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Subject: RE: Return to Compliance <br /> CAUTION:This email originated from outside LodiUSD. Do not click any links or open attachments and verify the sender <br /> if this is unsolicited email. <br /> Hello Jill, <br /> If the necessary training on the SPCC plan was done in December then I just need to see something that shows it was <br /> done. The training sign in sheets you are provided are titled, "HMMP & No Idle Law," "Oil Spill & Hazmat Clean-up, " <br /> "Personal Protective Equipment Training," "HazWaste Generator/CERS Basics," and "Hazardous Waste Management". <br /> Perhaps you can provide the contents of the trainings to show that the SPCC plan training was provided because the <br /> titles of the trainings don't appear to cover the entire SPCC plan. Here are what the regulations require for SPCC plan <br /> training: <br /> 40 CFR 112.7(f): Personnel,training, and discharge prevention procedures. (1)At a minimum,train your oil-handling <br /> personnel in the operation and maintenance of equipment to prevent discharges; discharge procedure protocols; <br /> applicable pollution control laws, rules, and regulations; general facility operations; and,the contents of the facility SPCC <br /> Plan. <br /> (2) Designate a person at each applicable facility who is accountable for discharge prevention and who reports to facility <br /> management. <br /> (3) Schedule and conduct discharge prevention briefings for your oil-handling personnel at least once a year to assure <br /> adequate understanding of the SPCC Plan for that facility. Such briefings must highlight and describe known discharges <br /> as described in § 112.1(b) or failures, malfunctioning components, and any recently developed precautionary measures. <br /> If the December training does not cover the above minimum requirements then staff need to be trained on the above. <br /> The training must be done within the following timelines. <br /> 40CFR 112.5(a): Amend the SPCC Plan for your facility in accordance with the general requirements in § 112.7, and with <br /> any specific section of this part applicable to your facility,when there is a change in the facility design, construction, <br /> operation, or maintenance that materially affects its potential for a discharge as described in § 112.1(b). Examples of <br /> changes that may require amendment of the Plan include, but are not limited to: commissioning or decommissioning <br /> containers; replacement, reconstruction, or movement of containers; reconstruction, replacement, or installation of <br /> piping systems; construction or demolition that might alter secondary containment structures; changes of product or <br /> service; or revision of standard operation or maintenance procedures at a facility. An amendment made under this <br /> section must be prepared within six months, and implemented as soon as possible, but not later than six months <br /> following preparation of the amendment. <br /> Your newest SPCC plan has a date of 1/23/2020 so training must be done within 6 months of that date. December is too <br /> far away. With that being said it is understandable that because of the current corona virus situation this may take <br /> longer to accomplish since schools are closed right now. <br /> If you have any questions or need assistance please let me know. <br /> Best Regards, <br /> Lydia Baker <br /> Registered Environmental Health Specialist San Joaquin County Environmental Health Department <br /> 209-468-8257 <br /> 1baker@sjgov.org<maiIto:Ibaker@sjgov.org> <br /> Please note my email address has changed to (baker@sjgov.org<mailto:lbaker@sjgov.org> <br /> 4 <br />