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I. Nurse tanks (55 gals to 125 gals) service small equipment---blowers, weed-eaters, ATVs in the field <br /> seasonally for the crops onsite. I was in agreement with your interpretation, they must be included <br /> although the nurse-tank units (which also carry 2000-gallon poly-water tanks are exempt.) When not in <br /> use, they are drained and vacant and remain on the property and inaccessible to the public. I tested <br /> each and they passed the structural requirements for periodic integrity test AND it was my intent to <br /> include them in the spcc plan with appropriate per-unit gallonage being applied to the facility total. I <br /> am preparing "NOT IN SERVICE" placards for the seasonal periods when they are not being used. <br /> 2. 1 am providing a blank training roster which Gary can back-date with the separate files he has. This will <br /> be included in the final spcc plan. <br /> 3. Upon addressing the two additional violations, I will finalize the spcc plan once the construction of the <br /> pad for the three 2000-gallon ASTs (AvGas, gasoline, diesel) have been installed. <br /> 4. 1 am also processing a Title 22 Site Assessment for the waste oil container although it does not meet <br /> the gallonage threshold (below 55 gallons) and will, therefore, be classified exempt. This will be <br /> referenced in the spcc plan and included in aggregate gallonage although the Title 22 Site Assessment <br /> will be maintained in a separate binder. <br /> 5. There is no faucet on the secondary containment for the 1000-gallon gasoline AST. However, a port <br /> with a threaded-cap was installed so the rainwater accumulation can be effectively drained as <br /> required. The spcc plan will find this equivalent to a faucet. <br /> I think this addresses the recent inspection I conducted (which I now find was premature). When the three <br /> 2000-gallon ASTs are moved onto the concrete pad, I will conduct an additional periodic integrity test to <br /> insure they were not damaged in the move. Please confirm you are in approval of these preliminary steps----I <br /> recommend I issue a DRAFT spcc plan as an interim step because the property is bounded by navigable <br /> waterways on both the north and south perimeters. I would provide the DRAFT to both Gary and you as <br /> interim insurance all factors are being watched and maintained. Thank you. <br /> D. Paul McWhorter, CEO <br /> SPC Corp <br /> From: Presto, Carol [EHD] <cpresto@sigov.org> <br /> Sent:Tuesday, December 28, 20217:46 AM <br /> To: DPaul McWhorter<spccorp@hotmail.com> <br /> Subject: FW: SPCC plan/Title 22 proposal <br /> Hi Paul, <br /> Please see forwarded email below. Sorry to hear about the blizzard and computer crash! <br /> Do you know what the petroleum nurse tanks are used for and do they stay on the property? <br /> Thanks! <br /> All the Best, <br /> Carol Presto <br /> Environmental Health Specialist <br /> San Joaquin County Environmental Health Department <br /> Email: cpresto@sigov.org I Phone: (209) 616-3061 <br /> https://www.sigov.org/department/envhealth/ <br /> 2 <br />