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Summary Statemel it to accompany the Return to Compliance <br /> Statement <br /> APSA Inspection Report dated 2/11/2016 <br /> Facility Location: 23100 Kasson Rd, Tracy, CA <br /> 201 The Professional Engineer(PE)certification is incomplete <br /> • We have contracted with Condor Earth Technologies Inc. to update our Spill Prevention, Control, <br /> and Countermeasure Plan (Plan). We've reviewed the Information in draft form and expect a <br /> final plan by the end of March. We will immediately begin work on requirements and <br /> recommendations such that we can complete work to implement the plan within 6 months of <br /> receipt. <br /> 301 The current plan indicates that there is interstitial monitoring between the walls of the tanks <br /> • The Plan update addresses how the interstitial space will be monitored and the required <br /> frequency. Future Plan amendments will be completed when there is a change in the Facility <br /> design, construction, operation, or maintenance that materially affects its potential for a <br /> discharge, within 6 months of the change, and implemented as soon as possible, but not later <br /> than 6 months following the preparation of the amendment. Administrative changes such as <br /> personnel, cleanup contractors will be made by the Facility whereas technical changes such as <br /> oil quantity changes and equipment installation will be reviewed by a Professional Engineer. <br /> 601 The SPCC does not follow the proper order and no cross-reference is provided <br /> • The Plan update follows the prescribed order and also provides a cross reference matrix. <br /> 604 The facility diagram doesn't identify the locations of all product piping <br /> • The Plan update will indicate all product piping. <br /> 608 The current plan does not address the resulting spill from a major equipment failure <br /> • The Plan update will evaluate and address the resulting spill from a major equipment failure. <br /> 609 The reviewed plan does not adequately describe the secondary containment or diversionary <br /> structures to prevent discharge <br /> • The Plan update evaluates the secondary containment and diversionary structures to determine <br /> if appropriate containment and/or diversionary structures exist to prevent a discharge. Any <br /> recommended changes will be addressed immediately and completed within 6 months. <br />