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October 20, 2017 REG" EIVED Page 5 of 6 OF 2 3 2017 RESPONSE: Training is scheduled and will be conducted once a year. ENVIRONMENTAL HEALTH DEPARTMENT 711 CFR 112.8(c)(6) Failed to perform scheduled tank tests or inspections by appropriately qualified personnel. No integrity test results were available for any of the tanks onsite. Mr. Alonzo estimated that the fuel tanks were installed in either 1998, or 1999. The SPCC plan stated that integrity testing is required to be conducted every ten years for these tanks. Each aboveground container shall be tested and inspected for integrity on a regular schedule and whenever repairs are made. The qualifications of personnel performing tests and inspections, frequency and type of testing and inspections that take into account container size, configuration, and design shall be determined in accordance with industry standards. Examples of these integrity tests include, but are not limited to: visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other systems of non-destructive testing. Comparison records and other records of inspections and tests must be maintained on site. Immediately conduct the necessary testing and submit a copy of the test results to the EHD, or provide equivalence as allowed by CFR 112.7(a)(2). RESPONSE: Test and inspection has been scheduled and copies will be mailed when completed. 714 CFR 112.8(c)(8)(i-iv) Failed to provide each container with a high level monitoring device. The 55 gallon drums of used oil onsite were not observed with high liquid monitoring devices. The SPCC plan did not discuss any high liquid monitoring devices for any tank. At least one of the following devices must be installed in each container: - High liquid level alarm with audible or visual signal High liquid level pump cutoff device set to stop flow at a predetermined content level Direct audible or code signal communication between the container gauger and the pumping station Fast response system, such as digital computer, telepulse, or direct vision gauge. If a direct vision gauge is being used for determining the liquid level of each tank, a person must be present to monitor gauges and the overall filling of the tanks. Immediately install an approved liquid level sensing device in accordance with CFR 112.8 and implement necessary procedures to ensure that the devices are fully functional and in use at all times during tank filling operations, or provide equivalence as allowed by CFR 112.7(a)(2). RESPONSE: A device will be installed or equivalence and updated on the SPCC Plan. 715 CFR 112.8(c)(8)(v) Failed to regularly test liquid level sensing devices to ensure proper operation. Liquid level sensing devices on the fuel tanks have not been tested. Procedures and frequency of testing for these devices were not addressed in the Spill Prevention, Control, and Countermeasure (SPCC) plan. Liquid level sensing devices must be installed in accordance with CFR 112.8 and shall be regularly tested to ensure proper operation. Immediately conduct all necessary testing of liquid level sensing devices, or provide equivalence as allowed by CFR 112.7(a)(2). Think Inside the Triangle"'_