COMPLIANCE INFO_PRE 2019 - Laserfiche WebLink

Home Browse Search

R .ULIvILL) October 20, 2017 OCT 2 3 2017 Page 3 of 6 ENVIRONMENTAL- HEALTH 301 CFR 112.5(a) Failed to amend Plan as necessary. DEPARTMENT According to Mr. Alonzo, the drum of petroleum storage that was described in the SPCC plan is no longer onsite. The Spill Prevention, Control, and Countermeasure (SPCC) Plan must be amended when there is a change in the facility design, construction, operation, or maintenance that materially affects its potential for a discharge, within 6 months of the change, and implemented as soon as possible, not later than 6 months following preparation of the amendment. Immediately make all necessary amendments to the SPCC Plan to accurately represent the procedures and policies currently in place at the facility. RESPONSE: We are currently in the process of revising our SPCC plan with Strandberg Associates in November 2017 to reflect this violation. 601 CFR 112.7 Failure of Plan to fulfill basic requirements including a cross-referencing section. The Spill Prevention, Control, and Countermeasure (SPCC) Plan does not follow the order or requirements in 40 CFR Part 112, and a cross-reference was not provided. If you do not follow the sequence specified in 40 CFR 112 for the Plan, you must prepare an equivalent Plan and supplement it with a section cross-referencing the location of requirements in 40 CFR 112 and the equivalent Plan. Immediately amend the SPCC Plan to include a cross-reference or to follow the required sequence. RESPONSE: We are currently in the process of revising our SPCC plan to reflect this violation. 603 CFR 112.7(a)(3) Failed to adequately describe the physical layout of the facility in the Plan. The facility diagram did not include the specific locations of the tanks, the tank contents, buried piping, or the location of drums. The Spill Prevention, Control, and Countermeasure (SPCC) Plan shall include a facility diagram which must mark the location and contents of each fixed storage container and the storage area where mobile or portable containers are located. It must identify the location of and mark as "exempt" underground tanks. It must also include all transfer stations and connecting pipes, including intra-facility gathering lines. Immediately update the facility diagram to include all of the required information. Submit a legible copy of the updated facility diagram to the EHD for review. RESPONSE: We are currently in the process of revising our SPCC plan to reflect this violation. 609 CFR 112.7(a)(3vi), 112.7(a4) Plan failed to adequately contain procedures for reporting a discharge. The plan failed to include the cleanup contractor information, the EHD, and OES addresses were outdated, and the number included for OES has been disconnected. The Spill Prevention, Control, and Countermeasure (SPCC) Plan shall include: - contact list and phone numbers for the facility response coordinator, National Response Center, cleanup contractors, and all appropriate Federal, State, and local agencies. Immediately amend the SPCC Plan to include all required information. RESPONSE: We are currently in the process of revising our SPCC plan to reflect this violation. Think Inside the Triangle"'