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RECEIVE <br /> BoReTeoch ON -��PL �ti T FtecYEVuipmo <br /> Boretech writes in response to the CUPA's two inspection reports dated March 28, 2017,the <br /> Hazardous Materials Program Inspection Report and the Small Quantity Hazardous Waste <br /> Generator Inspection Report. (See Exhibit L- Return to Compliance Certification Forms) <br /> Hazardous Materials Program Inspection Report—March 28, 2017 <br /> Alleged Violations Compliance <br /> 5 HSC Failure to submit <br /> 25506(a) complete hazardous Submitted September 30, 2016 <br /> material inventory <br /> Boretech retained consultant AMEC to upgrade its <br /> report for thoroughness (December—February <br /> 2017) <br /> (See Exhibit A- CERS Uploads September 2016, <br /> Exhibit Al —CERS 2017 Uploads, Exhibit A2 — <br /> CERS Uploads 2015 and 2016 and Exhibit B - <br /> Hazardous Material Inventory December 2016) <br /> Updated again onsite March 28, 2017 <br /> HSC Failure to submit Submitted September 2016 (See Exhibit A) <br /> 25505(a)(3) emergency response <br /> procedures An updated plan was prepared in December 2016 <br /> by the facilities consultants, was kept on site in a <br /> labeled training folder, but there was a glitch during <br /> uploading to CERS. It was the only upgraded <br /> document that was inadvertently not uploaded. <br /> See also Exhibits C and C 1 for updated uploads. <br /> 10 HSC Failure to submit Updated onsite March 28,2017 <br /> 25508.1(a)- revisions to business <br /> (f) plan within 30 days <br /> of substantial change <br /> in operations <br /> Alston&Bird LLP <br />