loading/unloading areas and use of storm drain covers does not appear to be <br />consistently amended throughout the new SPCC Plan and throughout the submitted RTC statements. Please <br />clarify whether the use of “properly designed storm drain covers” has been adopted at this site as per Apex’s <br />recommendation. Below are a few examples of the inconsistencies I found but there may be more. Please ensure <br />that this is addressed consistently throughout the updated SPCC Plan and RTC statements. <br /> On page 13 under the heading Loading/Unloading Areas, there is still that language regarding Apex’s <br />recommendation that “properly designed storm drain covers be placed over storm drains DI-1 and DI-3 <br />prior to any transfer operations” in the area but no clear statement as to whether this recommendation has <br />been adopted.