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plan to incorporate EPA regulation changes before the November 2011 EPA deadline. <br />Please find included in this package excerpts from the active SPCC plan demonstrating <br />that the site does have a PE certified and signed plan maintained on site. Additionally, <br />the site has located all "old" copies of the SPCC plan and has destroyed them to avoid <br />any future confusion in identifying the active SPCC plan. <br />Metal Grinding Fine Management: <br />The facility has implemented a metal grinding work process. All stationary grinders are <br />being equipped with a vacuum system intended to collect fine metal particles into a <br />dedicated location, please see attached picture. Site personnel have also been <br />instructed to utilize these retrofitted stationary grinders as a first preference. If other <br />portable grinders are to be used, the metal shavings are to be immediately cleaned up <br />and placed into the dedicated storage location. As disposal is needed, the metal <br />material will be screened and the (100 microns and less) metal fines will be managed <br />and disposed as hazardous waste, if analysis results prove the need to do so. <br />Activated Alumina Analysis: <br />Attached please find a copy of the analytical laboratory results for a sample of <br />activated alumina which was taken from the active Air Dryers on site. This represents <br />the worst case "used" material on site. This analytical analysis demonstrates that the <br />activated alumina of concern (used on instrument air service only) some of which was <br />observed to be present on the ground is not a hazardous waste. <br />Enclosed in this package please find the following attachments: <br />• Excerpts of APMC Stockton CoGen current SPCC plan PE certification and plant <br />management signature sheets <br />• Activated alumina laboratory analysis <br />• Pictures showing vacuum system installed on site grinders <br />• Completed and signed Return to Compliance Certification form <br />If you should have any questions or require additional information, please contact me <br />at (209) 983-0391 x 116 or S. Govert at (707) 748-7595 x 11. <br />Regards, <br />Glenn Sizemore <br />Plant Manager <br />APMC-Stockton CoGen <br />IPA <br />