.. ~ Department of Toxic Substances Control Linda S. Adams SecretaI)' for Environmental Protection Maureen F. Gorsen, Director 1011 North Grandview Avenue ·Glendale, California 91201 Arnold Schwarzenegger Governor CERTIFIED MAIL August 31,2007 Mr. Jose Arias Exide Technologies, Inc. 2700 South Indiana Street Los Angeles, California 90023 Dear Mr. Arias: On June 29, 2007 and July 3,5 and 10,2007, the Califomia Environmental Protection Agency, Department of Toxic Substances Control (DTSC), conducted a Comprehensive Evaluation Inspection (CEI) of Exide Technologies, Inc. located 2700 South Indiana Street, Los Angeles, California 90023. The enclosed report describes the findings of this inspection, including all violations and any actions that should be taken by the facility to correct the violations. You are required by section 25185(c)(3) of the Health and Safety Code to submit a written response to the Department within 30 days describing the corrective actions that you have taken or propose to take to bring your facility into compliance. If you dispute the violations, you should explain your disagreement in this written response. All pertinent information derived from the inspection, including documents, and photographs are included as attachments to the report. This report will become a public document; you may request that any trade secret or facility security information be withheld from public dLs_doBW"8 .. If you wish to assert trade secret privilege after you have reviewed the report, please provide specific answers to each of the following questions for each item: • • • To what extent is there knowledge of the information conveyed by the photograph/document, outside of your business? To what extent is there knowledge of the information conveyed photograph/document, by employees and others in your business? To what extent have measures been taken to guard the secrecy of the information? . @ Printed on Recycled Paper Mr. Jose Arias August 31, 2007 Page 2 • • • Is the information valuable to competitors? If so, why? Has there been sUbstantial monetary expenditure in the development of the information? Could the information be easily and properly acquired or duplicated by the others? DTSC will review your response to these questions to determine if the information should be treated as trade secret and will notify you of its decision. If you have any questions regarding this letter, or if you wish to meet with the Department to discuss any questions or concerns you have with the inspection, the report, the violations, or the proposed corrective action, please contact me at (818) 5512908 or Ruth Williams-Morehead at (818) 551-2916. Sincerely, '. MukufAgarwal Supervising Senior Hazardous Substances Scientist Enforcement and Emergency Response Program Glendale Office Enclosures Certified Mail No. 7006 2150 0004 3420 7243 Return Receipt Requested State of California - California Environmental Protection Agency Departrnent of Toxic Substances Control INSPECTION REPORT I. GENERAL INFORMATION: Company Name: Exide Technologies, Inc. Facility Address: 2700 South Indiana Avenue Los Angeles, California 90023 Telephone Number: (213) 262-1101 ext. 259 EPA ID Number: CAD097854541 Registration Number: 2157 Facility Type: RCRA Haz8l"dous Waste Treatment Facility Regulated Units: The facility is currently operating under an ISD for their stOlID water retention pond, two lead smelting furnaces, their waste water treatment lmit and six spent lead-acid battery and lead waste storage areas. Waste Streams: Polypropylene waste, furnace slag, rubber and plastic casing material, wastewater, filter cake sludge, lead contaminated wipes and rags, etc. Inspected by: Ruth Williams-Morehead, HSS - June 29,2007 and July 3, 5, and 10, 2007 Tina Roberson-Holefield, HSS _. June 29, 2007 and July 10,2007 Dates ofInspection: June 29, 2007, July 3,5 and 10, 2007 Type oflnspection: CEI XX CME. O&M. Focused Limited. Transporter Facility Representatives: Jose Arias, Envirol11l1ental Health and Safety Manager Carlos Pena, Plant Manager Rafael Perez, Plant Superintendent Jack London,Manager Inspection Report Exide Technologies, Inc. Page 2 Type of Business: II. Exide Technologies, Inc. is a secondary lead smelter that recovers lead primarily from lead acid batteries. The recycled lead is sold and reused in manufacturing new