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711 Materials Response: <br /> The SPCC Plan has been updated to provide additional discussion of the environmental <br /> equivalence of monthly visual inspections for shop-fabricated ASTs at the facility. the U.S. <br /> EPA provides guidance stating that for well-designed shop-built containers of less than 30,000 <br /> gallons, visual inspection plus elevation of a shop-built container in a manner that decreases <br /> corrosion potential (as compared to a container in contact with soil)and makes all sides of the <br /> container visible during inspection would be considered "equivalent environmental protection" <br /> to the methods outlined in 40 CFR 112.8(c)(6) as allowed by 40 CFR 112.7(a)(2). <br /> Additionally, the inspection schedule for the 12,000-gallon ConVault tank has been clarified <br /> in the SPCC Plan to reflect the industry standard STI SP-001 recommended inspection <br /> schedule. Inspection and maintenance procedures follow the ConVault Owner's Manual. <br /> The personnel performing these inspections are knowledgeable about storage facility <br /> operations, the type of ASTs and associated components present at the facility, spill control <br /> systems, and characteristics of the materials stored on site as described in the Steel Tank <br /> Institute's SP-001. <br /> Item # 715: <br /> CFR 112.8(c)(8)(v) Failed to regularly test liquid level sensing devices to ensure proper <br /> operation. <br /> Procedures and frequency of testing for these devices were not addressed in the Spill <br /> Prevention, Control, and Countermeasure (SPCC) plan. The monthly inspection checklist <br /> does not include testing of liquid level sensing devices. Per Steven Case (General Manager) <br /> liquid level sensing devices are tested by sticking the tank and comparing to the gauges. <br /> Liquid level sensing devices must be installed in accordance with CFR 112.8 and shall be <br /> regularly tested to ensure proper operation. Immediately ensure that liquid level sensing <br /> device testing is discussed in the SPCC plan and submit proof to the EHD. <br /> This is a repeat violation, Class ll. <br /> 711 Materials Response: <br /> 711 Materials personnel regularly test liquid level sensing devices during monthly inspection <br /> to ensure proper operation. Liquid level sensing devices are tested by sticking the tank and <br /> comparing the reading to that on the liquid level gauge. The SPCC Plan has been updated to <br /> reflect these procedures and is included in Attachment 2. <br /> Item # 717: <br /> CFR 112.8(c)(10) Failed to promptly correct visible discharges and/or remove accumulations <br /> of oil in diked areas. <br /> The secondary containment for the 300-gallon used oil tank had approximately 1/4 inch of oil <br /> in it. On the concrete around the secondary containment drain dark staining was observed. <br /> Visible discharges which result in a loss of oil from a container, including but not limited to <br /> seams, gaskets, piping, pumps, valves, rivets, and bolts, must be promptly corrected. <br /> Immediately clean out the secondary containment and the stains on the ground and manage <br /> according to the California Code of Regulations Title 22 hazardous waste regulations. <br /> This is a Class 11 violation. <br /> 711 Materials Response: <br /> Oil present at the time of inspection in the secondary containment of the 300-gallon used oil tank <br /> has been removed and disposed of in accordance with local, state, and federal regulations. <br /> July 3, 2019 4 <br />