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2. APSA#517- Summary and Response <br /> a. Copies of the quarterly inspection for the above ground containers were <br /> not found on site. Inspections and tests must be conducted in accordance <br /> with the procedures developed in the SPCC Plan. <br /> i. Response- In 2010 the SPCC Plan was not in effect. The <br /> introductory letter at the front of the Plan states that the SPCC Plan <br /> is a replacement for the PPERM Plan. Inspections were conducted <br /> under the facility PPERM Plan, now retired. Copies of the facility <br /> PPERM Plan quarterly inspections conducted since the last CUPA <br /> visit in 6/15/2010 are attached. Blank forms for the year 2010 are <br /> removed from the SPCC binder to prevent future <br /> misunderstanding. <br /> b. Records of these inspections and tests must be signed by the appropriate <br /> supervisor or inspector and kept on site with the SPCC Plan for a period of <br /> three years. <br /> i. Response-Review of the PPERM Plan inspections shows <br /> signatures by the inspector. Quarterly inspections from the SPCC <br /> Plan are signed. <br /> c. Immediately begin conducting the quarterly inspection, locate any copy of <br /> all inspection and testing records for the last three years and maintain them <br /> on site. <br /> i. Response- Quarterly inspections are on-going in the SPCC Plan <br /> from 2011 forward and records maintained. Copies attached. <br /> ii. Quarter 1 and Quarter 2 of 2011 from the PPERM Plan are <br /> transposed to the new SPCC Plan. <br /> d. STATUS: Complete <br /> e. Attached Documents <br /> i. Quarter 3 2010 PPERM Inspection, dated 7/23/2010 <br /> ii. Quarter 4 2010 PPERM Inspection, dated 12/24/2010 <br /> iii. Quarter 1 SPCC Inspection dated 3/20/2011 <br /> iv. Corrective Actions taken in response to the 2011 Quarter 1 <br /> inspection. <br /> v. Quarter 2 SPCC Inspection dated 6/20/2011. <br /> vi. Corrective Actions taken in response to the 2011 Quarter 2 <br /> inspection. <br />