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3 <br /> impracticable on an SPCC Plan or sections of one <br /> that is PE certified. Corrective Action: As <br /> stated on page 8 of the existing SPCC Plan under <br /> Section VII CONTAINMENT, secondary containment <br /> for this area is provided by the Storm Water <br /> Retention Pond. Section VII B states that "The <br /> probability of a spill from this facility <br /> reaching the navigable water body is negligible. <br /> A release or spill occurring at this facility, <br /> if undetected and unmitigated, would enter the <br /> storm drainage system and would gravity-flow, or <br /> be automatically pumped into the storm water <br /> retention pond and be contained there. " <br /> Management of the storm water retention pond <br /> extraction system is a manual process and may <br /> not proceed without approval of the DESJC <br /> Environmental Office and a water sample being <br /> collected. This process will prevent a spill <br /> from leaving the facility. Additional <br /> information is available in the Storm Water <br /> Pollution Prevention Plan for the DDJC Tracy <br /> Facility. Finally, DESJC considers it very <br /> unlikely that the entire drum inventory might <br /> rupture at any given time. The Depot does <br /> provide secondary containment spill pallets for <br /> individual drums spills at the storage site. <br /> (7) Item 32 - Failed to (1) train personnel on <br /> discharge prevention; (2) designate a person to <br /> be accountable for discharge prevention; of (3 ) <br /> schedule discharge prevention briefings at least <br /> annually. Corrective Action: The oil-handling <br /> personnel at DDJC that are required by 40 CFR <br /> 112 . 7 (F) to have training in the operation and <br /> maintenance of equipment and discharge <br /> prevention procedure protocols in order to <br /> prevent discharges are the fork lift operators <br /> (material handlers) and supervisors of Area C <br /> (POL drum storage area) and the HAZMAT employees . <br /> These personnel are trained to operate material <br /> handling equipment specifically to prevent <br /> discharges as well as First Responder training <br /> which outlines spill response protocols . The <br /> training records are kept in a database in the <br /> DDJC Training Office. The plan will be amended <br /> to indicate the correct location of the training <br /> records . Also note that the Hazardous Waste <br />