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Ameron <br /> April 26, 2010 <br /> Page 5 <br /> Liquid level sensing devices, or their equivalent as allowed by CFR 112.7(a)(2)will be <br /> installed on appropriate bulk storage containers. Ameron is currently investigating the <br /> most practical and economical method for the containers present on site. <br /> #52. Failed to promptly correct visible discharges and/or remove accumulations of oil in <br /> diked areas,or provide equivalence as allowed by CFR 112.7(a)(2) <br /> The Ameron-Tracy facility removed the oily rags and spillage around the valves, <br /> piping, and connections in front of the diesel tank. A facility walkthrough and <br /> inspection with the Designated Emergency Coordinator, Ameron's Group <br /> Manufacturing Engineer, One Stop Environmental, and HGA on April 7-8, 2010 <br /> identified areas of the facility where improved housekeeping is warranted. Suggestions <br /> for improving housekeeping are being implemented in chemical storage areas to <br /> facilitate discharge detection. <br /> We appreciate the opportunity to assist you in addressing the concerns raised during the March <br /> 18 inspection. We will be working collectively with you to address the concerns with which <br /> we've been tasked and to prepare a revised SPCC plan for the facility. Should you or <br /> representatives of Ameron or EHD have questions or concerns, please feel free to contact me at <br /> (951) 658-0114. <br /> Sincerely, <br /> Hemphill, Green&Associates LLC <br /> Jim Hutchison <br /> VP <br />