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Page 1 <br /> Stockton Steel - Return to Compliance <br /> Attachment 1 <br /> June 13, 2019 <br /> Itam#and Finding Corrective Action Taken <br /> 301 -The portable generators in the SPCC plan are described as Corrected—The SPCC Plan no longer classifies these <br /> operational equipment.The diesel belly tanks of the generators fall tanks as oil-filled operational equipment.The tanks are <br /> under the definition of bulk storage tanks.The SPCC plan must nowclassified as bulk storage containers,specifically, <br /> address the requirements of bulk storage tanks for the diesel belly portable containers.The containers are now subject to <br /> tanks throughout the plan. monthly and annual inspections and full secondary <br /> containment requirements. <br /> The following sections of the SPCC Plan were updated <br /> or added to accurately reflect the requirements for <br /> these tanks. <br /> Append A—Oil Inventory and Planned Response <br /> Append C—Site Map(updated to reflect the new <br /> equipment names(PC-007-014). <br /> Append F—Monthly Facility Inspection Checklist <br /> Append F-1—Annual AST and Portable Container <br /> Inspection Checklist(NEW) <br /> Append F-2—Incoming Portable Container Inspection <br /> Checklist(NEW) <br /> Append J—Bulk Storage Container Integrity Testing <br /> and Inspection <br /> 604-The SPCC plan describes two 55 gallons drums of used oil in Corrected—Oil Inventory Table(Appen A)and the Site <br /> the maintenance area of the facility.An additional 55-gallon container Map(Appen C)have been updated.The words <br /> of automatic transmission oil was observed in the area. "Automatic Transmission Fluid'were added to the <br /> Maintenance Area section of both appendices. <br /> 618-The facility inspections described in the SPCC plan are not Corrected—Monthly inspections have been restarted. <br /> being conducted,as stated by facility personnel. <br /> 630-CFR 112.7(k)The SPCC plan exempts listed operational Corrected—The SPCC plan's Contingency Plan for Oil <br /> equipment from the general secondary containment requirements and Spills(Appendix A-1)was updated to include the <br /> chose to follow the alternative requirements to general secondary applicable requirements of Part 109. Because this <br /> containment for operational equipment.The contingency plan in the contingency plan is developed for relatively small <br /> SPCC plan does not include an oil spill contingency plan following the containers at a fixed facility,and because this is not a <br /> provisions of part 109 of chapter 40 of the Code of Federal plan to be used by"state, local or regional"response <br /> Regulations. agency,some parts of a typical Part 109 plan(i.e. <br /> Note: Most of the oil-filled operational equipment was observed with interagency communication, plans for'major disasters', <br /> general secondary containment. etc.)are not included in the updated contingency plan. <br /> The SPCC plan contains the following statement which <br /> is signed by the Plant Manager. Stockton Steel believes <br /> that this satisfies the requirement for a commitment of <br /> manpower,equipment,and materials required to <br /> expeditiously control and remove any quantity of oil <br /> discharged that may be harmful. <br /> The plan has been approved bytop management <br /> and has been fully implemented.In the evert of an <br /> oil spill, Stockton Steel will make available all <br /> manpower, equipment and materials necessary to <br /> expedtiouslycontrol and remove any quantify of oil <br /> discharge that may be harmful to the environment. <br />