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San Joaquin County Environmental Health Department <br /> Environmental Health Specialist <br /> 1868 East Hazelton Ave <br /> Stockton,CA 95205 <br /> W (209)953-62131 A (209)464-0138 ® cruvalcabaPsiaov.ora <br /> SANJOANIN <br /> COUNTY <br /> r?.. Gi�oe�e., h .•,. <br /> From: DPaul<spccorp@hotmail.com> <br /> Sent: Monday,July 22,2019 1:14 PM <br /> To: Ruvalcaba,Cesar<cruvalcaba@sjgov.org> <br /> Subject: Re: Return To Compliance-DRAFT submittal for Haley Flying Service <br /> Cesar: <br /> I do NOT believe we are in disagreement on ANY of the enumerated issues as follow: <br /> 1. We/SPC Corp intends on "rewriting" the 2015 SPCC plan because there have been <br /> substantial/significant changes in onsite fuel/lube/etc. storage since it was originally certified. (e.g., <br /> waste oil storage; waste coolant storage)----numerous "out-of-service" tanks that remain un-labeled. <br /> 2. The rewritten SPCC plan will be re-certified by one of our PEs. We find this to be a Tier 11 facility based <br /> upon both our federal (40CFR112) and California(APSA) references that: <br /> a)there is a single tank greater than 5000 gallons AND <br /> b) aggregate storage of more than 10,000 gallons. Please confirm you are in agreement with these <br /> provisions. <br /> 3. Relative to nurse tanks, we have been instructed by Region 9 of US EPA that these are applied to those <br /> tanks storing fuel (primarily diesel) which go into the ag-field for satellite operations and return to the <br /> home-base on a daily basis. Moreover, no heating oil applies to west-coast operations. SPC Corp has <br /> certified SPCC plans which do reference heating-oils(under UL Standard 80) but this is primarily <br /> through the Midwest and Eastern seaboard. We further will seek your conclusion on whether/not the <br /> mobile refuelers are subject to regulation under the"home-rule" provision of virtually ALL <br /> regulations.....the local AHJ can always make the benchmark STRICTER than the federal guideline but <br /> never less-stringent. <br /> 4. An additional factor in wet-stamping the rewrite will be the fact that the original "singlewall" 1000- <br /> gallon AST was never submitted for corrective action. We will obtain a timeline for this compliance <br /> measure and share with you to insure we are on schedule. <br /> 5. The frequency provisions of our SPCC plan was based upon 2015 guidelines set forth in the CUPA <br /> forum held in Cupertino, CA in 2015. We have since been referencing Chapter 7 of the Regional <br /> Inspectors Guide of the US EPA website. We remain unconvinced that our recommendation for <br /> "weekly" inspections rather than monthly lowers the caliber/quality of onsite fuel- <br /> management. Moreover, we provided blank forms to initiate this practice---final thought: the <br /> northern boundary of the property borders a navigable waterway as does the southern boundary. We <br /> were attempting to implement the strictest measure of compliance as a result. <br /> 3 <br />