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Color Code Legend:
<br />Green highlight - Violation acknowledged and corrected.
<br />Orange highlight - Request to rescind violation.
<br />Yellow highlight -Corrective action in progress.
<br />Attachment 2. LLNL Violation Tracking Spreadsheet - Aboveground Petroleum Storage Act (APSA)
<br />Inspection Date: September - October 2015
<br />LLNL Site 300
<br />SUMMARY OF VIOLATIONS
<br />(CLASS I, CLASS II, or MINOR- Notice to Comply)
<br />Violation Report
<br />Regulation/Code
<br />Remarks
<br />Inspection Report Action Item
<br />Status
<br />ttem a
<br />Violation Class
<br />2,
<br />201
<br />CFR 112.3(d)
<br />PLAN CERTIFICATION BY A PROFESSIONAL ENGINEER (PE) MISSING OR INCOMPLETE
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<br />CFR 112.3(d) Plan certification by a Professional Engineer (PE) missing or incomplete. The Professional Engineer (PE) certification is incomplete. The
<br />Create Sitewide SPCC Plan that includes PE certification.
<br />Violation ackowledged.
<br />facility has calculated the APSA regulated capacity separately for each building at the facility. Only buildings 801 and 883 were calculated by the
<br />facility to have APSA regulated capacity. A PE certified SPCC Plan was prepared for building 801. The SPCC Plan prepared for building 883 was a Tier
<br />Sitewide SPCC Plan completed May 4, 2016.
<br />1 template and not PE certified. The PE certification must include all of the aspects in 40 CFR 112.3(d) (1), including attesting that the PE Is familiar
<br />Plan certified by Professional Engineer.
<br />with 40 CFR Part 112, he or his agent has visited and examined the facility, the Spill Prevention, Control, and Countermeasure (SPCC) Plan has been
<br />prepared in accordance with good engineering practice, including Consideration of applicable industry standards, procedures have been
<br />established for required inspections and testing, and the Plan is adequate for the facility. Immediately obtain a complete PE certification forthe
<br />facility's SPCC Plan. Submit a copy of the completed certification to the EHD.
<br />604
<br />CFR 112.7(a)(3)
<br />NO FACILITY DIAGRAM OR DIDN'T SHOW LOCATION AND CONTENTS OF CONTAINERS, TRANSFER STATIONS, AND PIPES
<br />CFR 112.7(a)(3) No facility diagram or didn't show location and contents of containers, transfer stations, and pipes. The facility has calculated the
<br />Create sitewide facility diagram that contains all required
<br />Violation ackowledged.
<br />APSA regulated capacity separately for each building at the facility and prepared separate SPCC Pians. Only buildings 801, 846, 865, and 883 have
<br />content
<br />SPCC Plans (according to the inventories, buildings 846 and 865 do not have APSA regulated capacity ). The inventories of the additional buildings
<br />Sitewide SPCC Plan completed May 4, 2016.
<br />at the facility were not included on the map Included in the SPCC Plans. The Spill Prevention, Control, and Countermeasure (SPCC) Plan shall include
<br />Plan includes facility diagram.
<br />a facility diagram which must mark the location and contents of each fixed storage container and the storage area where mobile or portable
<br />containers are located. It must identify the location of and mark as "exempt" underground tanks. it must also include all transfer stations and
<br />connecting pipes, including intra -facility gathering lines. Immediately update the facility diagram to include all of the required information. Submit
<br />a legible copy of the updated facility diagram to the EHD for review.
<br />605
<br />CFR 112.7(a)(3)
<br />PLAN FAILED TO ADDRESS FACILITY LAYOUT, OPERATIONS DISCHARGE PREVENTION METHODS AND CONTAINERS
<br />Class II
<br />CFR 1123(a)(3) Plan failed to address facility layout, operations discharge prevention methods and containers. The facility has calculated the APSA
<br />Create sitewide SPCC Plan that includes all required containers
<br />Violation ackowledged.
<br />regulated capacity separately for each building at the facility and prepared separate SPCC Plans. Only buildings 801, 846, 865, and 883 have SPCC
<br />and operations discharge prevention methods for those
<br />Plans (according to the inventories, buildings 846 and 865 do not have APSA regulated capacity). The APSA regulated storage at the additional
<br />containers.
<br />Sitewide SPCC Plan completed May 4, 2016.
<br />buildings at the facility were not included in the SPCC Plan inventories. The following shall be addressed in the Spill Prevention, Control, and
<br />Plan includes all required containers and
<br />Countermeasure (SPCC) Plan:
<br />discharge prevention methods for those
<br />- type of oil in each fixed container and it's storage capacity. For mobile or potable containers, the type of oil and storage capacity for each
<br />containers.
<br />container or an estimate of the potential number of mobile or portable containers, the types of oil, and anticipated storage capacities
<br />- discharge prevention measures Including procedures for routine handling of products
<br />- discharge or drainage controls such as secondary containment, equipment, and procedures forthe control of a discharge
<br />- countermeasures for discharge discovery, response, and cleanup
<br />- methods of disposal of recovered materials
<br />- contact list and phone numbers for the facility response coordinator, National Response Center, cleanup contractors, and all appropriate Federal,
<br />State, and local agencies.
<br />Immediately amend the SPCC Plan to include all required information.
<br />Aboveground Petroleum Storage Act Inspection Report
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