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#38 — Resolved #48—Resolved. The modified contingency plan being posted on site will be verified at the next Hazardous Waste inspection. Underground Storage Tank (UST) inspection: • #2—Resolved • #3—Resolved • #5—Resolved • #10—Resolved • #13—Resolved • #53—Resolved • #56 & 59 —These two are very closely related. Please provide an updated RTC statement for each that takes into consideration our conversation yesterday and my notes below. Make sure to address your plan for avoiding these issues in the future and the requirement to maintain records on site for 36 months. o I spoke with the program lead about this and she actually had some really good insight that I wanted to share with you. One of the requirements for all UST facilities is to keep a written record of all alarms and at[ responses to those alarms. Since the DO reports require documentation of compliance issues and a response from the facility, we usually use the DO reports to meet this requirement but having this written record and having DO reports meet all requirements are actually two separate things. So yes, there are issues with the DO reports — but ultimately, the separate issue is that now the facility is not meeting the requirement to have a written record of alarms/responses. It might be a good idea to create a template with days 1-31 for each month with space to write in alarms and responses that you can stick on a clipboard or in a binder or wherever. Every morning Mohammad or whoever is on site that day can write down any alarms that printed out overnight and then write down any that occur during their shift. To be clear, this is NOT something the DO would fill out— it would be your employees. This would ensure that you all know if/when alarms are happening so that you don't rely so heavily on your DO to fulfill this requirement. It would allow you to easily identify if alarms are being missed by the DO and also serve as great training for your staff on appropriate responses to alarms. They may not knowwhat to do the first time they write down a Fuel alarm or a PLLD shutdown alarm, but after they see it 2-3 times and they can easily look at the previous month to see what the appropriate response was Last time this alarm came up, it'll become routine. We've seen other sites do this and have it workvery smoothly after the first few months of the learning curve. o I also spoke with the program lead about this since you sent all the work orders you have, and a few alarms are still unexplained. This ties in heavily with my note above. Having that alarm log that your staff is responsible for maintaining would make it much simpler to tie work orders to alarms to ensure that all alarms are being responded to appropriately. Your RTC statement for this one could indicate that you aren't able to locate documentation of responses to all alarms but that you have a plan now and describe your plan. o Here is the public records link we talked about: httoc•//tfweb sjgQv.org/FHD/Wetcome acox-If it helps, here's a quick step-by-step for navigating the public records. Start by clicking the link to "Browse EHD Program Records by Address" link. Then clickthe second folder labeled "EHD Program Facility Records by Street Name". This is where it gets weird —You first took for the street name, then the street number. Since this facility's address is 6131 Pacific you would start by scrolling down and clicking the link for "P", then scroll down until you see "Pacific". Click the link for "Pacific" and then scroll down until you see 6131. It's strange because all address that start with 1 come first (everything in the 100's and everything in the 1000's) before going to addresses that start with 2 (everything in the 200's and everything in the 2000's). So, you have to scroll alt the way past every address that starts with 1-5 to find 6131. • #69 Resolved Best,