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Home My WebLink AboutCERTIFIED MAIL RECEIPT (3)SENDER: COMPLETE THIS SECTION r r 'r r .r r, r' �zr � I- 0.ar wo1 yorMa "U 0. 1r� Opr� 4zr�~ m Mrir � rac G s r lac v t.1 Sol a' r 1 1 r• r r 1 COBi pLETE THIS SECTION ON DELIVERY U.S. Postal Service'rM CERTIFIED IMAIL7M RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) For delivery information visit our website at www.usps.come PS Form 3800, June 2002 See Reverse for Instructions E R S F I IML D F /IPE ARTM T Afto" RONALD J. FRAZE FIRE CHIEF Gary Hutton, Senior Deputy Chief Administration 326 -3650 Deputy Chief Dean Clason Operations/Training 326 -3652 Deputy Chief Kirk Blair Fire Safety/Prevention Services 326 -3653 2101 "H" Street Bakersfield, CA 93301 OFFICE: (661) 326 -3941 FAX: '(661) 852 -2170 May 9, 2006 Agent for Service of Process: Mr. Peter G. Gordon 55 Francisco Street, Suite 410 San Francisco, CA 94133 Certified Mail CRYSTAL GEYSER WATER COMPANY, INC., DOCKET NO.: 2005 -27 To whom it may concern: Enclosed, please find a revised Order on Consent Agreement and regulations covering requirements for the proper installation of a new tank system designed to contain hazardous wastes and prevent their unauthorized discharge into the sewer. Submission of the signed Order on Consent Agreement, a Registered Professional Engineer's assessment of the proposed new tank system, and payment of the revised penalty amount, are due within thirty (30) days from the date of the enclosed Order. If you have any questions regarding the enclosed Order and regulations, please call me at (661) 326-3979. RALPH E. HUEY, DIRECTOR PREVENTION SERVICES Sincerely, FIRE SAFETY SERVICES • ENVIRONMENTAL SERVICES 900 Truxtun Avenue, Suite 210 f'I' Bakersfield, CA 93301 OFFICE: (661) 326 -3979 FAX: (661) 852 -2171 David Weirather Fire Plans Examiner 326 -3706 Howard H. Wines, III Hazardous Materials Specialist 326 -3649 Ralph E. Huey Director of Prevention Services Enclosures cc: D. Secara, Crystal Geyser, Bakersfield W. Cheung, Wastewater Division J. Scanlan, City Attorney's Office "Sewing the eonununittj J&st Maw J han, a " California Code of Regulatiox. Page 1 of 6 Cail -foti nia Office of Most ;decent Updates Sear&l Help Adr,ninistrative cc the ,fig yw y�e� � g ,�^� �rr.,�+� r; Z Welcome t o t 3 �! e 'S.�" fi �i f ;1 ii 7 `� � '�.A r bar a :4 9.i l rr y. .,c ... �. �:. . California Code of Regulations 22 CA ADC § 66265.192 22 CCR s 66265.192 Cal. Admin. Code tit. 221 s 66265.192 BARCLAYS OFFICIAL CALIFORNIA CODE OF REGULATIONS TITLE 22. SOCIAL SECURITY DIVISION 4.5. ENVIRONMENTAL HEALTH STANDARDS FOR THE MANAGEMENT OF HAZARDOUS WASTE CHAPTER 15. INTERIM STATUS STANDARDS FOR OWNERS AND OPERATORS OF HAZARDOUS WASTE TRANSFER, TREATMENT, STORAGE, AND DISPOSAL FACILITIES ARTICLE 10. TANK SYSTEMS This database is current through 04/21/06, Register 2006, Flo. 16. s 66265.192. Design and Installation of New Tank Systems or Components. (a) Owners or operators of new tank systems or components shall ensure that the foundation, structural support, seams, connections, and pressure controls (if applicable) are adequately designed and that the tank system has sufficient structural strength, compatibility with the waste(s) to be transferred, stored or treated, and corrosion protection so that it will not collapse, rupture; or fail. The owner or operator shall obtain a written assessment reviewed and certified by an independent, qualified, professional engineer, registered in California in accordance with section 66270.11(d) attesting that the system has sufficient structural integrity, is acceptable for the transferring, storing and treating of hazardous waste, and that the tanks and containment system are suitably designed to achieve the requirements of this article. This assessment shall be obtained prior to placing the tank system in service, and shall be kept on file at the facility. This assessment shall also include, at a minimum, the following information: (1) design standard(s) according to which the tank(s) and ancillary equipment are or will be constructed; (2) hazardous characteristics of the waste(s) to be handled; (3) for new tank systems or components in which the external shell of a metal tank or any external metal component of the tank system is or will be in contact with the soil or with water, a determination by a corrosion expert of: (A) factors affecting the potential for corrosion, including but not limited to: 1. soil moisture content; 2. soil pH; 3. soil sulfides level; 4. soil resistivity; 5. structure to soil potential; 6. influence of nearby underground metal structures (e.g., piping); 7. stray electric current; and, S. existing corrosion - protection measures (e.g., coating, cathodic protection), and California Code of Regulation. Page 2 of 6 (B) the type and degree of external corrosion protection that are needed to ensure the integrity