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Cesar Ruvalcaba [EH] <br /> From: Chong Lee <chong.lee@fedex.com> <br /> Sent: Thursday,January 3, 2019 4:35 PM <br /> To: Cesar Ruvalcaba [EH] <br /> Subject: FedEx Freight <br /> Attachments: scan1313.pdf <br /> Hi Cesar, <br /> Good talking to you, and I appreciate you taking the time to discuss your inspection results with me. <br /> With regards to item 710, inspections of ASTs are discussed in page 11—12 (attached) of our SPCC plan. As indicated in <br /> this section, rational for why "environmental equivalence" is applicable to this site is discussed, and includes reference <br /> to: SPCC Guidance for Regional Inspector,Version 1.0, November 28, 2005, Office of Emergency Management, EPA 550- <br /> 6-05-001. Given that our tanks are all "shop built" containers that are smaller than 30,000 gallon, and elevated,the <br /> Professional Engineer who certified this plan has determined that visual inspections provides equal environmental <br /> protection. Thus, reference to an industry testing/inspection standards is not needed for our plan. <br /> I would appreciate it if you could review the attached, particularly the highlighted sections,then reconsider whether <br /> violation 710 is still applicable. <br /> Thanks, <br /> Chong <br /> 408-654-3112 <br />