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(2)A written commitment of man-power, equipment, and materials required to expeditiously control and <br /> remove any quantity of oil discharged that may be harmful. <br /> 3. If the DEF does not contain petroleum it is not required to be on secondary containment or in the SPCC plan. <br /> If you still have questions you can reach me by email or my cell number is (209)481-8484. <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: DPaul McWhorter<spccorp@hotmail.com> <br /> Sent: Wednesday,April 22, 2020 9:36 AM <br /> To: Baker, Lydia <Ibaker@sigov.org> <br /> Subject:A.L. Powell Trucking, Inc./Escalon, CA <br /> Ms. Baker: <br /> Please note I have submitted two voicemails this week to your address, seeking the following compliance <br /> guidance: <br /> 1. Status of prosecution of the aforementioned client for historical non-compliance* by your <br /> jurisdiction. I spoke directly with your Mr. Cesar Ruvalcaba yesterday regarding these matters and he <br /> transferred me to you. <br /> 2. 1 specifically need to clarify whether/not the 2ndary containment on the 12,000-gallon diesel tank can <br /> be grand-fathered into the spcc plan. I broached this topic on 12/15/2017 when I conducted the initial <br /> onsite inspection. I subsequently re-inspected the facility on 4/13/2020 and confirmed no upgrade of <br /> the 2ndary had been performed. <br /> 3. Inside the service bay, a 300-gallon DEF AST (poly within a caged assembly) is located without 2ndary <br /> containment. Please advise whether/not you require this to be situated on a 2ndary containment <br /> pallet so I can include this in the spcc plan guideline requirements. <br /> 4. Although this is irrelevant, we/SPC Corp were not paid our fees for inspection-services rendered in <br /> 2017 until AFTER we conducted our follow-up inspection (at no additional charge in order to bring this <br /> site into compliance with your jurisdiction) on 4/13/2020. <br /> 5. We were not informed by the client that Mr. Ruvalcaba had issued an NOV in 2018 until our debriefing <br /> on 4/13/2020 after the follow-up inspection. <br /> 6. We were sent a copy of your 4/1/2020 memo to Sandy Bomer, advising that you were forwarding this <br /> matter to the District Attorney for investigation/prosecution by a member of the Powell office staff. <br /> *In closing, we have been advising this client since 2010 of the need to make relatively-inexpensive <br /> corrections to their onsite storage of fuel and variously-related HazMats with federal, state and local (your <br /> jurisdiction) guidelines. We will require your guidance to insure that what we/SPC Corp are prescribing meets <br /> your approval. <br /> 3 <br />