of the tank system during the use of the tank system or component, consisting of one or more of the following: 1. corrosion - resistant materials of construction such as special alloys or fiberglass- reinforced plastic; 2. corrosion - resistant coating (such as epoxy or fiberglass) with cathodic protection (e.g., impressed current or sacrificial anodes); and 3. electrical isolation devices such as insulating joints and flanges; (4) for underground tank system components that are likely to be affected by vehicular traffic, a determination of design or operational measures that will protect the tank system against potential damage; and (5) design considerations to ensure that: (A) tank foundations will maintain the load of a full tank; (B) tank systems will be anchored to prevent flotation or dislodgement where the tank system is placed in a saturated zone, or is located within a seismic fault zone; and (C) tank systems will withstand the effects of frost heave. (b) The owner or operator of a new tank system shall ensure that proper handling procedures are adhered to in order to prevent damage to the system during installation. Prior to covering, enclosing, or placing a new tank system or component in use, an independent, qualified installation inspector or an independent, qualified, professional engineer, registered in California, either of whom is trained and experienced in the proper installation of tank systems, shall inspect the system or component for the presence of any of the following items: (1) weld breaks; (2) punctures; (3) scrapes of protective coatings; (4) cracks; (5) corrosion; (6) other structural damage or inadequate construction or installation. All discrepancies shall be remedied before the tank system is covered, enclosed, or placed in use. (c) New tank systems or components and piping that are placed underground and that are backfilled shall be provided with a backfill material that is a noncorrosive, porous, homogeneous substance and that is carefully installed so that the backfill is placed completely around the tank and compacted to ensure that the tank and piping are fully and uniformly supported. (d) All new tanks and ancillary equipment shall be tested for tightness prior to being covered, enclosed or placed in use. If a tank system is found not to be tight, all repairs necessary to remedy the leak(s) in the system shall be performed prior to the tank system being covered, enclosed, or placed in use. (e) Ancillary equipment shall be supported and protected against physical damage and excessive stress due to settlement, vibration, expansion or contraction. (f) The owner or operator shall provide the type and degree of corrosion protection necessary, based on the information provided under subsection (a)(3) of this section, to ensure the integrity of the tank system during use of the tank system. The installation of a corrosion protection system that is field fabricated shall be supervised by an independent corrosion expert to ensure proper installation. (g) The owner or operator shall obtain and keep on file at the facility written statements by those persons required to certify the design of the tank system and supervise the installation of the tank system in California Code of Regulation_ Page 3 of 6 accordance with the requirements of subsections (b) through (f) of this section to attest that the tank system was properly designed and installed and that repairs, pursuant to subsection (b) and (d) of this section were performed. These written statements shall also include the certification statement as required in section 66270.11(d) of this division. (h)(1) Notwithstanding subsections (a) through (g) of this section, design and installation of new tank systems or components used to manage hazardous waste, and which meet the criteria specified in subsection (h)(2) of this section, are not subject to the requirements of subsections (h) through (m) of this section until January 24, 1998. The assessment specified in subsection (k) of this section shall be obtained prior to placing a new tank system in service and shall be kept on file at the facility. This assessment shall be reviewed and certified by an independent, qualified, professional engineer, registered in California, in accordance with section 66270.11(d), attesting that the tank system has sufficient structural integrity and is acceptable for the transferring, storing and treating of hazardous waste. The assessment shall be valid for a maximum period of five (5) years or the remaining service life of the tank system, as stated in the engineer's assessment, whichever is less. New tank systems that have been assessed pursuant to subsections (a) through (g) of this section prior to June 1, 1995 are not required to be reassessed pursuant to subsection (k) for a period of five years, from the date of the assessment or June 1, 2000, whichever is the