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Stacy Rivera August 3, 2011 Page 5 UPDATE ON RETURN TO COMPLIANCE CERTIFICATION - HAZARDOUS WASTE GENERATOR PROGRAM INSPECTION REPORT AND ABOVEGROUND PETROLEUM STORAGE ACT INSPECTION REPORT FOR CITY OF STOCKTON MUNICIPAL UTILITIES DEPARTMENT MAIN PLANT, TERTIARY PLANT AND STORES FACILITIES INSPECTIONS CONDUCTED MAY 11, 2011 16 V 16. SPCC Plan lacks full approval of management at a level of authority to commit the necessary resources to implement the Plan The management approval section of the Spill Prevention Countermeasure N and Control Plan has not been completed. The Plan must have the full approval of management at a level of authority to commit the necessary resources to fully implement the plan. Retained the services of Condor Earth Technologies, who are in the process of conducting a Spill Prevention, Control and Countermeasures Plan R update. July 2011 Updated Draft Working Copy is being reviewed by MUD Senior management for signature and incorporates other necessary changes or provides place holders for information updates. 18 V 18. No facility diagram or diagram failed to show the location and contents of each container, transfer stations, and connecting pipes. The Facility diagram does not include the location of emergency generators N and the Clarifloc totes. The Plan shall include a Facility diagram which must mark the location and contents of each fixed storage container and the storage area where mobile or portable containers are located. Update Facilities maps are being drafted by Condor Earth Technologies R who have been retained to update the Spill Prevention, Control and Countermeasures Plan. Will provide ollow-up letter. 19 19. SPCC Plan failed to include description of product type and storage 21 capacity for each container. 21. SPCC Plan failed to show discharge or & V drainage controls (secondary containment) equipment and procedures for 27 the control of a discharge. 27. SPCC Plan failed to include a description of potential equipment failure (direction, flow rate, quantity), of provide e uivalence as allowed by CFR 112.7(a) (2). The inventory listed in the SPCC Plan does not include the emergency generators of the Clarifloc totes. Discharge and drainage controls and potential equipment failure are not addressed for any of the unlisted N containers. The SPCC Plan must include the correct type of oil and storage capacity of each fixed storage container, and either the type of oil and storage capacity of each portable container or an estimate of the potential number of portable containers, types of oil and anticipated storage capacities. Retained the services of Condor Earth Technologies, who are in the process of conducting a Spill Prevention, Control and Countermeasures Plan R update. July 2011 Updated Draft Working Copy has incorporated changes or provided place holders for information update. Will provide follow-up as plan is finalized. 24 24. SPCC Plan failed to include required contact list and phone numbers of V the facility's response coordinator, cleanup contractors and agencies to notify in case of discharge. The phone number for the San Joaquin County Office of Emergency N Services is not included in the contact list. The alternate response coordinator has been changed from Steve Gittins to Larry Parlin. This