batteries. CONSENT: Consent to conduct an inspection that involves: talcing photographs, reviewing and copying records, questioning persoIDlel and inspecting hazardous waste handling areas. Consent given by: III. Jose Arias, Environmental Health and Safety Manager DOCUMENTS REVIEWED: a. Manifests, Bills of Lading, LDR's, Exception Reports: No violations were observed during the manifest review. b. Contingency Plan: The facility has an adequate contingency plan, and no violations were observed. c. Training Plan and Records: The facility has an adequate training plan and training records, and no violations were observed. d. Incident Report: None reported. e. Waste Analysis Plan and Records: The facility has an adequate waste analysis plan, and no violations were observed. f. Operating Log: The facility has an adequate operating log, and no violations were observed. g. Inspection Records: The facility has adequate inspection records, and no violations were observed. Inspection Report Exide Teclmologies, Inc. Page 3 h. Tiered Permitting Applications and Authorization Letters: N/A I. AnnuaIlBiennial Reports: j. The facility submitted the annual report for 2006, and no violations were observed. SB 14 Plans: N/A k. Closure Cost Estimates and Updates: The financial responsibility review fOUlld that the facility has adequate closnre and post-closnre cost. I. Part A: An application was filed in 1981 by Gould, Inc. fornler owner of GNB. Exide pnrchased GNB in 2000, but the facility has never been issued a Hazardous Waste Facility Permit. Exide is currently operating Ullder an Interim Status Document. m. Part B: Part B application is lUlder review by the Southern California Pernlitting and Corrective Action Division. n. POTW Compliance Data: The facility has a pennit to discharge treated wastewater into the Los Angeles COUllty Sanitation District. o. Tank and/or Containment Certifications: The facility has adequate tanlc certifications, 3l1d no violations were observed. p. . Air Board Permits: The Air Board Permits are current. q. Variances: Not currently operating under a vari3l1ce. r. Recycling Records: N/A Inspection Report Exide Technologies, Inc. Page 4 s. Other: N/A IV. NARRATIVE OF OBSERVATIONSIDISCUSSION WITH OPERATOR: On June 29, 2007, I, Ruth Williams-Morehead and Tina Roberson-Holefield began the annual Comprehensive Evaluation Inspection of Exide Teclmologies located at 2700 South Indiana Street, Los Angeles, California 90023. I met with Mr. Jose Arias, the new Enviromnental Health and Safety Manger. Mr. Arias succeeds Ms. Diane Kelmedy in this position and is directly responsible for the management of hazardous waste at the facility. I told Mr. Arias that the purpose of my inspection was to evaluate the facility's compliance with hazardous waste management laws and regulations. We also met with Mr. Jack London, Manger, and he assist Mr. Arias with the hazardous waste management activities at the facility. I told Mr. Arias that I wanted to begin my inspection with a walk-through of the facility to evaluate the hazardous waste management units. Mr. Arias granted us permission to begin the inspection' and we visited the following hazardous waste management units: Trailer Staging Area: This area is used to st'age incoming and outgoing trailers that contain hazardous waste. Incoming waste is usually recycled at the facility and outgoing waste is shipped off-site for disposal. During the walk-through, there were five trailers (attachment 1; photos 13) staged in this area. Four cOl1tained hazardous waste plastic that was generated from Exide's smelting operation. The plastic will be sent off-site as hazardous waste to KW Plastics in Bakersfield for recycling. The remaining trailer contained used batteries that were received from off-site and will be recycled at the facility. Each trailer was marked with a label that the contained the appropriate infOlmation. The trailers were stbred closed and I did not observe any leaks or spill coming from the trailers. Waste Water Treatment Plant: The waste water treatment plant treats hazardous waste effluent generated from the smelting operation and wash down fi'om the facility. The treated effluent is discharged in the sanitation district. The waste water treatment plant is comprised of several tanks that are surrounded by secondary contai1l1l1ent. Each