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Ruvalcaba, Cesar From: DPaul <spccorp@hotmaitcom> Sent: Sunday,August 25,2019 7:53 AM To: Ruvalcaba,Cesar Subject: Updates: a) Haley Flying Service and b) Maxim Crane Cesar: Leaving for Ely, NV to conduct major repairs on a 12,000-gallon ConVault AST tomorrow/8-26-19 returning late Thursday evening, 8-29-19. Will send you confirmations on Friday, 8/30/19 re the following: 1. Haley Flying Services---the DRAFT revision of the entire spcc plan which you itemized for compliance has been completed. We will be onsite with Mr.del Carlo on Friday, 8/30, to confirm Haley has completed all issues outlined in the revised plan. Inclusive in these matters are: a) replacement of 1000-gallon singlewall gasoline AST b) confirmation that 5 mobile tanks on truck-beds are water,not petroleum. c) confirmation that vacant 500 gallon AST has been labeled "out-of-service" d) confirmation that Mr. del Carlo has enrolled in mandated spcc training per US EPA as well as fed OSHA e) any other measures outlined in your NOV that need to be verified. f)SPC Corp will submit the DRAFT spcc plan to you for confirmation on 8/30 and schedule review with you via phone the following week. We do not wish to have our PE wet-stamp/certify until you are satisfied with the text(although he has reviewed each item). 2. Maxim Crane---my update here is NOT so encouraging. a) It appears the owner of the UST/AST is challenging OSFM regarding validity of this conclusion. We have independently contacted OSFM to reinforce your NOV that the tank-in-question is, in fact, a UST which is now prohibited under APSA to be utilized as an AST. The owner of the parcel leases this property to Maxim Crane who is helpless to proceed until this issue is resolved. b) We have communicated SPC Corp's intent to "de-certify"the earlier tank-test based on the findings under item a)to Maxim Crane. c) While Maxim Crane advise they have a 4000-gallon ConVault AST in "mint condition" in-house which they wish to transfer to the Stockton location from a north-Sacramento facility,they are unable to do so until the property owner agrees. d) all Maxim Crane parties have been advised 8/30 is the deadline for compliance. While I will be in Ely, NV thru Thursday,8/29,you are welcome to contact me via cell @ (209)969-0851. ttis our/SPC Corp expectation to resolve the preliminary compliance issues for each of these sites within your jurisdiction by 8/30 and we have communicated this deadline to each client. Thank you. D. Paul McWhorter, CEO SPC Corporation t