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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 discharge from one of the containers----note: there are navigable waterways on both the north and south boundaries of the facility. I believe this is a reasonable interim measure to create an audit-trail for this. No additional fee will be charged upon completion and referral to the PE for final wet- stamp/certification. 6. Gary has authorized immediate spcc plan training and a CD module was left at the facility to insure these measures are followed. Carol---in closing, Haley is a responsible client who has never demonstrated a safety short-cut to onsite fuel/hazmat storage. As a result, for the first time in 30 years, I am submitting this proposal to create an audit-trail for a measure we can all agree is reasonable, takes no shortcuts in safety/security and which we are all committed to finalizing. Part of the reason for this interim proposal is a series of NOVs issued by your predecessors and ultimately reviewed by Ms. Janice Witul of Region IX US EPA---creating this electronic file will serve as a marker for completion of the project. Thank you for your consideration in this matter. D. Paul McWhorter, CEO SPC Corporation 4