tank is marked with a NFP A placard to identify the type of waste stream illat is stored or treated in the tank. During the walk-through, we noticed that a feed line to one of the puinps and a clarifier were leaking (attachment 1; photos 4&5, 8-10). We observed a caustic like material on Inspection Report Exide Technologies, Inc. Page 5 top of the footings of the east and west equalization tanks (attachment 1; photos 6&7). We also observed that the footings on the east and west equalization tanks were cracked aod corroding (attachment 1; photos 11-20). The coating surrounding the drain (attachment 1; photo 21) which is adjacent to the acid tank aod the footing of the acid tank (attachment 1; photos 22-26) were also cracked and corroded. However, the tanks appeared to be intact aod I did not notice aoy leaks or spill coming from aoy of the tanks. I shared my observations with Mr. Arias and told him that I was concerned about the condition of the coating and the footings that support the equalization aod acid tanks. I also asked him what is the caustic material I observed on top of the footings on the east and west equalization tanks. Mr. Arias stated that he did not know if the matelial was caustic, but stated that he would begin to repair the footings 81ld cracks in the coating as soon as possible. Storm Water Retention Pond: The Stornl Water Retention Pond (attachment 1; photos 27-30) is used to collect rainfall and water generated from washing down the facility. During the walk-tln'ough the retention pond was almost empty of water. There was sludge in the bottom of tile pond aod Mr. Arias stated that the sludge contains about fifty percent lead. Mr. Arias stated that when the pond is empty, the sludge will be removed aod processed in one of the furnaces to recover the lead. Battery Storage Area - Bins 103-108: There were pallets of batteries stored in bin 103 (attachment 1; photo 35) 811d drums of batteries stored in bin 108 (attachment 1; photos 31&32). Bins 104 (attachment 1; photo 34), 105 (attachment 1; photo 33), 106 aod 107 were empty. The drums were marked with a label that contained the date the batteries were placed inside of the drum, and each drum was covered with a lid. Each pallet of battelies was marked with a label that contained the date of its receipt at the facility. DlUing the walk-through I observed that the batteries were intact and I did not observe 81ly leaks or spills. West Yard: The facility is prohibited from stoling hazardous waste on the west yard. DlUing the walk-through I observed that there were approximately 30 empty trailers p81'ked on the west yard. The facility also uses the west yard to store equipment. We concluded the walk-through of tile hazardous waste maoagement lU1its; aod I asked Mr. Arias if he would take us to see the soda ash storage t81lk. I told him that prior to this inspection, I had investigated a complaint alleging that Exide had been releasing soda ash into the air. Inspection Report Exide Technologies, Inc. Page 6 I observed that the soda ash storage tank is located inside of an enclosnre (attachment 1; .photos 36-38). The enclosnre is eqnipped with an air pollution control device (device). Mr. London stated that one end of a vent was placed into the device and the other end of the vent was placed inside of a filter (attachment 1; photo 39). He stated that the filter is examined periodically to deternline if any soda has escaped from the device. Soda ash from the storage tank is pumped directly into an enclosed conveyer belt (attachment 1; photo 40). The conveyer belt takes the soda ash directly into the mud tanks. I did not observe any soda ash on the ground adjacent to the tank or the enclosnre, nor did I observe soda ash escaping from the tank or its air pollution control device. At this time we concluded the inspection for the day, and I retumed to tlle facility on July 3, 2007 to resume the inspection. On July 3 and 5, :2007, I returned to the facility to conduct the record review. I received pe=ission for M1'. Arias to continue the inspection. During the record review I did not find any violations. On July 10, 2007, I and Tina Roberson-Holetleld returned to the facility. M1'. Arias gave us pernlission to continue the inspection. We conducted a second walk-furongh of the facility because Mr. Arias info=ed us that repairs