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IVEDSummary Statem I to accompany the Retur o Co E>eE <br />Certification <br />LB 14 2017 <br />706 CFR 112.8(c)(2) Failed to provide and maintain adequate secondary containment.�VIRONMENTAL HEALTH <br />• The Facility is evaluating appropriate methods of secondary ry containment for the motor oil���RTMENT <br />and oil skim tank. CFL intends to provide adequate containment as soon as possible though not to <br />exceed 90 days. Drums will be stored on appropriately -sized spill pallets or within a containment <br />structure. CFL will implement proper drum storage as soon as possible, though not to exceed 14 <br />days. Additional changes recommended by the PE will be addressed immediately and completed <br />within 6 months. <br />711 CFR 112.8(c)(6) Failed to perform scheduled tank tests or inspections by appropriately <br />qualified personnel. <br />A description of the type and frequency of inspection as well as inspector qualifications for each <br />oil container will be provided in the Plan update. As of January 25, 2017, Facility personnel <br />resumed completion of monthly visual inspection records. Facility personnel will continue to <br />perform, record, and retain documentation of monthly visual inspections. CFL will contract with <br />a certified tank inspector, as necessary, based on inspection criteria in the updated Plan. Copies of <br />the integrity inspection reports will be provided to SJCEHD. <br />714 CFR 112.8(c)(8)(i-iv) Failed to provide each container with a high level monitoring device. <br />• CFL is evaluating the appropriate equipment options and intends to comply with this regulation <br />as soon as possible, but not to exceed 30 days. <br />715 CFR 112.8(c)(8)(v) Failed to regularly test liquid level sensing devices to ensure proper <br />operation. <br />• Testing requirements and inspection intervals will be provided in the Plan update. <br />718 CFR 112.8(c)(11) Failed to provide sufficient containment for mobile or portable containers. <br />Drums will be stored on appropriately -sized spill pallets or within a containment structure. CFL <br />will 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 />724 CFR 112.8(d)(4) Failed to inspect aboveground valves, piping, and appurtenances. <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 />4010 CFR 112.7 SPCC Plan lacks full approval of management at a level of authority to commit the <br />necessary resources to implement the Plan. <br />• The Plan update will include the appropriate management approval in accordance with CFR <br />112.7. <br />Page 3 of 3 <br />