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PRODUCTS <br />Air Products Mfg. Corporation <br />1010 Zephyr Street <br />Stockton, CA 95206-4208 USA <br />Tel 209-983-0391 <br />Fax 209-983-1719 <br />30 June 2011 <br />Stacy Rivera <br />San Joaquin County <br />Environmental Health Department <br />600 East Main Street <br />Stockton, CA 95202-3029 <br />RECEIVED <br />it IL, 0 1 261111 <br />Subject: Response Letter Concerning Notice to Comply and Return to Compliance <br />Certification Received During the Environmental Health Department Inspection <br />on the 3`d of June 2011. <br />Ms. Rivera: <br />This letter is to comply with the Return to Compliance Certification instructions <br />requiring us to demonstrate that all identified violations have been corrected within 30 <br />days from the inspection date of 3 June 2011. The compliance issues identified during <br />the June 3`d inspection are summarized below: <br />1) A current certified copy of the SPCC plan must be maintained on site at all times <br />2) Management of metal fines generated from metal grinding, cutting and drilling <br />are not being sufficiently characterized prior to disposal <br />3) Aluminum oxide from the site air dryer was observed on the ground, site could <br />not provide analytical analysis that demonstrates this material is not hazardous <br />waste. <br />Below please find a written summary of the corrective actions taken at the APMC <br />Stockton CoGen Facility addressing the above noted deficiencies <br />SPCC Plan Issue: <br />On the date of the above noted inspection, the site Environmental Engineer was not <br />present. The finding that the facility does not maintain on site a certified SPCC plan <br />was observed in error. The Site Environmental Engineer had the sites active PE <br />certified copy of the SPCC plan in his office. He is in the process of updating the SPCC <br />