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Rev date: 5/6/16 Attachment 2. LLN L Violation Tracking Spreadsheet - Aboveground Petroleum Storage Act (APSA) Inspection Date: September - October 2015 LLNL Site 300 Violation Report Regulation/Code Remarks Inspection Report Action Item Status Item it Violation Class st f� 615 CFR 112.7(f)(2) FAILED TO DESIGNATE A PERSON ACCOUNTABLE FOR DISCHARGE PREVENTION to I Class II (r CFR 112.7(f)(2) Failed to designate a person accountable for discharge prevention. This facilitydoes not have a designated person for discharge The sitewide SPCC Plan will include an individual's or individuals' Violation ackowledged. prevention. The SPCC Plan for building 801 states that the designated person is the "Operations Facility Manager" but does not specify a specific names that are accountable for discharge prevention. person by name. The Spill Prevention, Control, and Countermeasure (SPCC) Plan shall designate a person at the facility who is accountable for Sitewide SPCC Plan completed May 4, 2016. discharge prevention and who reports to facility management. Immediately designate a person to be accountable for discharge prevention and Plan includes all individuals' names that are update the SPCC Plan to include this information, accountable for discharge prevention. 617 CFR 112.7(g) PLAN FAILED TO ADDRESS SECURITY OF SITE AND VALVES, LOCK OUT/TAG OUT, AND LIGHTING Class II CFR 112.7(g) Plan failed to address security of site and valves , lock out/tag out, and lighting. The sitewide SPCC Plan will include a description of lighting in Violation ackowledged. The Spill Prevention, Control, and Countermeasure (SPCC) Plan did not include a complete discussion of security lighting. The SPCC Plan for building the context of vandalism and assisting in the discovery of oil 801 discussed the lighting provided for tank transfer I fuel delivery operations, but did not address vandalism prevention or discharge discovery. discharges. Sitewide SPCC Plan completed May 4, 2016. The SPCC Plan must include descriptions of how you secure and control access to the oil handling, processing & storage areas, secure master flow Plan includes a description of lighting in the & drain valves, prevent unauthorized access to starter controls on oil pumps, secure out -of -service and loading/unloading connections of oil context of vandalism and assisting in the pipelines, and address the appropriateness of security lighting to both prevent acts of vandalism and assist in the discovery of oil discharges. discovery of oil discharges. Immediately update the SPCC Plan to Include all of the required security Information, or provide equivalence as allowed by 40 CFR 112.7(.)(2) . 713 CFR 112.8(c)(6) FAILTO PERFORM SCHEDULED TANK TESTS AND INSPECTIONS BY APPROPRIATELY QUALIFIED PERSONNEL Class II CFR 112.8(c)(6) Failed to perform scheduled tank tests and inspections by appropriately qualified personnel. The Diala oil tank for building 801 was The sitewide SPCC Plan will clearly define at what point integrity Violation ackowledged. not tested for integrity. According to the SPCC Plan, visual inspections will be used for integrity testing unless problems are detected. The monthly testing is required if there is an indication of an issue with a tank inspection records being maintained by Mr. Tom McWilliams (the building APSA "operator") have marked for many months that there is liquid piece of equipment. These decision points should be clearly Sitewide SPCC Plan completed May 4, 2016. visible in the secondary containment or berm and that the exterior coating is bubbling, cracked, or damaged. When questioned about what kind of defined and based on the judgment of the PE. Plan clearly defines at what point integrity "problems" noted during the monthly inspections would trigger additional integrity testing , Mr. McWilliams stated that he monitors the tank testing is required if there is an indication of inventory levels and would take action If the levels Indicated a loss of product. Each aboveground container shall be tested and inspected for an issue with a piece of equipment. Integrity on a regular schedule and whenever r repairs are made. The qualifications of personnel performing tests and Inspections, frequency and type of testing and inspections that take into account container size, configuration , and design shall be determined in accordance with industry standards. Examples of these integrity tests include, but are not limited to: visual Inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other systems of non-destructive testing. Comparison records and other records of inspections and tests must be maintained on site. Immediately conduct the necessary testing and submit a copy of the test results to the EHD, or provide equivalence as allowed by CFR 112.7(a)(2). 717 CFR 112.8(c)(8)(v) FAILED TO REGULARLY TEST LIQUID LEVEL SENSING DEVICES TO ENSURE PROPER OPERATION Class II CFR 112.8(c)(8)(v) Failed to regularly test liquid level sensing devices to ensure proper operation. Liquid level sensing devices have not been tested. The sitewide SPCC Plan will identify what overfill prevention Violation ackowledged. According to Mr. Tom McWilliams, the APSA "operator" at building 801, the liquid level sensing devices are looked at for determining inventory method is used for each container. Sensing devices must be levels, but are not tested or checked for accuracy. Procedures and frequency of testing for these devices were not addressed in the Spill tested as per manufacturer's recommendations and/or industry Sitewide SPCC Plan completed May 4, 2016. Prevention, Control, and Countermeasure (SPCC) plan. Liquid level sensing devices must be installed in accordance with CFR 112.8 and shall be standards to ensure they are functioning properly. Plan identifies what overfill prevention regularly tested to ensure proper operation. Immediately conduct all necessary testing of liquid level sensing devices, or provide equivalence as method is used for each container and states allowed by CFR 112.7(a)(2). that sensing devices must be tested as per manufacturer's recommendations and/or industry standards to ensure they are functioning properly. Aboveground Petroleum Storage Act Inspection Report Ir � Jt st f� 3. �r s to I (r r