had been made on the feed line, and on the coating covering the floor of tl1e waste water treatment plant. During the walk-through of the waste water treatment, we noticed that some repairs had been made (attachment2; photosl-11). The water feed line that was broken on June 29, 2007 has been repaired (photos 1&2). The coating tllat was cracked and corroded surrounding the drain on June 29, 2007 was being repaired (photos 3&4), but the concrete footings on the east and west equalization mid acid tanles remained cracked mId corroded (photos 5-11) After the walk-through we all met with M1'. Carlos Pena and M1'. Rafael Perez to have the e x i t i n t e r v i e w ; - - .- - - V. SUMMARY OF VIOLATIONS: 1. California Code of Regulations, section 66265.193(e) (1) (C) Exide violated California Code of Regulations, section 66265.193 (e) (1) (C), in that on or about June 29, 2007, the facility did not maintain the secondary containment for tlleir waste water treatment plant free of cracks and gaps. Also tlle concrete footings that support tlle east and west equalization and acid tanks, and the coating on top of an area surrounding a drain was cracked and corroded. Inspection Report Exide Technologies, Inc. Page 7 Corrective Action: Within 30 days the facility shall ascertain if the integrity of the secondary containment was breeched due to the cracks and gaps in the floor of the secondary containment, and perfo= the necessary repairs. VI. EXIT INTERVIEW INSPECTION REPORT: I met with l\1r. Arias, l\1r. Perez and Mr. Pena during the exit interview. I explained to them that dnring the inspection I found one violation regarding the condition of the coating covering the floor of the waste water treatment plant and the condition of the footings supporting the east and west .neutralization and acid till1kS. I told them that they should find out ifthe integrity ofthe secondary' containment remained intact and that they should repair the cracks and corrosion as soon as possible. I issued them the Summary of Violations (attachment 3) ill1d concluded the inspection at this time. On August 29, 2007, I received two e-mails from Jose Arias. Attached to each e-mail were five photos (attachment4; 10 photos) of the waste water treatment plant that showed that the repairs to the feed line, the area surrol1l1ding the drain and the footing on the east and west equalization and acid till1ks had been repaired. VII. ATTACHMENTS: L Photos, June 29,2007 (l-40) 2. Photos, July 10, 2007 (1-11) 3. Sl1l11mary of Violations 4. Photos sent bye-mail from Jose Arias showing repairs at the waste water treatment plant. -?/~!/o7 Date State of Cali·fornia - California Environmental Protection Agency --- Department of Toxic:; Substances Control J ---~------------------------------- SUMMARY OF VIOLATIONS On --'I4'.Q.L~4.;,lp.2,.1',::/-=---' the Department of Toxic Substances Control (DTSC), e tal Protection Agency, conducted an inspection at: Facility Name: Facility Address: 27 0D S:-, '1}J(iirm «..:: ri/Lt-el t e,4Q 017 EPAIDNumber: County Name: i?~f 5'-1'/ fAys. ./lvt0~.J, As a result of that inspection, the violations of hazardous waste laws, regulations, and requirements listed on the attached pages were discovered. All violations must be corrected; the actions you must take to correct the violations are listed with each violation. If you disagree with any of the violations or proposed corrective actions listed in this Summary of Violations, you should inform OTSC. If you disagree with any of the violations listed in Section I, you must give the inspector who issued the Notice to Comply a written notice of disagreement. You must correct the violations listed in Section III: Minor Violations, within ,~() days. Within five working days of achieving compliance, you must sign the statement certifying compliance at the bottom of Section III and return it to OTSC at the address provided. A false statement that compliance has been achieved is a violation of the law and punishable by a fine of not less than $2,000 or more than $25,000 for each violation. OTSC may reinspect this facility at any time. OTSC will provide you a complete inspection report within 65 days of the date of this inspection. You may request a meeting with OTSC to discuss the inspection or the findings of the report. The issuance of this Summary of Violations does