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Robert Lopez [EHD] <br /> From: Robert Lopez [EHD] <br /> Sent: Wednesday, September 22, 2021 3:15 PM <br /> To: pheintz@pacesupply.com' <br /> Subject: FW: PR0546986; Pace Supply Corp. Hazardous Materials Program Compliance Review <br /> Attachments: Emergnecy Response Contingency Plan Template 012220.pdf; Hazard Categories CERS <br /> Guidance.pdf; HMBP Guidelines.pdf; Map Guidance and Forms.pdf; Sample Training <br /> Record Form 110719.pdf <br /> Paul Heintz, <br /> The compliance review was amended to remove the comment "The training plan does not address the frequency of <br /> training, such as training for all new employees and annual training"from violation#8. This amended review replaces <br /> the initial review. <br /> I have reviewed the CERS submittal and compliance status and have found the following issues: <br /> • Violation #5—the hazardous materials inventory is not complete/up to date. <br /> 1. Acetylene -the maximum daily amount is wrongly reported at 20 cubic feet vs. the greater than 200 <br /> cubic feet observed;the average daily amount element has not been completed,the storage pressure is <br /> wrongly reported as "ambient"vs. "above ambient", and the obsolete federal hazard categories have <br /> not been updated. <br /> 2. Thread oil—the maximum daily amount is wrongly reported as 60 gallons vs. at least 150 gallons <br /> observed; the size of the largest container, average daily amount, storage pressure, and storage <br /> temperature elements have not been completed, and the obsolete federal hazard categories have not <br /> been updated. <br /> 3. Oxygen, compressed—the maximum daily amount is wrongly reported as 20 cubic feet vs. at least 556 <br /> cubic feet observed;the size of the largest container, average daily amount, storage pressure, and <br /> storage temperature elements have not been completed, and the obsolete federal hazard categories <br /> have not been updated. <br /> 4. Argon -the maximum daily amount is wrongly reported as 32 cubic feet vs. at least 7,584 cubic feet <br /> observed; the size of the largest container, average daily amount, storage pressure, and storage <br /> temperature elements have not been completed, and the obsolete federal hazard categories have not <br /> been updated. <br /> 5. Propane-the maximum daily amount is wrongly reported as 20 gallons vs. at least 178 gallons <br /> observed; the average daily amount element has not been completed,the storage pressure is wrongly <br /> reported as "ambient"vs. "above ambient", and the obsolete federal hazard categories have not been <br /> updated. <br /> • Violation #6,the site map does not show or address the following: <br /> 1. Internal roads. <br /> i <br />