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Baker, Lydia <br /> From: Baker, Lydia <br /> Sent: Friday, May 31, 2019 2:02 PM <br /> To: 'Deporto, Courtney' <br /> Cc: Ruvalcaba, Cesar <br /> Subject: RE: Inspection Report <br /> Attachments: IMG 1695.JPG <br /> Hello Courtney, <br /> I reviewed the email from Peter Reich of the EPA and the SDS sheet in it as well. Per HSC 25270.2 (h): <br /> "Petroleum" means crude oil,or a fraction thereof,that is liquid at 60 degrees Fahrenheit temperature and 14.7 pounds per square <br /> inch absolute pressure. <br /> So if the cutback oil is not liquid at 60 degrees Fahrenheit then it is not subject to APSA. I need more information to <br /> show that this is the case. In Peter Reich's email under the Asphalt section it states: <br /> The SPCC rule applies to asphalt cement(AC), as well as to asphalt derivatives such as cutbacks and emulsions. Because of the <br /> operational conditions under which AC,cutbacks and emulsions are used and stored,they do pose a risk of being discharged into <br /> navigable waters or adjoining shorelines.Although AC) is semi-solid or solid at ambient temperature and pressure, it is generally <br /> stored at elevated temperatures. Hot AC is liquid—similar to other semi-solid oils, such as paraffin wax and heavy bunker fuels—and <br /> therefore is capable of flowing. Cutbacks and emulsions are liquid at ambient temperature,and because of their low viscosity,they <br /> may flow when discharged onto the ground.All of these oils are regulated under the SPCC rule to prevent discharges to navigable <br /> waters or adjoining shorelines. <br /> In addition,the SDS states that the physical state of Tricor Road Oil is liquid and does not provide a melting point. If you <br /> could provide a melting point or additional information that shows that the cutback oil is not a liquid at 60 degrees <br /> Fahrenheit. <br /> Best Regards, <br /> Lydia Baker <br /> Registered Environmental Health Specialist <br /> San Joaquin County <br /> Environmental Health Department <br /> 209-468-8257 <br /> (baker@sigov.org <br /> Please note my email address has changed to (baker@sigov.org <br /> From: Deporto, Courtney<Courtney.Deporto@gcinc.com> <br /> Sent:Tuesday, May 28, 2019 4:21 PM <br /> To: Baker, Lydia <Ibaker@sjgov.org> <br /> Cc: Ruvalcaba, Cesar<cruva Ica ba @sjgov.org> <br /> Subject: RE: Inspection Report <br /> 1 <br />