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Tiger Lines, LLC <br /> 927 East Black Diamond Way <br /> Lodi, CA 95240 <br /> Corrective Actions for Inspection Date March 14, 2019 <br /> Item#301: CFR 312.5(a) Failed to amend Plan as necessary. <br /> Summary of Violations: <br /> A hydraulic ail tank on wheels was observed in the large maintenance shop. The tank appeared to <br /> have a capacity of over 55 gallons and was not mentioned in the SPCC plan.The two 25,000 diesel <br /> tanks appear to be permanently manifolded and this is not discussed in the SPCC plan. The SPCC <br /> plan describes four 55-gallon drums of oil near the 1,000-gallon oil tanks,five drums were observed <br /> in that area. The Spill Prevention, Control, and Countermeasure (SPCC) Plan must be amended <br /> when there is a change in the facility design, construction, operation, or maintenance that <br /> materially affects its potential for a discharge, within 6 months of the change, and implemented as <br /> soon as possible, not later than 6 months following preparation of the amendment. Immediately <br /> make all necessary amendments to the SPCC Plan to accurately represent the procedures and <br /> policies currently in place at the facility. <br /> Note: Permanently manifolded tanks are tanks that are designed, installed, or operated in such a <br /> manner that the multiple containers function as a single storage unit (67 FR 47122,July 17, 2002). <br /> Accordingly, the total capacity of manifolded containers is the design capacity standard for the <br /> sized secondary containment provisions(plus freeboard in certain cases). <br /> This is a minor violation. <br /> Corrective Actions Taken for Each Violation: <br /> 1. An audit of the entire facility will be scheduled before the end of March 2019. All 55-gallon <br /> containers and above will be mentioned in the SPCC Plan. <br /> 2. The piping configuration of the two 25,000-gallon diesel tanks, which appear to be permanently <br /> manifolded together, will be reviewed with the EPA Region 9 Representative. Appropriate <br /> action will be taken according to the outcome of that meeting. A meeting will be scheduled as <br /> soon as possible, based upon the availability of the EPA Representative. <br /> Item#601: CFR 112.7 Failure of Plan to fulfill basic requirements including a cross-referencing <br /> section. <br /> Summary of Violations: <br /> The Spill Prevention, Control, and Countermeasure (SPCC) Plan does not follow the order or <br /> requirements in 40 CFR Part 112, and a cross-reference which follows the sequence specified in 40 <br /> CFR was not provided. The cross reference provided does not follow the required sequence of 40 <br /> CFR part 112 and in some instances the referenced pages do not lead to the correct discussion. If <br /> you do not follow the sequence specified in 40 CFR 112 for the Plan, you must prepare an <br /> equivalent Plan and supplement it with a section cross-referencing the location of requirements in <br /> 40 CFR 112 and the equivalent Plan. Immediately amend the SPCC Plan to include a cross-reference <br /> or to follow the required sequence. <br /> This Is a minor violation. <br /> Page 1 of 5 <br />