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4IL6Sttar.. <br /> April 24, 2020 <br /> Mr. John Schofield(schofield.john e,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 (REVISED) <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 <br /> Violation correspondence dated April 2, 2020, associated with the inspection of the subject <br /> facility on February 18, 2020, conducted by yourself and Mr. Garrett Backus of the San Joaquin <br /> County Environmental Health Department (SJCEHD). <br /> NuStar's response is as follows: The Final Inspection Report identified 5 containers of transmix <br /> generated on April 3, 2018, and suggests that NuStar had accumulated them speculatively. <br /> NuStar shipped 10,704 pounds of transmix on April 4, 2018 (see attached Bill of Lading). If we <br /> utilize the following assumptions, it can be shown that 86 percent of that generated was shipped <br /> on April 4, 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 History: <br /> • Volume of transmix onsite April 3, 204-9 2018 = (5 X 294) + (10,704 10,240) lbs <br /> • Total pounds of transmix onsite = 12,174 11,710 lbs <br /> • Percentage of transmix shipped April 4, 202-0 2018 =.86 87 <br /> NuStar Terminals Operations Partnership L.P. <br /> 3505 Navy Dr• Stockton, CA 95206 • (209) 943-5662 <br />