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4. #32 CCR66265.192 failed to comply with new HW tank system assessment requirement. Former <br />tank system has been removed from the use and replaced with a system of 55 gallon barrels <br />placed on secondary containment pallets and moved inside a weather proof shed. <br />5. #44 CCR66265.51 failed to prepare a contingency plan. Tuff Boy has prepared an SPCC plan that <br />addresses contact phone numbers for all identified agencies. Tuff Boy has also prepared a <br />separate contingency plan for address containment of spills from three potential areas in the <br />facility. <br />6. #49 CCR66265.16 Personnel training records are incomplete — missing job title and description. <br />Tuff Boy conducted an employee training meeting with all shop personnel on 2/28/11. <br />Violation Response/Action Attachments to APSA inspection report: <br />#1 HSC25270.4.5(a) Failed to prepare a written SPCC plan. In response Tuff Boy's <br />compliance manager attended the San Joaquin County sponsored training class on <br />12/2/10. (Participation Certificate attached). An SPCC plan has now been written for this <br />site. <br />2. #2 DFR112.3(e) Copy of plan is on site. <br />On behalf of Tuff Boy Sales, Inc., I wish to thank you for your work on this and your patience in <br />providing extensions for compliance. <br />Please contact me with questions or concerns. <br />Sin erely, <br />r <br />Br erkins <br />