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AURA
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<br /> 7 ` �r R 112.7(e)Failed to conduct inspections or maintain records for 3 years_
<br /> k ,,fti �^ stia The inspection forms being used are not the forms provided by Spill Prevention,
<br /> Control,and Countermeasure
<br /> Fi � ,,� •,r�` hr �. e;. (SPCC)Plan,and in some instances,do not contain the same information.Inspections
<br /> t-tt :Y.rp;:.„.. and tests must be conducted and stored in accordance with the written procedures
<br /> nen? �' developed for this facility in the SPCC Pian.Immediately begin conductingall
<br /> � 'nspections and tests in accordance with the procedures in the SPCC Plan,oramend
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<br /> � xswsfi� he Pian and have it recertified by a Professional Engineer to accurately reflect the
<br /> inspection procedures currently followed at the facility.
<br /> rhe monthly inspections do not include the generator,drums,and compressors.
<br /> nspections and testing shall be conducted on all aboveground liquid petroleum
<br /> y rs jr , 7ontainers 55 gallons and larger,including the two generators,four compressors,the
<br /> 50 gallon used oil tank,and all 55 gallon drums of oil.Records of these inspections
<br /> �,a:•�; ,,. � �t^�:'t: .;ryas”:
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<br /> PCC Plan has been updated and new form accounts nd tests shall be signed by the appropriate supervisor or inspector and kept on site
<br /> for all necessary elements required for inspection. ith the Spill Prevention,Control,and
<br /> I.T. „'Ri y,3"�'''LZ:` y.Y,,• ry tI
<br /> Included is a copy of the old form which was in use ountermeasure(SPCC)Plan for a period of three years.immediately begin necessary
<br /> (depicting intent of CALAMCO to monitor and inspect :esting and inspections for all Aboveground Petroleum Storage Act regulated
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<br /> on a monthly basis),a copy of a 2 hour plant reading orrtainers and maintain on site with the SPCC Plan.
<br /> inspection(which includes inspections for leaks).
<br /> , v "ate ty; CFR 112.7(f)(1)Failed to train personnel on discharge prevention.
<br /> lm,, to ii handling personnel were not trained.At a minimum,oil handling personnel shall be
<br /> trained in the operation and maintenance of equipment to prevent discharges;
<br /> � ischarge procedure protocols;applicable pollution control laws,rules,and
<br /> i sP° raining records attached show training on spill egulations;general Facility operations;and the contents of the Spit!Prevention,
<br /> countermeasures. Moving forward,training will be Control,and
<br /> fyr+s ` .r.�s4 2 Viz; ` provided to address elements of the SPCC Plan, Countermeasure Plan.Immediately provide this training to all oil handling personnel
<br /> Discharge Prevention(Attached is a copy of the and submit a copy of the training log to the EHD.
<br /> updated training agenda). Also attached is updated This is a Class If violation.
<br /> training forspecific individuals who handle oil.
<br /> CFR 112.7(f)(3)Failed to schedule and conduct discharge prevention briefings at least
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<br /> Discharge prevention briefings are not scheduled at least once a year.Discharge
<br /> prevention briefings for oil handling personnel must be scheduled and conducted at
<br /> east once a year to assure adequate understanding of the SPCC Pian for that facility.
<br /> In addition to the Discharge Prevention Training for Such briefings must highlight and describe known discharges or failures,malfunctionin
<br /> Oil Handling Personnel,Discharge Briefings will be components,and any recently developed precautionary measures.Immediately
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<br /> �'�`- --'' ;�•r$�;F �n��,-rincluded/part of the discussion and documented via schedule and conduct a discharge prevention briefing,,ensure that they are scheduled
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<br /> sign in sheet,at a minimum once per year. Please see nd conducted at least once a year.
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<br /> ;:° attached training records.
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