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Cesar Ruvalcaba [EH] <br /> From: Christopher.Sherman@shell.com <br /> Sent: Wednesday,January 2, 2019 8:42 AM <br /> To: Cesar Ruvalcaba [EH] <br /> Subject: RE: APSA/SPCC - 25705 S. Patterson Pass Road Tracy, CA - <br /> Hello Sir, <br /> Tank 3TR2 does indeed meet the definition of a breakout tank and it's not utilized for storage. This tank is only used for <br /> surges in our oil pipeline system. The tank does not act as a storage tank at any time during the year. <br /> Regards, <br /> Christopher Sherman I Environmental Advisor <br /> Shell Pipeline Company LP 0 1 1801 Petrol Rd. I Bakersfield CA 93308 <br /> Office: (661) 391-2413 <br /> Mobile: (661) 204-5199 <br /> Email: christopher.sherman(�bshell.com <br /> From: Cesar Ruvalcaba [EH] <cruvalcaba@sjcehd.com> <br /> Sent: Friday, December 28, 2018 1:07 PM <br /> To: Sherman, Christopher SPLC-DPH <Christopher.Sherman@shell.com> <br /> Subject:APSA/SPCC-25705 S. Patterson Pass Road Tracy, CA- <br /> Mr. Sherman, <br /> I attempted to do an Aboveground Petroleum Storage Act(APSA)/Spill Prevention, Control, &Countermeasure (SPCC) <br /> inspection on 12/28/2018 at the facility located at <br /> 25705 S. Patterson Pass Road in Tracy, CA. In talking to the facility personnel and looking through the SPCC plan, it <br /> appears that the tank that would put the facility at over 10,000 gallons, and inspected by the county, may be a breakout <br /> tank. Per SPCC regulations a breakout tank is defined as follows: <br /> "...means a container used <br /> to relieve surges in an oil pipeline system <br /> or to receive and store oil transported <br /> by a pipeline for reinjection and <br /> continued transportation by pipeline." <br /> EPAA guideline documents state the following: <br /> "Although breakout tanks can be used to relieve surges in an oil pipeline system or to receive and store oil transported <br /> by a pipeline for reinjection and continued transportation by pipeline, they are sometimes used for bulk storage (i.e., <br /> non-transportation-related storage).Thus, breakout tanks may be regulated by EPA, DOT, or both depending on how the <br /> tank is used. Breakout tanks used solely to relieve surges in a pipeline, not used for any non-transportation-related <br /> activity(i.e., pipeline-in and pipeline-out configuration, and with no transfer to other equipment/mode of transportation <br /> such as a tank truck), are not subject to EPA jurisdiction. Bulk storage containers used to store oil while also serving as a <br /> breakout tank for a pipeline or other transportation-related purposes may be subject to both EPA and DOT <br /> jurisdiction..." <br /> i <br />