earlier date. If changes have been made to the tank system or new components have been added to the tank system subsequent to an assessment conducted prior to June 1, 1995, the tank system shall be reassessed pursuant to subsection (k). (2) The provisions of subsection (h)(1) of this section apply only to: (A) onground or aboveground tank systems containing only non -RCRA hazardous waste generated onsite, and tank systems authorized under Permit -by -Rule pursuant to Chapter 45 of this division, Conditional Authorization pursuant to HSC 25200.3, and Conditional Exemption pursuant to HSC 25201.5, and (B) onground or aboveground tank systems containing RCRA hazardous waste generated onsite, if: 1. the owner or operator is a conditionally exempt small quantity generator as defined in 40 CFR section 261.5, or a small quantity generator of more than 100 kg but less than 1000 kg per month as defined in 40 CFR section 265.201, or 2. the owner or operator is not subject to regulation in 40 CFR part 265 pursuant to an exemption in 40 CFR section 265.1, but the owner or operator is subject to the standards of this article. (i) A generator or owner or operator authorized pursuant to Permit -by -Rule pursuant to Chapter 45 of this division, Conditional Authorization pursuant to HSC 25200:8, or Conditional Exemption pursuant to HSC 25201.5, operating a non -RCRA underground tank system of an underground tank system otherwise exempt from permitting requirements pursuant to the federal act, shall comply with the applicable standards of Title 23 of the California Code of Regulations relating to underground tank systems. (j) New, onground or aboveground non -RCRA tank systems or tank systems otherwise exempt from permitting requirements pursuant to the federal act, with secondary containment, whose design and installation have been approved by a local agency or agencies, may, at the discretion of the CUPA, be exempt from the engineering assessment specified in subsection (k) of this section, provided minimum criteria specified in subsections (j)(1) through (j)(3) of this section are met. If the CUPA determines to exempt a new tank system from the assessment required pursuant to this subsection, the exemption shall be for a period of not more than three (3) years from the date the exemption was granted. The tank system owner or operator shall submit documentation of local agency approval to the applicable CUPA for review and possible acceptance in lieu of the assessment specified in subsection (k) of this section. If there is no CUPA, or the CUPA requests that the Department make a determination, the documentation shall be submitted to the Department. (1) tank system must have secondary containment capable of containing 100 percent of the contents of the ,tank and ancillary piping volume; and (2) if the tank system is exposed to precipitation, the secondary containment system must have sufficient capacity, in addition to that required in subsection (j)(1) of this section, to contain run -on. and infiltration from a 25 -year, 24 -hour rainfall event; (3) tank system secondary containment shall be provided with a leak detection system that is designed and California Code of Regulation Page 4 of 6 operated so that it will detect either the failure of the primary and secondary containment structure or any release of hazardous waste or accumulated liquid in the secondary containment system within 24 hours, or at the earliest practicable time if the existing detection technology or site conditions will not allow detection of a release within 24 hours. (k) The tank system assessment shall include all of the following information: (1) tank configuration (i.e., horizontal, vertical), material of construction, and gross capacity (in gallons); (2) design standard(s), if available, according to which the tank and ancillary equipment were or will be constructed and all of the following information: (A) material of construction; (B) material thickness and the method used to determine the thickness; (C) description of tank system piping (material, diameter), (D) description of any internal and external pumps; and (E) sketch or drawing of tank including dimensions. (3) documented age of the tank system (if tank was previously used), if available, (otherwise, an estimate of the age); (4) description and evaluation of any leak detection equipment; (5) description and evaluation of any corrosion protection equipment, devices, or material; (6) description and evaluation of any spill prevention or overfill equipment; (7) description and evaluation of secondary containment for the tank system (secondary containment must meet minimum standards as specified in subsections 0)(1) through (j)(3) of this section) including applicable secondary containment for ancillary equipment as required in subsection 66265.193(f); (8) hazardous characteristics of the waste(s) that have