COMPLIANCE INFO_2006-2008 - Laserfiche WebLink

Home Browse Search

0 0 Response: As noted on the 'official inspection report-continuation form',the sensors were repositioned at the time of inspection. Also, site has just completed installation of'tamper proof sensors, as witnessed by Inspector Naidu. A copy of the updated Monitoring&Response Plan is enclosed. 2. Alleged Violation: The UST Program inspection report stated, "#21 Liquid was observed in the 91 turbine and fill sumps, in the 87 master fill sump, and the 87 slave fill sump. Remove this liquid in accordance with title 22 hazardous waste regulations. Correct immediately" In the corresponding violation checklist, a check was placed next to"HSC 25291 (e),water in 2 containment analyzed&properly disposed of." Response: As noted on the 'official inspection report-continuation form', liquid was removed at the time of inspection. This liquid was placed into a properly labeled hazardous waste drum. 3. Alleged Violation: The UST Program inspection report stated, "23(f)Facility employees have not yet been trained on the facilities best management practices, Immediately conduct this training and submit copies of the training records to this office by 6/30/2006."In the corresponding violation checklist, a check was placed next to"CCR 2715, Designated Operator: (a) statement from UST owner; (c-e) Monthly inspection; (f) employee training." Response: All site employees have been trained in accordance with BP's best management practices. The training logs were seen by Lori Luces and Toua Yang. As previously communicated, BP has changed it's training form and training material guideline,to include the words 'best management practices'. However, it is understood that the training material and subsequent training logs are in accordance with BP's best management practices. Updated training logs and guidelines have recently been sent to all sites and you will see these new documents for the 2006 refresher and new hire training documentation. I encourage you to look at CCR 2715 within title 23, section 16 and explain where BP's listed training topics located on the training log,do not meet or exceed the written regulation. I would think that your department heads would have better use of your time and energy than direct you to write violations that are in fact,not violation's. I am still waiting for clarification from your boss to my inquiry on this issue. That request was on or around April 19, 2006. 4. Alleged Violation: The UST Program inspection report stated, "#26, 87 slave spill bucket failed the lake test. Repair or replace this spill bucket under a permit from this office immediately." In the corresponding violation checklist, a check was placed next to"HSC 25284.2,Annual spill containment testing." Response: The 87 slave spill bucket was replaced and tested by Elite IV on 6/6/2006. A copy of the retest report form is enclosed. In addition,I am enclosing the annual monitoring system certification, electronic line leak detector test data sheet, and the spill/overfill containment box test data sheets for Arco facility listed above. I am also enclosing the 'Return to Compliance Certification' statement.