not preclude DTSC from taking administrative, civil, or criminal action as a result of the violations --t:loted in theS u mmary-of-Violatiot:lsor-thathave-t:lot-Qee t:lcorrected-with iii-the-Ii me- -- provided in the Notice to comply. Company Representative Accepting Summary Department Representative Name~ II· fA),/lV'{I1(-Iiov.eI7ed'Title DTSC f /-/- 4J !IlkII' tJ,Fe V TitletkS. Signature r~ I- Signature Date J-/(J,-- 0 I Date -(7/05) --------- ~IJ (J/)tl;:)1&v/u£ ,kD!D'? I I Page ~ol=---:. state of .0alifornia - California Environmental Protection Agency Department of Toxic Substances Control SUMMARY OF VIOLATIONS SECTION II: CLASS II VIOLATIONS AND REQUIRED CORRECTIVE ACTION (Class II Violations not considered Minor Violations) You must correct the following violation(s) within & days. Within five working days of achieving compliance, you are required to sign the certification below, and return it to DTSC at the following address: _ _ _ _ _ _ _- - - - - - -_ _ __ I certify under penalty of law that the corrective actions listed in SECTION II of this document have been taken and the violations have been corrected. I am aware that there are significant penalties for submitting false information. Signature DTSC (7105) ~ L,-_________ Date 1-1()·o2 Page_of_ Exide June 29, 2007 : ' .i :1 ., ' . I " - @',," :,,,,Vij Trailer that contains hazardous waste plastic that will be shipped to KW Plastics for disposal. 1 A-I ~ 00. -lJCD ..., ,..... 0) en ::::l"" !:to) ,..... en (") (") O'g .0..., or_. _. ::::l '- ~ en o ::::l"" en m 0) - . 0) C :::J o CD N a.. c en 1\.)>< _. ~ se- CD "0 0) se_. (") ,..... ::::l"" a ::!E. 0"- CD en _. ::::l"" "0 "0 ~ ,..... o m .. , , . .. . , < ..CD -. c.. CD CD I\.) o o -...J C1 () o ::J Q) :::!. ~ :J. Q) ::J" (1) :3 ..., (1) Ci5" ::J c.... 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CD Q.. en CD (") o :::J Q.. ru -< ..... a o o "'""'-J Exide June 29 "1312' C'On?f?te footings on 'the?a?t 'a'nd'WE'St 6 found cracked and corroding. qualiza?ibn tanks were 11 Exide June 29, 2007 The concrete footings on t~e east and west equalizqtion tanks were found cracked and corroding. 12 Exide June 29. 2007 The concrete footings on the east and west equalizafion tanks were . found cracked and corroding. 13 Exide June 29~ 2007 The concrete footings on the east and west equalization tanks were found cracked and corroding. 14 Exide June 29, 2007 The concrete footings on the east and west equalization tanks were 15 . found cracked and corroding. • o-...--1 ::T C CD ::J (") (") ::J 0. 0 ru Q (") $E. @CD 0.0' 0 Q) ::J ~ o.::J (")CO o C/) a0. 0 ~ ::J .-+ ::J co ::T CD CD Q) C/) .-+ c.... C ::J CD m ~>< < (C~ ... I\.) o o ----J CD Exide June 29~ 2007 ~ I The concrete footings on the east and west found cracked and corroding. equaliz~tion tanks were 18 Exide June 29, 2007 The concrete footings on the east and west equalizatio found cracked and corroding. 19 o---I :::J'" C CD ::::l C') C') ::::l 0. 0 ru Q CD 7\ CD CD C') 0.0' Q) 0 ::::l !::!: o.::::l C')co o C/) aa. ::::l ., 0 :::J m ~>< Q) ::::l a. ~ C/) CD ..c c Q) o C CD ::::l co N c.... CDc.: '"" CD ~ o o --..J Exide June 29. 2007 The coating around a drain in the floor of the waste wa~er treatment, located near the acid tank has peeled way. The drain IS surrounded by secondary containment. 21 -I ::T CD ru (') 0.: ...... ru ::J "~ c.... ::T C :::J (') ::T (f) o g CD ...... ::T o o ~ (f) ...... CD ~ ---..J ~ 3 CD ::J ...... N N 1\.)>< I\.) CD ~ m COo.: a. ~ CD ..., ...,...... -CD CD - CD Exide June 29~ 2007 The coating surrounding the drain which is adjacent to ~he acid tank and 23 the footing of the acid tank was found cracked and corroded. Exide June 29~ 2007 -. The coating surrounding a drain which is adjacent to the acid tank, and the 24 footing of the acid tank was found cracked and corrodecd. Exide June 29~ 2007 I'h' The coating surrounding a drain which is adjacent to the aqid tank, and the footing of the acid tank was found cracked and corroded. . 25 Exide June 29, 2007 The coating surrounding a drain which is adjacent to the acid tank, and the footing of the acid tank was found cracked and corroded. 26 I Exide June 29. 2007 The storm water retention pond is almost empty of in the bottom of the pond contains 50% lead, and will processed in one of the smelting furnaces. . The sludge removed and 27 Exide June 29, 2007 rm-water-retentio-npo-ncns -almoste-mpty-bf wafer. The sludge in the bottom of the pond contains 50% lead, and will IDe removed and processed in one of the smelting furnaces. 