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Attachment 3. LLNL Violation Tracking Spreadsheet-Above-ground Petroleum Storage Act(APSA) November 2018 LLNL Site 300 Green highlight indicates violation acknowledged and accepted. Corrective action provided in the Violation Response/Completion Date column. Orange highlight indicates violation disputed. Yellow-Open issue, additional action needed. VIOLATION RESPONSE VIOLATION TOTAL VIOLATION REGULATION CITED COUNT REPORT ITEM # VIOLATION CLASS VIOLATION/Discovery INSPECTION REPORT ACTION ITEMS CORRECTIVE ACTION STATUS COMPLETION DATE 105 CFR 112.1(b)(3), 112.2 FAILURE TO PROPERLY CLOSE TANKS WHEN MAKING A CLAIM OF PERMANENTLY CLOSED CFR 112.1 (b)(3), 112.2 Failure to properly close tanks when making a claim of permanently closed. A portable generator with a diesel tank of a capacity of over 55 gallons was said to be permanently closed. The generator was located in the parking area of the 875 building.The generator's diesel tank is not in use but has not been properly closed.The tank was missing a sign Violation accepted. Corrective action of conspicuously stating that it is a permanently closed container and denoting the date of closure. When a tank is not in use. it must be installing signage took place on 11/27/18 permanently closed by meeting the following conditions: (see Attachment-5_Signage Close Up View 1 Minor -M�move all liquid and sludge from each container and connecting line and Attachment-6_Signage Full View. -disconnect and blank off all connecting lines and piping have from the tank -lose and lock all valves 875GDE05 generator and associated portable container 875TFBD05 relabeled -0ost a sign conspicuously stating that it is a permanently closed container and denoting the date of closure "SPCC Permanently Closed" with date of closure 4/15/16. 203 CFR 112.3 FAILURE TO IMPLEMENT THE SPCC PLAN LLNL requests SJCEHD to rescind this violation based on the information provided in Attachment-7—STI SP001—Leak Testing Requirements, and the following rationale: CFR 112.3 Failure to implement the SPCC Plan. Table 5.5 "Table of Inspection Schedules" The SPCC plan calls for the replacement of the stainless-steel single-walled fuel containers on the mobile refuelers after 17 years in accordance Implement the plan as written or submit evidence that the Fuel permits periodic testing in conjunction with 2 Minor with the STI SP-001 standards.The 100 gallon stainless-steel single-walled mobile refueler tank is over 17 years old and has not been replaced.A Tank Pressure Test meet the requirements of the SP-001 leak testing Category 3 stainless steel tanks passing "fuel tank pressure test" dated 11/19/2018 was available for review for the tank identified as G7103595.The owner or operator or an standard. every 17 years. Monthly inspections are onshore or offshore facility subject to this section must prepare in writing and implement a Spill Prevention Control and Countermeasure Plan being conducted and a leak test was conducted (and passed, see Attachment- (hereafter SPCC Plan or "Plan")," in accordance with § 112. 7 and any other applicable section. 8—Leak Test Results) in accordance with STI SP001 section 9.0. Therefore, LLNL feels this violation was issued erroneously. 618 CFR 112.7(e), 112.8(c)(6) FAILED TO KEEP RECORDS OF PROCEDURES, INSPECTIONS,OR INTEGRITY TESTS FOR THREE YEARS Violation accepted. Corrective action of conducting annual inspections for 879TF001, 879TF002, 875TF003and 875TF002 occurred on 11/27/18 (see Attachment- CFR 112.7(e), 112.8(c)(6) Failed to keep records of procedures, inspections, or integrity tests for three years. 9 cur TF003 1/2 /18TF0(s e A tachm 875 Copies of annual inspection records were not found on site for tanks 879TF001, 879TF002, 875TF003, 875TF002 and 875TFBD04. SPCC plan calls Immediately locate a copy of all inspection and testing records TF002 Annual SPCC Inspections). 3 Class II for the last three years, maintain them on site. and submit for monthly and annual inspections per STI SP001 standards. Inspections and tests must be conducted in accordance with the written procedures developed in the Spill Prevention, Control, and Countermeasure (SPCC) Plan. Records of these inspections and tests must be signed by the copies to the EHD. In regards to SPCC regulated piece of appropriate supervisor or inspector and kept on site with the SPCC Plan for a period of three years. equipment 875TFBD04, per section 6.7 of the STI SP001, an annual is not required because this is a portable container and not a tank (see Attachment- 10—STI SP001—Periodic AST Inspections). 3 APSA violations, 3 corrected as of 11/27/2018 Aboveground Petroleum Storage Act Inspection Report