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Page 1 3 <br />impracticable on an SPCC Plan or sections of one <br />that is PE certified. Corrective Action: As <br />stated on page 8 of the existing SPCC Plan under <br />Section VII CONTAINMENT, secondary containment <br />for this area is provided by the Storm Water <br />Retention Pond. Section VII B states that "The <br />probability of a spill from this facility <br />reaching the navigable water body is negligible. <br />A release or spill occurring at this facility, <br />if undetected and unmitigated, would enter the <br />storm drainage system and would gravity -flow, or <br />be automatically pumped into the storm water <br />retention pond and be contained there." <br />Management of the storm water retention pond <br />extraction system is a manual process and may <br />not proceed without approval of the DESJC <br />Environmental Office and a water sample being <br />collected. This process will prevent a spill <br />from leaving the facility. Additional <br />information is available in the Storm Water <br />Pollution Prevention Plan for the DDJC Tracy <br />Facility. Finally, DESJC considers it very <br />unlikely that the entire drum inventory might <br />rupture at any given time. The Depot does <br />provide secondary containment spill pallets for <br />individual drums spills at the storage site. <br />(7) Item 32 - Failed to (1) train personnel on <br />discharge prevention; (2) designate a person to <br />be accountable for discharge prevention; of (3) <br />schedule discharge prevention briefings at least <br />annually. Corrective Action: The oil -handling <br />personnel at DDJC that are required by 40 CFR <br />112.7(F) to have training in the operation and <br />maintenance of equipment and discharge <br />prevention procedure protocols in order to <br />prevent discharges are the fork lift operators <br />(material handlers) and supervisors of Area C <br />(POL drum storage area)and the HAZMAT employees. <br />These personnel are trained to operate material <br />handling equipment specifically to prevent <br />discharges as well as First Responder training <br />which outlines spill response protocols. The <br />training records are kept in a database in the <br />DDJC Training Office. The plan will be amended <br />to indicate the correct location of the training <br />records. Also note that the Hazardous Waste <br />