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Summary Statemk to accompany the Retun , IEO&VED <br />Certification <br />FEB 14 2017 <br />613 CFR 112.7(c) Failure to provide appropriate secondary containment, diversionary structures <br />or equipment ENVIRONMENTAL HEALTH <br />DEPARTMENT <br />• The Facility is evaluating appropriate methods of secondary containment for the motor oil tanks <br />and oil skim tank. Temporary containment measures will be implemented within 14 days. <br />Permanent measures would be in place as soon as possible but not to exceed 90 days. Drums will <br />be stored on appropriately -sized spill pallets or within a containment structure. CFL will <br />implement proper drum storage as soon as possible, though not to exceed 14 days. Additional <br />changes recommended by the PE will be addressed immediately and completed within 6 months. <br />618 CFR 112.7(e), 112.8(c)(6) Failed to conduct inspections or integrity tests or maintain records <br />for 3 years. <br />As of January 25, 2017, Facility personnel resumed completion of monthly visual inspection <br />records. Facility personnel will continue to perform, record, and retain documentation of monthly <br />visual inspections. <br />620 CFR 112.7(f)(2) Failed to designate a person accountable for discharge prevention. <br />• The Plan update will include a designated person accountable for discharge prevention. <br />621 CFR 112.7(f)(3) Failed to schedule and conduct discharge prevention briefings at least <br />annually. <br />• Within 30 days of completion of the Plan update CFL will conduct an annual discharge <br />prevention briefing. CFL will document personnel attending the briefing using a training form <br />provided in the Plan update. CFL is evaluating the use of a third party firm to provide the annual <br />briefing and personnel training. <br />622 'CFR 112.7(f)(3) Failure to conduct spill prevention briefing for oil -handling personnel. <br />• Within 30 days of completion of the Plan update CFL will conduct an annual discharge <br />prevention briefing. CFL will document personnel attending the briefing using a training form <br />provided in the Plan update. CFL is evaluating the use of a third party firm to provide the annual <br />briefing and personnel training. <br />701 CFR 112.8(b)(1) Failure to ensure drainage from diked areas is restrained by valves or <br />alternative method. <br />Facility personnel have begun investigating possible sources of secondary containment leaks. The <br />investigation has focused on the condition of drain valves, identifying unknown drains, pipes <br />running through containment walls, and condition of the containment floor under the tanks. <br />Deficiencies will be noted on the monthly inspection form and containment promptly repaired. <br />Page 2 of 3 <br />