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{ LL �- <br /> 1111 Ll <br /> Figure 1. Truck Wash Area (Tank Removed) <br /> Item # 622: <br /> CFR 112.7(0(3) Failure to conduct complete annual discharge prevention briefings for oil- <br /> handling personnel. <br /> The last discharge prevention briefing was on May 7, 2018. Discharge prevention briefings <br /> are not scheduled at least once a year. Discharge prevention briefings for oil handling <br /> personnel must be scheduled and conducted at least once a year to assure adequate <br /> understanding of the SPCC Plan for that facility. Such briefings must highlight and describe <br /> known discharges or failures, malfunctioning components, and any recently developed <br /> precautionary measures. Immediately schedule and conduct a discharge prevention briefing, <br /> ensure that they are scheduled and conducted at least once a year and submit proof to the <br /> EHD. <br /> This is a minor violation. <br /> 711 Materials Response: <br /> The facility completed an annual discharge prevention briefing on June 11, 2019. The sign-in <br /> sheet for the training is included in Attachment 1. The discharge prevention briefing included <br /> discussion of past discharges or failures, leak inspection and notification procedures, spill <br /> response and notification procedures, as well as proper AST operation at the facility. 711 <br /> Materials will be sure to conduct these briefings annually going forward and document the <br /> trainings in the SPCC Plan. <br /> Item # 711: <br /> CFR 112.8(c)(6) Failed to perform scheduled tank tests or inspections by appropriately <br /> qualified personnel. <br /> The SPCC plan calls for quarterly inspections on page 19. Quarterly inspections are not being <br /> done. Each aboveground container shall be tested and inspected for integrity on a regular <br /> schedule and whenever repairs are made. The qualifications of personnel performing tests <br /> and inspections, frequency and type of testing and inspections that take into account container <br /> July 3, 2019 2 <br />