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October 20, 2017 <br /> Page 6 of 6 <br /> RESPONSE: Testing has been scheduled and will be included in the revised SPCC plan. <br /> 724 CFR 112.8(d)(4) Failed to regularly inspect aboveground valves, piping, and appurtenances. <br /> Copies of inspection and testing records for the last three years were not found on site. All aboveground <br /> valves, piping, and appurtenances shall be regularly inspected. Immediately inspect aboveground valves, <br /> piping, and appurtenances and ensure inspections are done regularly, or provide equivalence as allowed <br /> by CFR 112.7(a). <br /> RESPONSE: Testing is scheduled and records will be kept on file for three years. <br /> 725 CFR 112.8(d)(4) Failed to conduct integrity and leak testing on buried piping any time it is worked <br /> on. No test results were available for piping integrity. Buried piping shall be tested for integrity and <br /> leaks at the time of installation, modification, construction, relocation, or replacement. Immediately <br /> perform integrity and leak testing of this piping and ensure that piping is tested when required, or <br /> provide equivalence as allowed by CFR 112.7(a)(2). <br /> RESPONSE: Testing is scheduled and records will be kept on file. <br /> 4010 40 CFR 112.7 SPCC plan lacks full approval of management at a level of authority to commit the <br /> necessary resources to implement the Plan. <br /> The management approval section of the SPCC plan is unsigned. The Spill Prevention, Control, and <br /> Countermeasure (SPCC) Plan must have the full approval of management at a level of authority to <br /> commit the necessary resources to fully implement the Plan. Immediately obtain required management <br /> approval for the SPCC Plan for this facility. <br /> RESPONSE: SPCC Plan is scheduled for revision and will be updated with this inform®attion. <br /> RECEIED <br /> V <br /> OCT 232017 <br /> ENVIRONMENTAL HEALTH <br /> DEPARTMENT <br /> Think Inside the Triangle"® <br />