Laserfiche WebLink
4 uStar <br /> April 20,2020 <br /> Mr.John Schofield(schofield.john@epa.gov) <br /> Hazardous Waste and Chemical Section,ENF 2-2 <br /> Enforcement and Compliance Assurance Division <br /> U.S.Environmental Protection Agency <br /> 75 Hawthorne Street <br /> San Francisco,CA 94105 <br /> VIA EMAIL CORRESPONDENCE <br /> Subject: Response to Notice of Violation <br /> NuStar Terminals Operations Partnership L.P. <br /> 2941 Navy Drive <br /> Stockton,California <br /> Dear Mr. Schofield, <br /> NuStar Terminals Operations Partnership L.P. (NuStar)is herewith responding to the Notice of Violation correspondence dated April <br /> 2,2020,associated with the inspection of the subject facility on February 18, 2020,conducted by yourself and Mr.Garrett Backus of <br /> the San Joaquin County Environmental Health Department(SJCEHD). <br /> NuStar's response is as follows: The Final Inspection Report identified 5 containers of transmix generated on April 3,2018,and <br /> suggests that NuStar had accumulated them speculatively. NuStar shipped 10,704 pounds of transmix on April 4,2018(see attached <br /> Bill of Lading). If we utilize the following assumptions,it can be shown that 86 percent of that generated was shipped on April 4, <br /> 2018,and therefore,the material was not accumulated speculatively. <br /> Assumptions: <br /> ➢ 1 bbl=42 gallons <br /> ➢ Relative density=0.84 <br /> ➢ Weight of 1 gallon of water=8.34 lbs <br /> ➢ Therefore 1 gallon of transmix=7.01 lbs,and <br /> ➢ 1 bbl=294 lbs <br /> ➢ Volume of transmix onsite April 3,2019 =(5 X 294)+(10,704)lbs <br /> ➢ Total pounds of transmix onsite = 12,174 lbs <br /> ➢ Percentage of transmix shipped April 4,2020 =86 <br /> Note that the NAICS Code as listed on the report was 424710,this should be corrected to read 493190 as NuStar is not a Merchant <br /> Wholesaler;NuStar does not own products transferred to and from or stored at the Terminal. <br /> Given the current COVID-19 crisis,this correspondence will be transmitted electronically; if a hard copy is desired let me know and I <br /> will make the necessary arrangements. Do not hesitate to contact me should you have questions regarding this correspondence. <br /> Respectfully, <br /> Stephan Rosen <br /> Senior HSE Manager—West Region <br /> cc: Mr. Garrett Backus,REHS—SJCEHD via email(gbackus(&sigov.org) <br /> Attachment <br /> NuStar Terminals Operations Partnership L.P. <br /> 3505 Navy Dr • Stockton, CA 95206 • (209) 943-5662 <br />