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RECEIVE[) <br /> AUG 2 32016 <br /> ENVIRONMENTAL <br /> HEALTH DEPARTMENT <br /> not practicable, periodic integrity testing shall be performed on bulk storage containers, and <br /> periodic integrity and leak testing shall be performed on the valves and piping. Immediately <br /> amend the SPCC Plan and submit a copy of the changes to the EHD. <br /> This is a Class II violation. <br /> Item 616: CFR 112.7(f)(3) Failed to schedule and conduct discharge prevention briefings at <br /> least annually. <br /> Discharge prevention briefings are not scheduled at least once a year.According to William <br /> Boscacci,the last spill prevention briefing was held in 2013. Discharge prevention briefings <br /> for oil handling personnel must be scheduled and conducted at least once a year to assure <br /> adequate understanding of the SPCC Plan for that faci lity. Such briefings must highlight and <br /> describe known discharges or failures, malfunctioning components, and any recently <br /> developed precautionary measures. Immediately schedule and conduct a discharge <br /> prevention briefing,ensure that they are scheduled and conducted at least once a year. <br /> This is a Class II violation. <br /> Owens' Response/ Corrective Action for Items #101, 302, 604, 605, 610, and <br /> 616: <br /> The Facility contracted with a Professional Engineer to review and amend its <br /> Spill Prevention, Control, and Countermeasure plan to address technical <br /> amendments since the previous Plan was completed. A copy of the updated <br /> plan will be forwarded to the Health Department by August 22, 2016. <br /> Secondary Containment / Diked Areas <br /> Item 609: CFR 112.7(c) Faiiedto provide secondary containment,diversionary structures,or <br /> equipmentto prevent discharge. <br /> According to the site inspection and according to the reviewed tank assessment report, <br /> prepared by Conestoga-Rovers &Associates (dated August 15, 2012), the 450-gallon and 1750- <br /> gallon waste oil tanks appear to have insufficient secondary containment. The reviewed waste <br /> oil tank assessment, indicated the oil/water separator pit used as secondary containment for <br /> the 1,750-gallon tank "doesn't appear to meet the requirements of 22 CCR 66265.193 and it <br /> didn't appear to be lined and cracks were observed in concrete above the liquid level in the <br /> pit". Furthermore,according to the same tank assessment, the 450-ga Ilon waste oil tank has <br /> no secondary containment. Also,the oily waste mixture, referred to as "biosol' and used in <br /> the glass making process, discharges directly from the glass making area into an unlined area <br /> where it pools and subsequently flows into the respective in-ground oil water separators. <br /> Also, standing oily liquid was noted next to the oil filled equipment,and no sized or general <br /> secondary containment provisions were observed at the time of inspection next to the said <br /> 15 <br />