COMPLIANCE INFO_PRE 2019 - Laserfiche WebLink

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DJWWTP-SEWD Spill Prevention, Control, and Countermeaserre (SPCC) Plan including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system will not escape the containment system before cleanup occurs. Immediately provide adequate secondary containment for all aboveground petroleum storage containers larger than 55 gallons. Note: 'General' containment per 112.7(c) may be active or passive in design, use or operation, and must be sufficient to contain a release from the 'typical' failure mode and likely release volume (i.e., most likely release - not full sized containment). This is a Class II violation. The SPCC plan, was amended to include secondary containment sorbent material for mobile refuelers. Each mobile refueler is now equipped with an 8.3 gallon spill kit which is more than the most likely release of 3.0 gallons from section 4.2.11. 711 CFR 112.8(c)(6) Failed to perform scheduled tank tests or inspections by appropriately qualified personnel. The 10,000 gallon tank, 5,000 gallon tank and the 2,000 gallon tanks were not tested on schedule as described in the SPCC plan. The SPCC plan states that the oldest tank at the facility was installed in 1991, the SPCC plan does not specify which tank it is referring to or the age of the three mentioned tanks. The SPCC plan calls for formal inspections by a certified SP001 inspector be conducted every 20 years on the three tanks. Based on the year of the oldest tank provided in the SPCC plan, these inspections should have been conducted in 2011. The SPCC plan also calls for monthly and annual inspections to be conducted by the facility. Monthly inspections are being conducted by the facility but the annual checklist is not being verified. Each aboveground container shall be tested and inspected for integrity on a regular schedule and whenever repairs are made. The qualifications of personnel performing tests and inspections, frequency and type of testing and inspections that take into account container size, configuration, and design shall be determined in accordance with industry standards. Examples of these integrity tests include, but are not limited to: visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other systems of non-destructive testing. Comparison records and other records of inspections and tests must be maintained on site. Immediately conduct the necessary testing and submit a copy of the test results to the EHD, or provide equivalence as allowed by CFR 112.7(a)(2). This is a Class II violation. The 2,000 -gallon external inspection was not required in the amended SPCC plan. The District approved the purchase order for the formal external inspection by a certified SP001 inspector for the 10,000 and 5,000 -gallon tanks. Attached are the Purchase Order and Proposal from Powers Engineering &Inspection Inc. The District created the Procedures for the Annual AST Inspection in Maintenance Connection, which automatically creates work orders to complete the inspection. Attached is Procedure Tasks report for the annual inspection. 718 CFR 112.8(c)(11) Failed to locate properly or provide sufficient secondary containment for mobile/ portable containers. The 55 gallon drums in the storage area next the the used oil tank were observed with insufficient secondary containment. Approximately six 55 gallon drums were observed on wooden pallets in the storage area. The drums were observed outside of the diked area. Facility personnel stated that this was the regular storage location of the 2