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• Violation #40—Closed <br /> • Violation #43—Open.The tank and container assessment has not been updated to include the <br /> items noted in the inspection report. I spoke with Tony from Teracon 4/20/26, he stated that their <br /> goal is to get the report updated by end of April. <br /> • Violation #67—Closed <br /> • Violation #69—Open. It's unclear from the photo that the crystallized debris has been cleaned up <br /> and an investigation into the cause of the release was not addressed. Please see corrective action <br /> guidance in the report for more information. <br /> • Violation #76—Closed <br /> Tiered Permitting: <br /> • Violation #2—Open. Updates are needed in CERS. <br /> • Violation #6—Open. <br /> o The closure cost estimate scope of work states that it utilizes price sheet from 2019 <br /> proposal, but total cost submitted is less than the total cost submitted based on the 2019 <br /> proposal in 2024. <br /> o The estimate submitted does not address all disposal categories or materials listed or the <br /> energy, insurance, & recovery fee listed in the 2019 proposal. <br /> o The estimate submitted does not address the required professional engineer certification <br /> of the FTU closure, sampling, etc. Please see the attached example closure cost estimate <br /> for reference. <br /> o The closure cost estimate, if based on 2019 prices, does not include adjustments for <br /> inflation for each year since 2019. <br /> • Violation #7—The closure cost estimate does not include adjustments for inflation since 2019, <br /> the reference price list. Inflation adjustments must be made in accordance with the requirements <br /> of CCR. See attached inflation factor guidance. <br /> o The other option, which you are welcome to do, is to create/obtain a whole new estimate. <br /> • Violation #12 - Open. The tank and container assessment has not been updated to include the <br /> items noted in the inspection report.As mentioned above, I spoke with Tony from Teracon <br /> 4/20/26, he stated that their goal is to get the report updated by end of April. <br /> • Violation #17—Open.The RTC statement does not address the missing/blank inspection records <br /> from the inspection report. Please provide a corrective action statement indicating how this has <br /> been addressed to prevent this compliance issue from reoccurring. <br /> • Violation #18—Open.The updated operating instructions look great, but I don't see any mention <br /> of when to implement the contingency plan. I see instruction to notify a supervisor or <br /> maintenance for some of the potential system upsets, but under what circumstances would the <br /> contingency plan be activated?Or, if it's a case by case,who makes the call to do so? Is it that <br /> supervisor or maintenance staff they are required to notify? <br /> Let me know if you have any questions. <br /> Best, <br /> Lynsey Sammons <br /> Registered Environmental Health Specialist <br /> Cell: (209) 616-3067 <br /> Office: (209)468-3420 <br /> 2 <br />