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N1M o n i e r L i f e t i l e- 9508 South Harlan Rd. tel: 209-982-1473 x8670 <br /> Changing the way people think about roofs. French Camp, CA 95231 fax: 209-982-5327 <br /> PO Box 6037 <br /> Stockton,CA 95206 <br /> January 7,2011 <br /> Hand Delivered <br /> San Joaquin County Environmental Health Department <br /> 600 East Main St. <br /> Stockton,CA 95202-3029 <br /> Subject: Inspection performed on December 10,2010 <br /> MonierLifetile LLC <br /> French Camp, CA <br /> Dear Ms. Tran, <br /> This letter and supporting documentation is in response to the Aboveground Petroleum Storage Act(APSA)Program inspection <br /> conducted at our facility in French Camp,CA on December 10,2010. <br /> Prior to the inspection,we had contracted a consulting firm to update our SPCC plan. Several of the findings are affected by the <br /> update of the plan. We have received a first draft of the revised plan from the consultant and have returned comments requesting <br /> some additional revisions. We believe that the finished plan will satisfy the current requirements for an SPCCP,including those <br /> updates listed in your inspection report. We are enclosing a copy of the SPCCP in its draft stage including revision notes. The PE that <br /> is certifying our plan is listed,but his seal will not be in place until the plan is finalized. <br /> To clearly outline our compliance,each finding is listed below with its corresponding corrective action. <br /> Aboveground Petroleum Storage Act(APSA)Program Inspection Report Findings and Corrective Actions <br /> #17 Failed to provide equivalent environmental protection and/or state the reasons for nonconformance and describe the <br /> alternate methods and how they achieve equivalent environmental protection. Overfill protection devices will be installed on <br /> each tank. Completion of the installation is expected in the first quarter of 2011. In the interim,procedures have been put in place to <br /> ensure equivalent protection. The procedures are outlined in the SPCC plan. <br /> #23 SPCC plan failed to address disposal methods for recovered materials. This procedure is address in the revised SPCC plan, <br /> a draft of which is enclosed. <br /> #24 SPCC plan failed to include required contact list and phone numbers of the facility's response coordinator,clean up <br /> contractors and agencies to notify in case of discharge. The contact list in the revised SPCC plan has been updated with confirmed <br /> telephone numbers. A draft of the revised SPCC plan is enclosed. <br /> #50 Failed to install and regularly test approved liquid level sensing devices,or provide equivalence as allowed by CFR <br /> 112.7(a)(2). Liquid level sensing devices will be installed as part of the overfill protection system for each tank. Installation of the <br /> devices is expected in the first quarter of 2011. The revised SPCC plan includes a testing schedule for the overfill protection systems. <br /> A copy of the quote and an email confirming the project start date are enclosed. A draft of the revised SPCC plan is enclosed. <br /> To the best of our knowledge,this addresses all of the findings associated with your inspection conducted on December 10,2010. <br /> Should you have any questions regarding our response,please contact Juan Espinoza at(209)456-0659 or Terri Evans at(949)981- <br /> 3319. <br /> Respectfully Yours, <br /> Monier ifetile LLC <br /> Juan E inoza <br /> Yard Manager/Environmental Coordinator <br /> French Camp,CA <br /> cc Mrs. Terri Evans,Rialto <br />