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SPCC regulations define a farm as follows"a facility on a tract of land devoted to the production of crops or raising of <br /> animals,including fish,which produced and sold,or normally would have produced and sold,$1,000 or more of <br /> agricultural products during a year" <br /> Let me know what you think,The facility is regulated under APSA, HMBP and Hazwaste. I don't know if HMBP has a <br /> separate definition for farms. <br /> —Original Message— <br /> From:Joseph Gigli<jgigli24@gmail.com> <br /> Sent:Wednesday,August 21,2019 11:01 AM <br /> To: Ruvalcaba,Cesar<cruvalcaba@sjgov.org> <br /> Subject: Re:Gigli's Lathrop(SPCC)-PR0527892 <br /> Sorry this took so long. I've been short 2 guys I'm filling in for and trying to keep up with all else. I hope this helps to <br /> understand what I do here. <br /> Thanks <br /> Joe <br /> On Tue,Aug 13,2019 at 2:00 PM Ruvalcaba,Cesar<cruvalcaba@sjgov.org>wrote: <br /> > Hi Joseph, <br /> >There are exemptions for farm facilities under California Regulations or Aboveground Petroleum Storage Act(APSA) <br /> and Spill Prevention,Control,&Countermeasure(SPCC)regulations(federal). I have attached a pamphlet from the <br /> federal perspective and the state perspective. <br /> > It all depends on what the qualifying petroleum product is used for. I was under the impression that the tanks were for <br /> the fueling and maintenance of trucks and squeezes and that the facility buys and sells hay and is not devoted to <br /> farming.The trucks and squeezes would not be part of an farm operation as defined in regulations.The facility falls <br /> under two other programs within our department and none classify the facility as a farm. <br /> >APSA regulations defer to the SPCC regulations for the definition of a <br /> >farm-"a facility on a tract of land devoted to the production of crops or raising of animals,including fish,which <br /> produced and sold,or normally would have produced and sold,$1,000 or more of agricultural products during a year." <br /> > If you feel the facility meets the definition of a farm,let me know why you feel that is. Provide a list of all activities that <br /> the facility performs,including those that may not fall under farming. Include a description of the full business activities <br /> of Gigli Hay. This will be discussed with management. <br /> > It is possible that even though the facility may be a farm,a RE certified SPCC plan may still be required under the <br /> federal regulations because the storage capacity exceeds 6,000 gallons. <br /> >Thank you, <br /> >Cesar Ruvalcaba <br /> >San Joaquin County Environmental Health Department Environmental <br /> 6 <br />