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Presto, Carol [EHD] From: DPaul McWhorter <spccorp@hotmail.com> Sent: Wednesday, December 22, 2021 12:13 PM To: Gary delCarlo; Presto, Carol [EHD] Subject: SPCC plan/Title 22 proposal CAUTION:This email is originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Gary/Carol: Good/Bad news: I have concluded there was a mis-communication between the client and SPC Corp which was probably our fault as follows (I probably should have rescheduled yesterday's onsite inspection until the pad was completed----as a result, I am proposing an "interim" SPCC plan/Title 22 Assessment: 1. Good news: Virtually every tank (both stationary and nurse-tank units) was tested using periodic integrity tank protocols and PASSED without exception. In addition, SPC Corp provided a third complimentary test to Haley---testing the steel-wall thickness for each unit at no add'I charge (I believe this legitimizes our evaluation beyond the floor-level requirement). However, three of the 2000 gal ASTs (AvGas, Gasoline, Diesel) have not been installed on their pad due to problems with the spec-Engr and the Construction Company who will eventually prepare/pour the pad in 2022. When the pad is complete, I will retest these three ASTs to insure that the movement of the tanks has not structurally damaged any of them (we/SPC Corp will not charge Haley for yesterday's test of three ASTs although we will document their pass-results in the interim spcc plan.......when we re-test them in the future, upon completion of the pad, we will charge Haley a discounted fee and include these tank-test certs in the final SPCC plan) ---this complies with both the Fire Code and Environmental requirements. 2. Good news: Based upon debriefing with Gary yesterday, I am going to waive the Title 22 Site Assessment fee ($1650) because although we/SPC Corp will issue a PE wet-stamped/certified Title 22 for separate documentation as well as include it in the spcc plan, the onsite gallonage does NOT meet required thresholds and will be found as ---as a result, I am not comfortable in charging Mr. delCarlo for this transaction. Moreover, Mr. delCarlo has still agreed to anchor the container as we are in a seismic zone---I believe these good-faith efforts deserve consideration. 3. Bad news: The chemical/spraying and fertilizer poly tanks were inspected and will be referenced in the spcc plan. No fee will be charged for this reference documentation. In addition, currently these units are empty and are only in use seasonally with crops. 4. Bad news: Petroleum nurse tanks were also empty and are only in use seasonally as in item #3--- therefore, we will include tank-testing certs with each nurse tank. Question: normally the Fire Code requires these types of tanks to be signed as "out of service......I believe this is misleading and since they are restricted to seasonal use AND Mr. delCarlo has them emptied on a daily basis as a safety- measure, SPC Corp will NOT charge Haley for documenting these as well. 5. Good/Bad news: I am proposing SPC Corp submit a "provisional" spcc plan to both Haley and San Joaquin-CuPA until the onsite construction of the pad is completed. Upon completion of the pad and installation of the 3 ASTs to their permanent location, SPC Corp will conduct the periodic integrity tests for the three ASTs (AvGas, gasoline, diesel) and a discounted-fee will be charged. The Title 22 Site Assessment will be processed, PE wet-stamped and certified as soon as Mr. delCarlo has anchored the system and provided us photographic proof of this measure. By having an "interim/provision" spcc plan (although not PE wet-stamped/certified), we will have some plan in place on the chance of any 1