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as allowed by CFR 112.7(a)(2). Submit proof of correction to the EHD. <br />This is a Class II Violation. <br />;• ro <br />AUG 2 3°2016 <br />ENVIRONfVAENTAL <br />HEALTH DEPARTMENT <br />Owens' Response/Corrective Action: <br />Owens is currently performing daily inspections of its hazardous waste used <br />oil tank system. A copy of the inspection log is included as Exhibit 7. <br />Item 717: CFR 112.8(c)(8)(v) Failed to regularly test liquid level sensing devices to ensure <br />proper operation. <br />According to Mr. Boscacci, the existing liquid level sensing devices have not been tested for <br />all existing tanks. Procedures and frequency oftestingforthese devices were not addressed <br />inthe Spill Prevention, Control, and Countermeasure (SPCC) plan. Liquid level sensing devices <br />must be installed in accordance with CFR 112.8 and shall be regularly tested to ensure proper <br />operation . Immediately conduct all necessary testing of liquid level sensing devices, or <br />provide equivalence as allowed by CFR 112.7(a)(2).Submit proof of correction to the EHD. <br />This is a Class II Violation. <br />Owens' Response/Corrective Action; <br />Please refer to the following section in the SPCC Pian: Integrity Testing - 112.8 <br />(c)(6). The text states Additional tank inspections are performed in accordance <br />with the standards used to manufacture the tank or as specified by the <br />manufacturer. Level alarms and other instrumentation are inspected annually, <br />or per manufacturer's recommendations. This section of the SPCC Plan will be <br />revised to more explicitly include liquid level sensing devices in the annual <br />preventive maintenance schedule for testing. <br />Trainin <br />Item 614: CFR 112.7(f)(1) Failed to train personnel on discharge prevention. <br />Oil handling personnel were not adequately trained. Thirty people were trained in Z�10 <br />compared to the most recent training during, which only two people were trained.The last <br />spill prevention briefing was held in 2013. At a minimum, oil handling personnel shall be <br />trained in the operation and maintenance of equipment to prevent discharges; discharge <br />procedure protocols; applicable pollution control laws, rules, and regulations; general facility <br />operations; and the contents of the Spill Prevention, Control, and Countermeasure Plan. <br />Immediately provide this training to all oil handling personnel and submit a copy of the <br />19 <br />