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AUG.2&2016 <br />ENVIRONMENTAL <br />HEALTH DEPARTMENT <br />not practicable, periodic integrity testing shall be performed on bulk storage containers, and <br />periodic integrity and leak testing shall be performed on the valves and piping. Immediately <br />amend the SPCC Plan and submit a copy of the changes to the EHD. <br />This is a Class II violation. <br />Item 616: CFR 112.7(f)(3) Failed to schedule and conduct discharge prevention briefings at <br />least annually. ^ <br />Discharge prevention briefings are not scheduled at least once a yea r. Accord ingto William <br />Boscacci, the last spill prevention briefing was held in 2013. Discharge prevention briefings <br />for oil handling personnel must be scheduled and conducted at least once a year to assure <br />adequate understanding of the SPCC Plan for that faci lity. Such briefings must highlight and <br />describe known discharges or failures, malfunctioning components, and any recently <br />developed precautionary measures. Immediately schedule and conduct a discharge <br />prevention briefing, ensure that they are scheduled and conducted at least once a year. <br />This is a Class II violation. <br />Owens' Response/ Corrective Action for Items #101, 302. 604, 605, 610, and <br />616: <br />The Facility contracted with a Professional Engineer to review and amend its <br />Spill Prevention, Control, and Countermeasure plan to address technical <br />amendments since the previous Plan was completed. A copy of the updated <br />plan will be forwarded to the Health Department by August 22, 2016. <br />Secondary Containment /Diked Areas <br />Item 609: CFR 112.7(c) Failed to providesecondarV containment,diversionary structures, or <br />equipmentto preventdischar�e0 <br />According to the site inspection and according to the reviewed tank assessment report, <br />prepared by Conestoga -Rovers &Associates (dated August 15, 2012), the 450 -gallon and <br />gallon waste waste oil tanks appearto have insufficient secondary containment. The reviewed waste <br />oil tank assessment, indicated the oil/water separator pit used as secondary containment for <br />the 1,750 -gallon tank "doesn't appear to meet the requirements of 22 CCR 66265.193 and it <br />didn't appear to be lined and cracks were observed in concrete above the liquid level in the <br />pit". Furthermore, according to the same tank assessment, the 450 -gallon waste oil tank has <br />no secondary containment. Also, the oily waste mixture, referred to as "biosol' and used in <br />the glass making process, discharges directly from the glass making area into an unlined area <br />where it pools and subsequently flows into the respective in -ground oil water separators. <br />Also, standing oily liquid was noted next to the oil filled equipment, and no sized or general <br />secondary containment provisions were observed at the time of inspection next to the said <br />