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Mario: <br /> I apologize for the delayed-submittal which was promised while I was enroute to the office. Upon my arrival <br /> last evening,the office computer system has been externally-hacked and I am just now back in "recovery". I <br /> tried to send you the previous correspondence from SPCCorp-to-Cesar and that's how I learned that we/SPC <br /> Corp had been hacked. Here are the issues we need to provide to your Mgt/legal team for consideration: <br /> 1. The entire focus of the NOV is the conclusion by Stockton Fire Dept reported to San Joaquin-CUPA <br /> which the CUPA agreed finds Maxim Crane is currently operating a UST(underground storage tank) <br /> which was modified to an AST(aboveground storage tank) prior to 2016. Current federal regulations <br /> (40CFR112) and California(APSA) prohibit use of USTs-as-ASTs. <br /> 2. The existing spcc plan certified by your PE does not include"equivalency" methods for ongoing tank- <br /> testing beyond STI SP001. We have explained these concerns to the AHJ on your behalf but he insists <br /> your PE validate these test methods(in accordance with Chapter 7 of the Regional Inspectors Guide of <br /> US EPA as equivalent). I am prepared to advise Cesar that you are exploring this option. <br /> 3. Maxim Crane is no longer using the UST-as-AST in operations until these issues are resolved. <br /> 4. Maxim Crane is exploring the"replacement of the UST" with a valid-certified AST(by UL). <br /> If you allow me to communicate this to Cesar by 9/1/2019 (while you are reviewing with your internal TEAM), <br /> I believe this will prevent additional sanctions by San Joaquin-COPA until these matters are reconciled. I <br /> remain available to your TEAM via email OR my direct cell(209)969-0851 over the weekend----I do NOT <br /> believe SPC Corp has any liability in this matter but you have been an exemplary client and I will make the <br /> extra effort to get this resolved on your behalf. Difficult or unreasonable clients do not receive this <br /> support. Thanks. <br /> p.s. I will begin providing you copies of the previous correspondence between Cesar and SPC Corp now that I <br /> have our network up and running again. <br /> Paul <br /> SPC Corporation <br /> CONFlDENTIALITY NOTICE <br /> This a-mail,and the Information transmitted,along with any attachments,comains Information that Is,or may be,covered by electronic communication privacy <br /> laws,and Is also confidential,proprietary legally privileged anclor othervAse exempt from disclosure.This a-mail,and the Information transmitted,along with any <br /> attachments,Is Intended only for the person or entity to which it Is addressed.If you are net the Imported reepiernpiease he advised that any reviev,re- <br /> transmission,dissemination,copying,or any other use of,or taking of any action In reliance upon,this Information is strictly prohibited.If you receive this a-mail In <br /> error,please contact the sender Immediately by telephone(412-500-0200)or by return a-mail,and Immediately delete the material and any and all attachments <br /> thereto.Thank you In advance for your cooperation. <br /> hWY/ wmawmcrdnecam <br /> 2 <br />