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October 9, 2014 <br /> Stacy Rivera <br /> San Joaquin County Envir. Health Dept. <br /> 600 East Main Street <br /> Stockton, CA 95202 <br /> RE: A. Teichert & Son, Inc. <br /> 120 Frank West Circle, Stockton <br /> Comments to inspection dated 9/11/15 <br /> Aboveground Petroleum Storage Act Inspection Report <br /> Item 603 —The SPCC plan stated that weekly visual inspections and yearly tests <br /> of the double wall tank interstitial sensors would be employed as "environmental <br /> equivalence" to other methods. In fact this was the environmental protection <br /> suggested by Peter Reich of the US EPA at a conference at your building in <br /> 2009. Since then more language has been added to SPCC regulations to make <br /> it even tougher to show "equivalent environmental protection. At this point, I know <br /> the regulatory industry will all line up against us. So, reluctantly, we will use STI <br /> SP001 annual and monthly inspections. Weekly visual inspections will be <br /> replaced with monthly and yearly visual inspections per STI. Annual testing of <br /> interstitial sensors will no longer be done. Revised SPCC page attached. <br /> Item 609 — Secondary containment for the oil tanks is already provided as stated <br /> in the SPCC plan. The oil tanks are located on the concrete floor within the <br /> building. The concrete floor slopes towards the center of the building which has <br /> two floor drains that drain to a containment sump with no outlet. Furthermore <br /> the entire facility has containment provided by (2) 2,500 gallon underground <br /> oil/water separators. <br /> Item 613 —As stated above for Item 603, weekly inspections will be ended and <br /> replaced by monthly and yearly inspections using STI SP001 inspection <br /> checklists. <br /> t�-.c I <br /> �i <br /> SEP 1 <br /> ENVIRONMENTALA <br />