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Page 2 of 3 <br /> is by August 15, 2011. Please see attached signed proposal with activity schedule. <br /> Violation # 32: Annual training is not conducted for the aboveground petroleum <br /> storage program and containers. At a minimum, oil-handling personnel must be trained <br /> in the operation and maintenance of equipment to prevent discharge procedure <br /> protocols, applicable pollution control laws, rules & regulations, general facility <br /> operations and the contents of the facility's SPCC plan. Annual briefings must be <br /> conducted to assure adequate understanding of the SPCC Plan and highlight and <br /> describe any known discharges or failures, malfunctioning components and any recently <br /> developed precautionary measures. <br /> Solution to Violation # 32: We have conducted the necessary training with all oil <br /> handling personnel using the old SPCC; please see attached training record sheet. <br /> Furthermore, we will train our associates again when ERM completes and certifies the <br /> SPCC plan. <br /> Violation # 50: Liquid level sensing devices have not been tested. Liquid level <br /> sensing devices must be installed in accordance with 40 CFR 112.8 and shall be <br /> regularly tested to ensure proper operation. <br /> Solution to Violation # 50: ERM is scheduled to conduct liquid level sensing device <br /> test during the integrity test on July 20, 2011. <br /> Violation # 60, 61, 62: Manifest number 00490784633K (1/21/10) and <br /> 003336135JJK (3/3/10) were not found on site. Hazardous waste generators shall <br /> retain copies of all manifests for three years or until a copy signed off by the destination <br /> facility is received. The signed off copy shall be retained and made readily available for <br /> review for three years. If the generator did not receive a copy of the manifest with the <br /> handwritten signature of the owner or operator of the facility to which the generator's <br /> waste was submitted within 35 days of the date the waste was accepted by initial <br /> transporter, the generator shall contact the transporter and/ or the owner operator of <br /> the designated facility to determine the status of the waste. If the generator did not <br /> receive a copy of the manifest with the handwritten signature of the owner or operator <br /> of the facility to which the generator's waste was submitted within 60 days of the date <br /> the waste accepted by the initial transporter, the generator shall submit a legible copy <br /> of the missing manifest, with some indication that the generator has not received <br /> confirmation of delivery. <br /> Solution to Violation # 60, 61, 62: The manifest number 00490784633K was <br /> located after the audit, attached is the signed manifest. A copy of manifest number <br /> 00333613533K and the letter to DTSC are attached. <br /> 8/29/2011 <br />