been or will be handled; (9) prior to placing a new tank system or component in use, an independent, qualified installation inspector or an independent, qualified, professional engineer, registered in California, either of whom is trained and experienced in the proper installation of tank systems, shall inspect the system or component for the presence of any of the following items and document in writing the results of the inspection: (A) weld cracks or breaks; (B) scrapes of protective coatings; (C) corrosion; (D) any structural damage or inadequate construction or installation such as cracks, punctures, damaged fittings. All discrepancies shall be documented in the assessment and remedied before the tank system is placed in use. (10) all new tanks and ancillary equipment shall be tested for tightness prior to being placed in use. The results of the test(s) shall be documented in this assessment. Tank system integrity or leak test requirements must be in compliance with all local requirements. Prior to conducting a tank system integrity test or leak test, contact local agency staff for local requirements. (11) estimated remaining service life of the tank system based on findings of subsections (k)(1) through (k) (10). (1) The assessment specified in subsection (k) of this section is not required for the replacement of the following identical or functionally equivalent tank system parts or components: California Code of Regulation Page 5 of 6 (1) pumps (same type and capacity); (2) plumbing or piping components such as unions, elbows, tees and gaskets; (3) valves and check valves; (4) piping and valve hangers and supports; (m) Replacement of identical or functionally equivalent tank system parts or components not listed in subsection (1) of this section shall be approved by the CUPA prior to replacement or changeout. If the tank system part or component is determined to be identical or functionally equivalent by the CUPA, the assessment specified in subsection (k) of this section is not required. The owner or operator shall provide the CUPA, or the Department if there is no CUPA or the CUPA requests that the Department make a determination, with the following information in writing so that a determination can be made: (1) name, address, and EPA identification number of the fadlity; (2) date of planned replacement; (3) description part or component to be replaced; (4) description of the tank system and type of waste(s) handled; (5) description of how the part or component is identical or functionally equivalent to the part or component to be replaced. Note: Authority cited: Sections 25150 and 25159, Health and Safety Code. Reference: Sections 25159 and 25159.5, Health and Safety Code; 40 CFR Section 265.192. HISTORY 1. New section filed 5- 24 -91; operative 7 -1 -91 (Register 91, No. 22). 2. New subsections (h) (1) - (h) (2) (B) 2. filed 6 -19 -95 as an emergency; operative 6 -19 -95 (Register 95, No. 25). A Certificate of Compliance must be transmitted to OAL by 10 -17 -95 or emergency language will be repealed by operation of law on the following day. 3. New subsections (h) (1) - (h) (2) (B) 2. refiled 10 -16 -95 as an emergency; operative 10 -16 -95 (Register 95, No. 42) . A Certificate of Compliance must be transmitted to OAL by 2 -13 -96 or emergency language will be repealed by operation of law on the following day. 4. New subsections (h)(1)- (h)(1)(B)2. refiled 2 -16 -96 as an emergency; operative 2 -16 -96 (Register 96, No. 7) . A Certificate of Compliance must be transmitted to OAL by 6 -15 -96 or emergency language will be repealed by operation of law on the following day. 5. New subsections (h)(1)- (h)(1)(B)2. refiled 6 -17 -96 as an emergency; operative 6 -17 -96 (Register 96, No. 25) . A Certificate of Compliance must be transmitted to OAL by 10 -15 -96 or emergency language will be repealed by operation of law on the following day. 6. New subsections (h)(1)- (h)(2)(B)2. refiled 10 -15 -96 as an emergency; operative 10 -15 -96 (Register 96, No. 42) . A Certificate of Compliance must be transmitted to OAL by 2 -12 -97 or emergency language will be repealed by operation of law on the following day. 7. Editorial correction removing duplicative subsection (g) (Register 97, No. 7) . California Code of Regalator, Page 6 of 6 8. New subsections (h)(1)-(h)(2)(B)2. refiled 2-11-97 as an emergency, including amendment of Note; operative 2-11-97 (Register 97, No. 7). A Certificate of Compliance must be transmitted to OAL by 6-11-97 or emergency language will be repealed by operation of law on the following day. 9. Certificate of Compliance as to 2-11-97 order transmitted to OAL 6-10-97; disapproved by OAL and order of repeal as to 2-11-97 filed on 7-24-97 (Register 97, No. 30). 10. Certificate of Compliance as to 2-11-97 order, including amendment of section, resubmitted to OAL and approved on 7-24-97 (Register 97, No. 30). 