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From: Presto, Carol [EHD] Sent: Monday, December 27, 20213:59 PM To: DPaul McWhorter<spccorp@hotmail.com>; Gary delCarlo <hfstracyca@msn.com> Subject: RE: SPCC plan/Title 22 proposal Good Afternoon Paul and Gary, Unless tanks have been 'permanently closed' in accordance with 40 CFR Part 112.2 requirements,the tanks must still be included in the facility SPCC Plan. 112.1(b)(3) states that any container that is used for standby storage,for seasonal storage, or for temporary storage, or not otherwise "permanently closed" as defined in 112.2 is still applicable under 40 CFR 112. I'm not a fire inspector so I don't have authority on Fire Codes, but here is a link to the South San Joaquin County Fire Authority contact page for questions on fire codes https://www.sicfire.org/about-us/contact Please submit your SPCC plan and if they cover the items noted in the inspection report dated 1/7/2019, 1 can close out those violations. Reminder that 2 of the open violations are not related to SPCC Plan revisions but rather one needs a copy of training records submitted to EHD and one is a photo showing the that the valved-faucet has been installed to full enclose the secondary containment enclosure on the 10,000-gallon tank. Please see my email from 11/9/2021 with a copy of the 1/7/2019 inspection report for reference. Thank you and I hope you had a nice holiday weekend All the Best, Carol Presto Environmental Health Specialist San Joaquin County Environmental Health Department Email: cpresto@sigov.org I Phone: (209) 616-3061 https://www.sigov.org/department/envhealth/ From: DPaul McWhorter<spccorp@hotmail.com> Sent: Wednesday, December 22, 202112:13 PM To: Gary delCarlo<hfstracyca@msn.com>; Presto, Carol [EHD] <cpresto@sil;ov.org> Subject: SPCC plan/Title 22 proposal CAUTION:This email is originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Gary/Carol: Good/Bad news: I have concluded there was a mis-communication between the client and SPC Corp which was probably our fault as follows (I probably should have rescheduled yesterday's onsite inspection until the pad was completed----as a result, I am proposing an "interim" SPCC plan/Title 22 Assessment: 1. Good news: Virtually every tank (both stationary and nurse-tank units) was tested using periodic integrity tank protocols and PASSED without exception. In addition, SPC Corp provided a third complimentary test to Haley---testing the steel-wall thickness for each unit at no add'I charge (I believe this legitimizes our evaluation beyond the floor-level requirement). However, three of the 2000 gal ASTs (AvGas, Gasoline, Diesel) have not been installed on their pad due to problems with the spec-Engr and the Construction Company who will eventually prepare/pour the pad in 2022. When the pad is complete, I will retest these three ASTs to insure that the movement of the tanks has not structurally damaged any of them (we/SPC Corp will not charge Haley for yesterday's test of three ASTs although 3