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Baker, Lydia <br /> From: Salli-Anne Newhard <sanewhard@riponusd.net> <br /> Sent: Monday, April 13, 2020 9:40 AM <br /> To: Baker, Lydia <br /> Subject: RE: Documents for Above Ground Petroleum Storage <br /> Attachments: SPCC2020opt.pdf <br /> Hi Lydia, <br /> I am sorry I didn't reply sooner. I thought I had from my phone, but apparently it never sent.We were out of the office <br /> last week and my mind is not operating properly with all this upheaval of"normal routine".Attached is our SPCC plan. I <br /> am going to forward your email to Gary so that he can address your concerns on that. <br /> "Please note that my email has changed to sanewhard(arinonusd.net <br /> T adjoaa, <br /> YaImlaae <br /> From: Baker, Lydia <Ibaker@sigov.org> <br /> Sent: Monday,April 6, 2020 11:04 AM <br /> To: Salli-Anne Newhard <sanewhard@riponusd.net> <br /> Subject: RE: Documents for Above Ground Petroleum Storage <br /> Hello Salli-Anne, <br /> I reviewed what you sent over and closed out two of the open violations. For the other four open violations I need to <br /> see a copy of the SPCC plan. <br /> Just a note on the formal external inspection done by Gary Reeves. His reports have been looked over by the Steel Tank <br /> Institute and they do not appear to satisfy the requirements for an SP001 external inspection as described in Section 6 <br /> and 7 of the SP-001 standard. Several important elements appear to be missing from the reports. For your facility this <br /> would be a deviation from the SP001 standard which would need to be discussed in the SPCC plan. If an owner or <br /> operator deviates from applicable industry standards to develop an integrity testing program,then a PE must certify an <br /> environmentally equivalent alternative in the SPCC Plan.The Plan must provide the reason for the deviation, describe <br /> the alternative approach, and explain how it achieves environmental protection equivalent to the applicable industry <br /> standard. <br /> If you have any questions or need assistance please let me know. <br /> Best Regards, <br /> Lydia Baker <br /> Registered Environmental Health Specialist <br /> San Joaquin County <br /> Environmental Health Department <br /> 209-468-8257 <br /> Ibaker@sjgov.org <br /> i <br />