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From: DPaul<spccorp@hotmail.com> <br /> Sent: Sunday,July 28,2019 6:38 PM <br /> To: Ruvalcaba,Cesar<cruvalcaba@sjgov.org> <br /> Subject: Haley's Flying Service <br /> Cesar: <br /> Please note our original PE from 2015 has retired; our new PE is not comfortable to issue a new SPCC plan in <br /> light of your regulatory guidance. He has recommended: <br /> 1. We enforce some of the provisions in 2015 (2ndary containment for 1000 gal AST, analysis of waste <br /> oil/waste coolant which was omitted, mobile refueler policy, etc.) <br /> 2. He would prefer to radically revise the existing SPCC plan and then compose/recertify in 2020. <br /> 3. This sounds reasonable to us in light of the fact that we re-tested ALL tanks and would include this in <br /> the current revision. <br /> Just wanted your input to this process so we can get this finalized ASAP. Thanks for your feedback. <br /> Paul <br /> SPC Corp <br /> 2 <br />