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Cesar Ruvalcaba [EH] From: Cesar Ruvalcaba [EH] Sent: Friday, February 22, 2019 2:16 PM To: 'Doug Brewer' Cc: Litchfield, Don; Ramirez, Ruben; Aaron Garcia; Michael Cullinane Subject: RE: Corrective Actions/Return to Compliance Certification: Forward Inc. Landfill CERS 10182195 - PR0515721 Doug, Below is a list of violations that have not been addressed.The SPCC plan was not reviewed in whole,the cross reference section was used to identify the proper discussion area(s) in the plan for the violations. In trying to find some of the discussions there were some observations made where the plan may not meet the requirements of regulations. Observations: The cross reference section contains errors or guides the user to non-existent pages. For example while trying to locate the discussion on 40 CFR part 112.7(a)(4)the cross reference section guides the user to section 2.5 page 2-12— Discharge Reporting Information.There is no page 2-12 in the SPCC plan. Other sections of the plan guide the user to pages 2-11, and 2-13, and these pages do not exist in the SPCC plan. overfill Overfill prevention— It is unclear which overfill prevention system was certified by the engineer and is in use by the facility. A description of the overfill system that meets the requirements of the regulation should be in the plan.There is also a requirement to test the overfill system. Violations that remain open: Violation#609-Plan failed to adequately contain procedures for reporting a discharge. The SPCC plan does not contain the name and contact information of the cleanup contractors with whom the facility has an agreement for response. Regulations require "...Contact list and phone numbers for the facility response coordinator, National Response Center, cleanup contractors with whom you have an agreement for response, and all appropriate Federal, State, and local agencies who must be contacted in case of a discharge..." Violation#711 -Failed to perform scheduled tank tests or inspections by appropriately qualified personnel. Once the testing report is ready, please forward a copy to close this violation. Violation#712-Failed to test or inspect each container for integrity based on industry standards. Although the annual inspection, as called for in the SP-001 standard has been added,the plan deviates from the SP-001 standard.The SPCC plan does not mention the certified inspector testing/inspections which are required under the SP- 001 standard for the 10,000 gallon tank.The SP-001 Table 5.5 "Table of Inspection Schedules"found in the 6t"edition of the STI SP-001 standard can be referenced for more detail.The regulations state that "...You must determine, in accordance with industry standards,the appropriate qualifications for personnel performing tests and inspections,the frequency and type of testing and inspections. ..." Feel free to contact me with any questions or ceoncerns. i