11. Change without regulatory effect amending subsection (k)(10) filed 7-1-2004 pursuant to section 100, title 1, California Code of Regulations (Register 2004, No. 27). 22 CA ADC s 66265.192 END OF DOCUMENT (C) 2006 Thomson/West. No Claim to Orig. U.S. Govt. Works. Docs,In Sequence Table of Contents. This site is provided by West. -r"C>MSC:)N Oc 2006 West I Privacy I Accessibility WEST In the Matter of: STATE OF CALIFORNIA CITY OF BAKERSFIELD CERTIFIED UNIFIED PROGRAM AGENCY Docket No.: 2006-27 CRYSTAL GEYSER WATER COMPANY, INC. ORDER ON CONSENT A California corporation No. C0823855 AGREEMENT Respondent. Health and Safety Code Section 25187 INTRODUCTION 1. Parties. The Office of EnvironmOhtal Services for the City of Bakersfield Fire Department, a Certified Unified Program Agency (CUPA) authorized by the Secretary of the California Environmental Protection Agency (Cal/EPA) to administer and enforce the Hazardous Substance Control Act in the City of Bakersfield, issues this Order on Consent Agreement (Order) to Crystal Geyser Water Company, Inc., a California corporation. 1.2. Site. Respondent generated, handled, treated, stored, and/or disposed of hazardous waste at the following site(s), including, but not limited lo: 1233 East California Avenue in Bakersfield, California. 1.3 Generator. The Respondent generated the following hazardous wastes: Aqueous with a pH less than or equal to 2, a corrosive hazardous waste pursuant to title 22 of the California Code of Regulations (CCR), section 66261.22. 1.4 Jurisdiction. Section 25187 of the Health and Safety Code (HSC) authorizes the CUPA to order action necessary to correct violations and assess a penalty when the CUPA determines that any person has violated specified provisions of the Health and Safety Code or any permit, rule, regulation, standard, or requirement issued or adopted pursuant thereto. 1 DETERMINATION OF VIOLATIONS The CUPA hereby determines that Respondent violated: 2.1 The Hazardous Waste Control Law (Health & Safety Code section 25100, et seg.), to wit: section 25189.5 Disposal, treatment or storage at, or transportation to, facilities without permits or at unauthorized points. 2.2 On March 22, 2006, approximately 4672 gallons of industrial waste water with a pH less than or equal to 2 was discharged to the sanitary sewer in violation of the City of Bakersfield Publicly Owned Treatment Works (POTW) industrial wastewater discharge permit requirements and hazardous waste control laws. SCHEDULE FOR COMPLIANCE 3. Based on the forgoing DETERMINATION OF VIOLATIONS, IT IS HEREBY ORDERED THAT: 3.1 Respondent shall make all arrangements necessary to prevent the future discharge of any hazardous waste liquids into the POTW. 3.2 Submittals. A set of drawings stamped by a Registered Professional Engineer for installation of the proposed hazardous waste tank system designed in accordance with Title 22 of the California Code of Regulations, Section 66265.192 to prevent future hazardous waste releases shall be forwarded within thirty (30) days from the date of this Order to: Mr. Ralph Huey Director of Prevention Services City of Bakersfield 900 Truxtun Avenue, Suite 210 Bakersfield, California 93301 3.3 Communications. All approvals and decisions of the CUPA made regarding submittals and notifications will be communicated to Respondent in writing by the Director of Prevention Services or his/her designee. No informal advice, guidance, 2 suggestions, or comments by the CUPA regarding reports, plans, specifications, schedules, or any writings by the Respondent shall be construed to relieve Respondent of the obligation to obtain such formal approvals as may be required. 3.4 CUPA Review and Approval. If the CUPA determines that the schedule or other documents submitted for approval pursuant to this order fails to comply with the order or fails to protect. public health or safety or the environment, the CUPA may: a. Modify the document as deemed necessary and approve the document as modified, or b. Return the document to Respondent with recommended changes and a date by which Respondent with recommended changes and a date by which Respondent must submit to the CUPA a revised document incorporating the recommended changes. 3.5 Compliance with Applicable Laws. Respondent shall carry out this Order in compliance with all local, State, and federal requirements, including but not limited to requirements to obtain permits and to assure worker safety. 3.6 Endangerment during Implementation. In the event that the CUPA determines that any circumstances or activity (whether or not pursued in compliance with this Order) are creating an imminent or substantial endangerment to the health or welfare of people on the site or in the surrounding area or to the environment, the CUPA may order Respondent to stop further implementation of this Order for such period of time as needed to abate the endangerment. Any deadline in this Order directly affected by a Stop Work Order under this section shall be extended for the term of the Stop Work Order. 