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• #15 — Closed • #20 — Closed • #30 — Open o The training records submitted to not use the form required by Appendix I of the facility's SPCC Plan. An alternate form can be used but the SPCC Plan would need to be updated. o The training records provided are for a course titled, "OSHA Training: Storm Water Runoff & Spill Prevention". Please provide the content of the training to confirm all topics required for SPCC training are covered by the training. o All training records submitted pre -date the inspection. Based on observations during the inspection, additional training is needed. Provide all oil -handling personnel with SPCC training and submit training records that postdate the inspection. • #32 — Open o The training records submitted to not use the form required by Appendix I of the facility's SPCC Plan. An alternate form can be used but the SPCC Plan would need to be updated. o The training records provided are for a course titled, "OSHA Training: Storm Water Runoff & Spill Prevention". Please provide the content of the training to confirm all topics required for Annual Spill Prevention Briefings for oil -handling personnel are covered by the training. o All training records submitted pre -date the inspection. Based on observations during the inspection, additional training is needed. Conduct an annual spill prevention briefing for all oil -handling personnel that covers all required topics and submit training records that postdate the inspection. • #57 — Open o The forms used for the inspection records submitted do not match the forms required by Appendix G of the facility's SPCC Plan. The SPCC Plan specifies that the STI SP001 forms will be used, including: ■ STI SP001 Monthly Inspection Checklist ■ STI SP001 Bulk Tank & Portable Container Monthly Inspection Checklist ■ STI SP001 Annual Inspection Checklist. o The facility can use an alternate form, but the SPCC Plan would need to be updated. o Also, if the facility does want to use an alternate form, the one currently being used does not suffice. Multiple components of the AST system are not being inspected/tested as required. The STI checklists in the plan are a good guide for everything that needs to be inspected and documented. • #63 — Open o The RTC statement and photos address the staining but do not address the active leak observed at dispenser 2 during the inspection. • #78 — Closed was also able to process the most recent CERS submittals. The first two elements of the HMBP were accepted. However, based on violation #13 of the HMBP report, the training plan needs to be updated. The APSA information submitted also needs to be updated to reflect the most recent changes to the plan. Please let me know if you have any questions. Best, Lynsey Sammons Registered Environmental Health Specialist Cell: (209) 616-3067