COMPLIANCE INFO_PRE 2019 - Laserfiche WebLink

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�.. Violation#27 ../ The SPCC Plan is to include a description of potential equipment failure(direction, flow rate, quantity),or provide allowed equivalences. The written SPCC Plan includes a description of the potential equipment failures under the section labeled "Potential Spill Predication, Volumes, Rates and Control. " The site SPCC Plan shows the locations and flow directions. See copy of the amended current SPCC Plan. Violation#32 (1)Train personnel on discharge prevention; (2) Designate a person to be accountable for discharge prevention; or (3) Schedule prevention discharge prevention briefings at least annually. Plant Operations and Maintenance Department engineers received training on discharge prevention in accordance with Part 112 "Oil Pollution Prevention" using the following procedure documents: "Management of Used Oils(Petroleum-Based), Spent Sorbents, Used Oil Filters and Spent Fuel Filters"and "Management of Used Edible (Cooking)Fats, Oils and Grease. " Food Services Department staffreceived training on discharge prevention using procedure document: "Management of Used Edible (Cooking)Fats, Oils and Grease. " See copies of training records for oil-handling personnel. Violation#33 The SPCC Plan is to (1) Describe how the oil handling,processing and storage areas are secured and controlled; (2) Describe how master flow and drain valves are secured; (3) Describe how unauthorized access to starter controls on oil pumps are prevented; (4) Describe how out-of-service and loading/unloading connections are secured; (5) Described the appropriateness of security lighting; or (6) Provide allowed equivalences. The written SPCC Plan includes a description of the site security under the section labeled "Site Security. " See copy of the amended current SPCC Plan. Violation#35 Provide methods to prevent vehicles from departing loading and unloading areas before complete disconnection of transfer lines or allowed equivalences. The site SPCC Plan includes notes for the proposed measures to prevent vehicles from departing loading and unloading areas before complete disconnection of the transfer line by an interlocking warning light. See copy of the amended current SPCC Plan. See also, example warning signage. Violation#38 The SPCC Plan is to include a complete discussion of conformance to discharge prevention and containment procedures as listed in Federal requirements and any applicable more stringent State rules,regulations, and guidelines. The site SPCC Plan Note #7 states "the management shall be familiar and conform to the discharge prevention and containment procedures as listed in Part 112 "Oil Pollution Prevention"of the "Code of Federal Regulations Title 40 Protection of Environment" See copy of the amended current SPCC Plan. Violation#57 Regularly inspect aboveground valves,piping, and appurtenances, or provide allowed equivalences. Plant Operations and Maintenance Department engineers received training on how to inspect the Above-Ground Storage Tank pumps, valves, connections, alarms, etc. in accordance with