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DJWWTP-SE WD Spill Prevention, Control, and Colin SAN JOAQUIN COUNTY ENVIRONMENTAL HEALTH DEP SUMMARY OF VIOLATIONS (October 10, 2018) Item #Remarks Plan NOV J 2018 FNVIHONIIIENTAL HE,'- l -T -O -H 203 CFR 112.3 Failure to implement the SPCC Plan. IEPA4Tl�riFNT The SPCC plan calls for Table 3-2 "Fuel Transfer Procedures" ,found in the SPCC plan, to be posted near unloading/loading points. The "Fuel Transfer Procedures" were not observed posted and facility personnel could not point the sign out. The owner or operator or an onshore or offshore facility subject to this section must prepare in writing and implement a Spill Prevention Control and Countermeasure Plan (hereafter "SPCC Plan" or "Plan")," in accordance with § 112.7 and any applicable section. Immediately implement the plan as written or make amendments to the SPCC Plan to accurately represent the procedures and policies currently in place at the facility. This is a Class II violation. The SPCC Plan was amended and the sentence indicating Table 3-2 is posted next to the loading/unloading point was removed. The SPCC Plan to accurately represent the procedures and policies currently in place at the facility. 604 CFR 112.7(a)(3)(i) Plan failed to include oil type and storage capacity for each container. The SPCC plan lists a total of two 55 gallon drums, one containing oil and another solvents. The storage area for the 55 gallon drums was observed with approximately six 55 gallon drums, storing new oil and used oil. You must also address in your Plan: (i) The type of oil in each fixed container and its storage capacity. For mobile or portable containers, either provide the type of oil and storage capacity for each container or provide an estimate of the potential number of mobile or portable containers, the types of oil, and anticipated storage capacities. Amend the SPCC plan reflect the type of oil storage capacity for each portable container or provide an estimate of the potential number of mobile or portable containers, the types of oil and anticipated storage capacities, submit copy of amended plan to the EHD for review. This is a Class II violation. The SPCC Plan was amended, four 55 -gallon drums were included with two containing oil and two containing solventsM The other two drums contain coolant for a total of six drums. The two coolant drums are not included in the SPCC Plan. 612 CFR 112.7(c) Plan failed to include secondary containment, diversionary structures, or equip to prevent discharge. The SPCC plan states that the two 100 gallon "mobile diesel" refuelers do not have secondary containment. General secondary containment is a requirement for mobile refuelers. A facility shall provide appropriate containment and/or diversionary structures or equipment to prevent a discharge. The entire containment system, 7