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From: Schofield,John <br /> To: Rosen,Stephan <br /> Cc: Backus,Garrett; Habets,Todd;Jackson,Jerome;Smith,Rav <br /> Subject: RE: Response to NOV--February 18,2020 Inspection/NuStar Energy,Stockton <br /> Date: Monday,April 20,2020 4:28:18 PM <br /> Mr. Rosen: <br /> Thank you for your response. EPA's comments concerning NuStar's response are as follows: <br /> • There were more than five 55-gallon containers of trans mix at the site at the time of the <br /> inspection. If you shipped the containers observed onsite after the inspection, please provide <br /> a copy of the shipping document(s). <br /> • According to NuStar's response, the site had 12,174 pounds of trans mix on January 1, 2019. <br /> At the end of 2019, the same number of containers were located on site. This mixture of <br /> trans mix was not managed as excluded recyclable materials in 2019. NuStar may have <br /> shipped off-site 86%of this trans mix in 2018. Again, none of the trans mix observed by EPA <br /> and San Joaquin County was managed as excluded recyclable material in 2019, therefore, <br /> NuStar was speculatively accumulating the trans mix waste observed by the EPA and San <br /> Joaquin County, Environmental Health Department inspectors. <br /> • The NAICS code listed in EPA's inspection report was obtained from the EPA Compliance <br /> History Online database. The NAICS information in the database was provided by NuStar. If <br /> the NAICS information is incorrect, NuStar should submit a revised EPA Form 8700-12 with <br /> the correct NAICS code(s). EPA recommends that the revised EPA form 8700-12 be <br /> submitted through the myRCRAid process: <br /> https:,//rcrainfo.epa.gov/rcrainfo/help/generalhelp/introduction__myrcraid.htm <br /> Please provide a copy to EPA and to Mr. Backus, a copy of the manifest document, as request in the <br /> first bullet above. <br /> If you have any questions concerning the above process, please contact me at your convenience. <br /> regards, <br /> John <br /> ************************************** <br /> John Schofield <br /> U. S. Environmental Protection Agency <br /> Region 9 <br /> Enforcement and Compliance Assurance Division <br /> Air, Waste and Analysis Branch, ENF-2-2 <br /> 75 Hawthorne Street <br /> San Francisco, CA 94105 <br /> (415) 972-3386 <br /> (415) 947-3530 (fax) <br /> schofield.john(fta.gov <br /> ************************************* <br /> NOTE: This email, including any attachments, may contain material that is confidential, privileged and/or <br />