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-f One black metal 55 gallon drum of Dynalube was observed in area D5 without sufficient secondary containment. <br /> Table 1 of the SPCC plan states that the secondary containment is the furnace building for this area.The doorway <br /> of the D5 area is sloped to allow releases from the building. <br /> Portable oil storage containers must be positioned or located to prevent a discharge and shall be furnished with a <br /> secondary means of containment sufficient to contain the capacity of the largest single container with sufficient <br /> freeboard to contain precipitation. Immediately provide sufficient secondary containment for all portable containers <br /> at this facility, or provide equivalence as allowed by CFR 112.7(a)(2)and submit proof to the EHD. <br /> This is a Class II violation. <br /> Response: <br /> a. Corrected on site. <br /> b. We have replaced the secondary containment pallet with a 77-gallon sized capacity. See photo <br /> (Figure 6) in Appendix C. <br /> c. We have oil storage cabinets with built-in secondary containment designated on our updated <br /> SPCC plan for this area D7. The black drum observed at the time of the inspection is now stored <br /> inside this cabinet. See photo (Figure 7) in Appendix C <br /> d. We have oil storage cabinets with built-in secondary containment designated on our updated <br /> SPCC plan for this area D7. The black drum observed at the time of the inspection is now stored <br /> inside this cabinet. See photo (Figure 7) in Appendix C <br /> e. Area D3 is a cinder-block room with a berm at the entrance,this room provides a secondary <br /> containment capacity of approximately 572 gallons. Individual secondary containment pallets for <br /> drums stored inside this room are not necessary. See photo (Figure 8) in Appendix C. <br /> f. The Dynalube 55 gallon drum is now on a secondary containment. See photo (Figure 9) in <br /> Appendix C. <br /> If you have any questions regarding this submittal, please contact Owen's Environmental <br /> Manager, Bill Boscacci at 567-336-8269. <br /> jjAppenclices: <br /> ncerely, <br /> hn Granadosant Manager <br />