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April 26, 2010 <br /> Ameron Water Transmission Group <br /> 10100 W. Linne Road <br /> Tracy, CA 95377 <br /> Subject: Response to Aboveground Petroleum Storage Act(APSA) Inspection <br /> Conducted March 18,2010 by San Joaquin County Environmental Health <br /> Department <br /> Dear Mr. Williams: <br /> Below are responses to the APSA Inspection Report that the Ameron-Tracy facility received <br /> from the San Joaquin County Environmental Health Department (EHD) after their March 18, <br /> 2010 inspection. <br /> As a preface to the comments which follow, it should be noted that Hemphill, Green & <br /> Associates LLC (HGA) is completely overhauling the Spill Prevention, Control, and <br /> Countermeasures (SPCC) Plan for Ameron's Tracy facility. On June 19, 2009, EPA published <br /> in the Federal Register a SPCC compliance date extension for all facilities until November 10, <br /> 2010. Facilities must amend or prepare, and implement SPCC Plans by the compliance date in <br /> accordance with revisions to the SPCC rule promulgated since 2002. The revised SPCC plan <br /> will comply with the SPCC rule and all amendments. We anticipate completion of the revised <br /> plan by May 31, 2010. A copy of the revised SPCC plan will be presented to EHD upon its <br /> completion. <br /> #6. SPCC Plan Certification by a Professional Engineer(PE) is missing or incomplete <br /> The existing SPCC plan lacks PE certification. The revised SPCC plan mentioned <br /> above will contain the required California-licensed PE certification. The PE will also <br /> certify any amendments to the revised SPCC plan when technical amendments to the <br /> SPCC plan are made, such as changes in facility design, construction, operation, or <br /> maintenance which materially affects the facility's potential for discharge. <br /> #8. Failed to amend SPCC Plan within 6 months, or implement changes within 6 months of <br /> amendment when there is an applicable change to the facility <br /> The SPCC plan was not modified when Mr. Jack Soito, the previous Designated <br /> Emergency Coordinator, retired. The current Designated Emergency Coordinator is <br /> Mr. Rusty Williams. The Alternate Coordinator is Mr. Lynn Pindar. The revised SPCC <br /> plan mentioned above will include this information, and the existing SPCC plan page <br /> identifying the Designated Emergency Coordinator has been amended. <br />