Laserfiche WebLink
RECEIAT) <br /> October 20, 2017 OCT 2 3 2017 <br /> Page 4 of 6 <br /> ENVIRONMENTAL HEALTH <br /> DEPARTMENT <br /> 612 CFR 112.7(c) Plan failed to include secondary containment, diversionary structures, or equip to <br /> prevent discharge. The SPCC plan stated that the 55 gallon used oil drums "containment has not been <br /> designed to provide sufficient "available capacity" for a spill." Secondary containment was observed for <br /> the two used oil drums in the form of overpack drums. The SPCC plan needs to discuss the secondary <br /> containment for each aboveground petroleum storage container larger than 55 gallons. Immediately <br /> update the SPCC plan to discuss the secondary containment for all aboveground petroleum storage <br /> containers larger than 55 gallons. <br /> RESPONSE: We are currently in the process of revising our SPCC plan to reflect this violation. <br /> 618 CFR 112.7(e), 112.8(c)(6) Failed to conduct inspections or integrity tests or maintain records for 3 <br /> years. <br /> Copies of inspection and testing records for the last three years were not found on site. Inspections and <br /> tests must be conducted in accordance with the written procedures developed in the Spill Prevention, <br /> Control, and Countermeasure (SPCC) Plan. Records of these inspections and tests must be signed by the <br /> appropriate supervisor or inspector and kept on site with the SPCC Plan for a period of three years. <br /> Immediately locate a copy of all inspection and testing records for the last three years, maintain them on <br /> site, and submit copies to the EHD. <br /> RESPONSE: We are currently in the process of revising our SPCC plan to reflect this violation. <br /> Inspections and test will be scheduled and records will be kept for a period of three years. Weekly <br /> inspection logs kept on file and submitted to EHD. <br /> 619 CFR 112.7(f)(1) Failed to train personnel on discharge prevention. <br /> Oil handling personnel were not trained. At a minimum, oil handling personnel shall be trained in the <br /> operation and maintenance of equipment to prevent discharges; discharge procedure protocols; <br /> applicable pollution control laws, rules, and regulations; general facility operations; and the contents of <br /> the Spill Prevention, Control, and Countermeasure Plan. Immediately provide this training to all oil <br /> handling personnel and submit a copy of the training log to the EHD. <br /> RESPONSE:Training is scheduled and in process and will be sent to EHD when available. <br /> 622 <br /> CFR 112.7(f)(3) Failure to conduct spill prevention briefing for oil-handling personnel. <br /> Discharge prevention briefings are not scheduled at least once a year. Discharge prevention briefings for <br /> oil handling personnel must be scheduled and conducted at least once a year to assure adequate <br /> understanding of the SPCC Plan for that facility. Such briefings must highlight and describe known <br /> discharges or failures, malfunctioning components, and any recently developed precautionary measures. <br /> Immediately schedule and conduct a discharge prevention briefing, ensure that they are scheduled and <br /> conducted at least once a year. <br /> Think Inside the Triangle"'® <br />