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WH <br /> FInc. Environmental and Engineering Group <br /> Post Office Box 427 <br /> CA 95361-0427 <br /> RD E `E rl'iF= D OaOffice: (09) 848-4280 <br /> 1 LO10 Fax: (209) 848-4282 <br /> Ua,i L <br /> October 18, 2010 ENVIRONMENT HEALTH <br /> PERMIT/SERVICES <br /> Mr. Muniappa Naidu <br /> San Joaquin County <br /> Environmental Health Department <br /> 600 East Main St. <br /> Stockton, CA 95202-3029 <br /> Re: Spill Prevention Control and Countermeasures Plan for Brown Sand, Inc. 800 West <br /> Mossdale Rd. Lathrop, CA <br /> Dear Mr. Naidu, <br /> Enclosed please find a copy of the Return to Compliance Certification and one copy of the Spill <br /> Prevention Control and Countermeasures Plan dated October 15, 2010 for the aforementioned <br /> site. This plan has been prepared in response to the inspection on August 27, 2010 and the <br /> violations listed on the Aboveground Petroleum Storage Tank Program Inspection Report. We <br /> apologize for the delay in submission of this plan however; secondary containment structures had <br /> to be upgraded. <br /> As you know, as a result of the same inspection a Underground Storage Tank Program Inspection <br /> Report was also received which notes the presence of 4 tanks operating below grade"without a <br /> permit." A Return to Compliance Certification for this inspection report is also attached. In <br /> response to this inspection report Brown Sand, Inc. submitted a UST Operating Permit <br /> Application dated August 26, 2010. The summary of violations sites the Health and Safety Code <br /> section 25283.5(a) for the exemptions from UST criteria as being: <br /> 1) Have all exterior surface of the tanks, including piping and the flooring directly beneath the <br /> tanks, monitored by direct viewing. <br /> 2) The structure in which the tank is located is constructed in such a manner the structure <br /> provides for secondary containment of the content of the tank. <br /> 3) The owner or operator of the UST conduct weekly inspections of the tanks and maintain a log <br /> of inspection results for review. <br /> After our inspection of the vaulted tanks and review of inspection logs it appears that all three <br /> conditions of§25283.5(a) are being met and therefore the facility should not be required to meet <br /> all the UST requirements for monitoring and testing. In addition, the operation of the 4 tanks <br /> within the vaulted concrete containment structure is addressed in the SPPC plan. <br />