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RCENE <br /> as allowed by CFR 112.7(a)(2).Submit proof of correction to the EHD. AUG 2 32016 <br /> ENVIRONMENTAL <br /> This is a Class II Violation. HEALTH DEPARTMENT <br /> Owens' Response/Corrective Action: <br /> Owens is currently performing daily inspections of its hazardous waste used <br /> oil tank system. A copy of the inspection log is included as Exhibit 7. <br /> Item 717: CFR 112.8(c)(8)(v) Failed to regularly test liquid level sensing devices to ensure <br /> proper operation. <br /> Accordi ng to Mr. Boscacci, the existing liquid level sensing devices have not been tested for <br /> all existing tanks. Procedures and frequency of testi ng for these devices were not addressed <br /> inthe Spill Prevention, Control, and Countermeasure (SPCC) plan. Liquid level sensing devices <br /> must be installed in accordance with CFR 112.8 and shall be regularly tested to ensure proper <br /> operation . Immediately conduct all necessary testing of liquid level sensing devices, or <br /> provide equivalence as allowed by CFR 112.7(a)(2).Submit proof of correction to the EHD. <br /> This is a Class II Violation. <br /> Owens' Response/Corrective Action: <br /> Please refer to the following section in the SPCC Plan: Integrity Testing- 112.8 <br /> (c)(6). The text states Additional tank inspections are performed in accordance <br /> with the standards used to manufacture the tank or as specified by the <br /> manufacturer. Level alarms and other instrumentation are inspected annually, <br /> or per manufacturer's recommendations. This section of the SPCC Plan will be <br /> revised to more explicitly include liquid level sensing devices in the annual <br /> preventive maintenance schedule for testing. <br /> Training <br /> Item 614: CFR 112.7(f)(1) Failed to train personnel on discharge prevention. <br /> Oil handling personnel were not adequately trained. Thirty people were trained in 2010 <br /> compared to the most recent training during,which only two people were trained.The last <br /> spill prevention briefing was held in 2013. At a minimum, oil handling personnel shall be <br /> trained in the operation and maintenance of equipment to prevent discharges; discharge <br /> procedure protocols;applicable pollution control laws, rules, and regulations;general facility <br /> operations; and the contents of the Spill Prevention, Control, and Countermeasure Plan. <br /> Immediately provide this training to all oil handling personnel and submit a copy of the <br /> 19 <br />