28 Exide June 29, 2007 The storm water retention pond is almost empty of water. The sludge in the bottom of the pond contains 50% lead, and will be removed and processed in one of the smelting furnaces. . 29 Exide June 29, 2007 7 JlIjii'L NIt 1'-. The storm water retention pond is almost empty of water. The sludge in the bottom of the pond contains 50% lead, and will be removed and 30 processed in one of the smelting furnaces. . Exide June 29, 2007 Drums that contain batteries were stored in Battery Sterage area 108. 31 o 2 3CJ) ....... ::::r ~ C") o :::J ....... w. :::J 0W ::::: (\) ::::!. (\) CJ) :::E (\) CD CJ) ....... o CD 0. :::J OJ w ::::: (\) -< (j) ....... ~ o., w CO (\) ru CD ru c.... C ::J CD m f\J>< a: CD CD .~ f\J o o ~ c..... C . . . ::J CD ....... o CJ1 ~ en CD 3 "8- '< c.. C :::::!. :::J (0 , m "'>< CDc.: CD ~ '" o o "'-J 'C :::J ....... o CD +::0. 1\.)>< ~ en CD 3 ~ a. c ~. :::J, CO ....... :::r CD :::J .. ~ CD ~ o :::J m . ' < c.. CD o --I :::J ::r c.....CD c () :::J 0 CD 00 .-+ N _. (O:::J ~ en N.-+ O::r O~ -....J~ ~ 00 00 en en () m 0-'" CD _. ()00 :::J '" en CD .., 0. CD 00 "0 :::J 00. 0. .., () CD 0 .0..., .., o 0. CD 0. :::J en o >< _. Q. ",CD o o --...J o ::J --I :::r c.....(1) c (") ::J 0 ~~ c.o::J ~ "' CO ....... o:::r o~ -.....J::E ::E 0) 0) CJ) CJ) (") O"ro (1). (") ::J ~ CO (1) .., 0. (1) 0) "'0 ::J 0). 0. .., (1) (") 0 .., 0..., . o 0. (1) 0. m >< o _. . . a. ~CD o o ~ 0. ro_. Exide July 10, 2007 The concrete footings on the east and west equaliz~tion tanks that were found cracked and corroded on June 29, 2007 have not been repaired. 5 Exide 10,2007 The concrete footings on the east and west equali~ation tanks that were found cracked and corroded on June 29, 2007 have not been repaired. 6 Exide 10,2007 equallzatlpn tanKS that were found cracked and corroded on June 29,2007 Have not been repaired. 7 Exide The oncrete ootings on th west equalizatl I tanks that were found cracked and corroded on June 29, 2007 hefave not been 8 repawed. Exide July 10, 2007 The concrete footings on the east and west equalizaltio were found cracked and corroded on June 29,2007 ihave not been repaired. 9 Exide July 10, 2007 The concrete footings on the east and west equali were found cracked and corroded on June 29,2007 have not been 10 repaired. Exide July 10, 2007 e concrete tootlngs on the east and west equalizati were found cracked and corroded on June 29, 2007 Have not been repaired. 11 -EXIDE' 'TECHNOI~OGle:s Global Leader in Stored Electrical Enorgy Exide Technologies 2700 S. Indiana Street Los Angeles, CA 90023 Phone 323.262.1101 Fax 323.269.1906 CERTIFIED MAIL 7006 2150 0003 12480133 September 24, 2007 Mrs. Ruth Moorhead Department of Toxic Substances Southern California Region Statewide Compliance Branch lOll NOith Grandview Ave Glendale, CA 91201 RE: Notice of Violation from letter dated 8-31-07 Dear Mrs. Moorhead: Tbis letter is in response to your letter dated 8-31-07, transmitting a Notice of Violation to Exide Technologies. Exide Technologies received the complaint on September 05, 2007, at our facility located at 2700 South Indiana Street Los Angeles, CA 90023. Facility management surveyed and evaluated the condition of secondary containment in the Waste water treatment area on June 29, 2.007. That survey revealed that the Waste water treatment area had a few cracks located on tank footings and a crack alongside the waste water drainage system. The cracks were repaired on August 12, 2007 (a copy ofthe cost estimate along with pictnres of the aforementioned repairs is attached). Management at Exide Technologies is committed to protecting the environment. Thank yO~1 for your interest in our plants commitment to environmental excellence. Respectfhlly yours, f.z..- LJose Arias Environmental Health & Safety Mgr. Enclosures / CLIENT EXIDE TECHNOLOGIES PROJECT WATER TREATMENT EPOXY DATE WEEKENDING 07.12.07 THRU 8.12.07 2007039 JOB# PROJECT SUMMARY LABOR MATERIALS RENTALS EQUIPMENT RENTALS $11,440.00 $2,536.94 $0.00 $1,048.00 $0.00 SUB TOTAL $15,024.94 OVERHEAD/PROFIT TOTAL FILE COpy 15% • $17,278.68 PO Box 1578 Huntington Beach Ca 92647 Phone: 714-848-3204 advancedeon slru etors. co m Fax: 714-848-3205