3.7 Liability. Nothing in this Order shall constitute or be construed as a satisfaction or release from liability for any conditions or claims arising as a result of past, current, or future operations of Respondent... other than those violations alleged in section 2 of this order. Notwithstanding compliance with the terms of this Order, 3 Respondent may be required to take further actions as are necessary to protect public health or welfare or the environment. 3.8 Data and Document Availability. Respondent shall permit the CUPA and its authorized representatives to inspect and copy all sampling, testing, monitoring, and other data generated by Respondent or on Respondent's behalf in any way pertaining to work undertaken pursuant to this Order. Respondent shall allow the CUPA and its authorized representatives to take duplicates of any samples collected by Respondent pursuant to this Order. Respondent shall maintain a central depository of the data, reports, and other documents prepared pursuant to this Order. All such data, reports, and other documents shall be preserved by Respondent for a minimum of three years after the conclusion of all activities under this Order. If the CUPA requests that some or all of these documents be preserved for a longer period of time, Respondent shall either comply with that request, deliver the documents to the CUPA, or permit the CUPA to copy the documents prior to destruction. 3.9 Government Liabilities. The City of Bakersfield shall not be liable for injuries or damages to persons or property resulting from acts or omissions by Respondent or related parties specified in paragraph 3.15 in carrying out activities pursuant to this Order, nor shall the City of Bakersfield be held as a party to any contract entered into by Respondent or its agents in carrying out activities pursuant to the Order. 3.10 Additional Enforcement Actions. By issuance of this Order, the CUPA does not waive the right to take further enforcement actions. 3.11 Incorporation of Plans and Reports. All plans, schedules, and reports that require CUPA approval and are submitted by respondent pursuant to this Order are incorporated in this Order upon approval by the CUPA. 3.12 Extension Request. If Respondent is unable to perform any activity or submit any document within the time required under this Order, the Respondent may, M prior to expiration of the time, request an extension of time in writing. The extension request shall include a justification for the delay. 3.13 Extension Approvals. If the CUPA determines that good cause exists for an extension, it will grant the request and specify in writing a new compliance schedule. 3.14 Penalties for Noncompliance. Failure to comply with the terms of this Order may also subject Respondent to costs, penalties, and/or punitive damages for any costs incurred by the CUPA or other government agencies as a result of such failure, as provided by HSC section 25188 and other applicable provisions of law. 3.15 Parties Bound. This Order shall apply to and be binding upon Respondent, and its officers, directors and agents, including but not limited to individuals, and upon the CUPA and any successor agency that may have responsibility for and jurisdiction over the subject matter of this order. PENAL 4. The CUPA assesses a penalty of $1,125. Payment of the total penalty of $1,125 is due within thirty (30) days from the effective date of the Order. Respondent's check shall be made payable to City of Bakersfield, Certified Unified Program Agency, and shall identify the Respondent and Docket Number, as shown in the heading of this case. Respondent shall deliver the penalty payment to: Ms. Susan Chichester Business Manager City of Bakersfield Fire Department 2101 H Street Bakersfield, California 93301 A photocopy of the check shall be sent to: Mr. Ralph Huey Director of Prevention Services City of Bakersfield 900 Truxtun Avenue, Suite 210 Bakersfield, California 93301 5 5. This Order is final and effective upon execution by the City and Respondent. 6. "Days" for purposes of this Order means calendar days. Date of Issuance: May 9, 2006. 1�7 Mr. Ralph Hue�� Director of Prevention Services City of Bakersfield Crystal Geyser Water Company, Inc. Typed or Printed Name of Respondent's Representative cc: Ms. Janice Scanlan Deputy City Attorney City Attorney's Office City of Bakersfield 1501 Truxtun Avenue Bakersfield, CA93301 0 J-' ' - C)46'* Date Date ACKNOWLEDGMENT OF RECEIPT Without admitting the violations, I acknowledge receipt of this Enforcement Order, Statement to Respondent, Certification of Compliance form, and two copies of the form entitled Notice of Defense. DATED: Signature Print Name and Title SACORRESPONDENCE HAZ\2006-041E N FORCE MENTORDER-CGi-.DOC rA