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Page 2 of 3 <br /> This letter is to advise you of the corrections that we have made and our status in regards to <br /> your audit on June 20, 2011. <br /> Violation # 8: The spill prevention, countermeasure, and Control (SPCC) Plan on site <br /> states that a petroleum filter is being used on the storm drain closest to the <br /> aboveground diesel tanks. A petroleum filter was not observed on the storm drain and <br /> facility personnel were unfamiliar with the practice. The SPCC plan must be amended <br /> when there is a change in the facility design, construction, operation, or maintenance <br /> that materially affect its potential for a discharge, within 6 months of the change, and <br /> implemented as soon as possible, not later than 6 months following preparation of the <br /> amendment. Immediately make all necessary amendments to the SPCC Plan to <br /> accurately represent the procedures and policies currently in place at the facility. <br /> Solution to Violation # 8: We installed the petroleum filter in the storms drains <br /> closet to the aboveground diesel tanks in corresponding to our current (SPCC). Please <br /> see attached pictures and fact sheet for the filter. <br /> Violation # (10, 18, 24, 48, 50) Routine Aboveground Petroleum Storage Act <br /> Solution to Violation # (10, 18, 24, 48, 50) Routine Aboveground Petroleum <br /> Storage Act: We have contacted and hired ERM (Environmental Resource <br /> Management to conduct tank integrity testing and updated SPCC plan and PE <br /> certification. The estimated time of completion for the SPCC and tank integrity testing <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 /> 9/6/2011 <br />