COMPLIANCE INFO_2021 - Laserfiche WebLink

Home Browse Search

• ER Procedures (HSC 25505(a)(3)); • Training Program (HSC 25505(a)(4)). Please note,with the exception of violation 4, HSC 25508(a)(1), PG&E believes that these violations were cited in error as they indicate that PG&E has previously failed to establish and implement these elements of the HMBP for these facilities. However,the inspection comments for each violation clearly indicate that the violations were cited specifically for not submitting the 2021 annual certification, making these violations contradictory to violation 9, addressed below. In addition to violations 4-8, addressed above, each report cites a violation of HSC 25508.2 for failure to annually review and certify that the HMBP is complete and accurate by the due date (violation 9 on the inspection reports).We have reviewed our records and have confirmed that the HMBP for the above referenced sites was not reviewed and certified by the annual 2021 due date.This was corrected on August 13, 2021 by Stephen Dioszegi who electronically certified the HMBP in CERS. Finally,the violations for failure to electronically submit the Business Activities or Owner/Operator page, as well the failure to annually review and certify the HMBP,were classified as a Class II violations on each report. In accordance with the CaIEPA Violation Classification Guidance for Unified Program Agencies, dated 03/03/2020 (Attachment 1), these violations should be classified as Minor Violations as they yielded no economic benefit to PG&E nor do they represent a pattern of neglect or disregard.Attachment A, Violation Classification Examples, of the Violation Classification Guidance,specifically identifies these violations as Minor when no change to the chemical inventory has occurred,which was confirmed to be the case at these facilities during the routine inspections that generated these reports. In summary, having reviewed the inspection reports and violations issued by the CUPA, PG&E requests that violations 5-8 on the above referenced reports be rescinded and the reports be reissued to accurately reflect violations 1 and 9 as Minor Violations. Please feel free to reach out to me directly at 209-262-0164 with any questions or concerns. Respectfully, Sheilah Lillie, REHS, MS Senior Environmental Scientist CC: Stephen Dioszegi, EFS; Lori Luces-Nakagawa,Supervisor,Central Area; Melissa Nissim, CUPA Program Coordinator