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<br /> <br /> <br /> <br /> <br /> 2 <br />to prevent discharges; discharge procedure protocols; applicable pollution <br />control laws, rules, and regulations; general facility operations; content of the <br />facility SPCC plan; and annual discharge prevention briefings for oil -handling <br />personnel to assure adequate understanding of the SPCC plan. Provide proof of <br />correction to the EHD. <br />33 <br />Ensure that the SPCC plan adequately addresses the following security <br />measures: appropriateness of security lighting. Provide proof of correction to <br />the EHD. <br />47 Ensure that the SPCC plan discusses compatibility of petroleum containing bulk <br />storage containers. Submit proof of correction to the EHD. <br />54 <br />Ensure that the SPCC Plan adequately discusses facility's procedures to test and <br />inspect aboveground/bulk storage containers in accordance with all applicable <br />industry standards. This discussion must <br />include, but not be limited to, inspection/testing schedule/frequency, and <br />personnel qualifications. Submit proof of correction to the EHD. <br />59 <br />Ensure the SPCC Plan adequately addresses overfill prevention methods, <br />including a description of the devices or systems in place for each container to <br />prevent overfills and regular testing of these devices. Provide proof of correction <br />to the EHD. <br />74 Immediately submit a complete and adequate tank facility statement or a <br />business plan. Submit proof of correction to the EHD. <br /> <br />In response to SJCEHD’s inspection, Terracon has been contracted to assist Escalon <br />Premier Brands with the correction of the above identified violations. Terracon will <br />complete an initial on -site assessment of the facility’s regulated oil storage and handling <br />activities. Following the assessment, Items 10 through 59 will be addressed by <br />preparing an updated Spill Prevention, Control, and Countermeasure (SPCC) Plan in <br />conformance with 40 CFR 112 . As required by 40 CFR 112, the SPCC Plan will also be <br />reviewed by a Registered Professional Engineer (P.E.). Item 74 will be amended by <br />adjusting the reportable quantities within CERS for the Hazardous Materials Business <br />Plan (HMBP), including the tank facility statement. Following completion of the corrective <br />action items, a Return to Compliance Certification form will be completed and submitted <br />to SJCEHD. <br /> <br />Sincerely, <br />Terracon Consultants, Inc. <br /> <br /> <br />Hilary Kane Travis Knisley, P.E. <br />Project Scientist Department Manager / Senior Associate <br /> <br />Attachments: Return to Compliance Certification <br /> CP22 – AST Non-Qualified Inspection Report, Dated December 3, 2024, <br /> Amended December 9, 2024 DRAFT