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® M o n i e r L i f e t i l e° 9508 South Harlan Rd. tel: 209-982-1473 x8670 French Camp, CA 95231 fax: 209-982-5327 Changing the way people think aboutruufs. PO BOX 6037 Stockton, CA 95206 January 7, 2011 Hand Delivered San Joaquin County Environmental Health Department 600 East Main St. Stockton, CA 95202-3029 Subject: Inspection performed on December 10, 2010 MonierLifetile LLC Lathrop, CA Dear Ms. Tran, This letter and supporting documentation is in response to the Aboveground Petroleum Storage Act (APSA) Program inspection and Hazardous Waste Program inspection, conducted at our facility in Lathrop, CA on December 10, 2010. Prior to the inspection we had contracted a consulting firm to update our SPCC plan. Several of the findings are affected by the update of the plan. We have received a first draft of the revised plan from the consultant and have returned comments requesting some additional revisions. We believe that the finished plan will satisfy the current requirements for an SPCCP, including those updates listed in your inspection report. We are enclosing a copy of the SPCCP in its draft stage including revision notes. The PE that is certifying our plan is listed, but his seal will not be in place until the plan is finalized. To clearly outline our compliance, each finding is listed below with its corresponding corrective action. Hazardous Waste Pro rag m Inspection Report Findings and Corrective Actions #30 An empty HW or Haz Mat container (larger than 5 gallons) was not marked with the date it was emptied and/or not managed within one year of being emptied. The drum has been labeled as empty with the date it was emptied and is stored in our used oil storage area until such time that it will be disposed. See attached photo. #60 Failed to keep signed copy for 3 years. #63 Failed to keep a copy of the consolidated manifest for 3 years. All signed copies of manifests noted in the inspection as missing are on file. A copy of each signed manifest is enclosed. Aboveground Petroleum Storage Act (APSA) Program Inspection Report Findings and Corrective Actions #6 SPCC Plan certification by a Professional Engineer (PE) missing or incomplete. Our final updated SPCC plan that is currently in revision by a consultant will be certified by a professional engineer. #17 Failed to provide equivalent environmental protection and/or state the reasons for nonconformance and describe the alternate methods and how they achieve equivalent environmental protection. Overfill protection devices will be installed on each tank. Completion of the installation is expected in the first quarter of 2011. In the interim, procedures have been put in place to ensure equivalent protection. The procedures are outlined in the SPCC plan. #18 No facility diagram or diagram failed to show location and contents of each container, transfer stations and connecting pipes. The facility diagram has been updated to indicate the location and contents of each container. The updated diagram is enclosed. #23 SPCC plan failed to address disposal methods for recovered materials. This procedure is address in the revised SPCC plan, a draft of which is enclosed. #24 SPCC plan failed to include required contact list and phone numbers of the facility's response coordinator, clean up contractors and agencies to notify in case of discharge. The contact list in the revised SPCC plan has been updated with confirmed telephone numbers. A draft of the revised SPCC plan is enclosed. #31 Failed to conduct inspections and tests in accordance with written procedures and/or maintain signed records of inspections and tests as required by the facility's SPCC Plan on site for 3 years. The inspections were provided to the inspector during the site visit. Please note the inspector's handwritten note, "Corrected onsite provided copies for review."