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Rev date:11/29/16 UAL 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 Com
<br /> Violation Report Regulation/Code Remarks Location where Violation was addressed in the SPCC Plan
<br /> Item# Violation Class
<br /> 201 CFR 312.3(d) PLAN CERTIFICATION BY A PROFESSIONAL ENGINEER(PE)MISSING OR INCOMPLETE
<br /> CFR 112.3(d)Plan certification by a Professional Engineer(PE)missing or incomplete.The Professional Engineer(PE)certification is incomplete. Page iv(Page 5 of PDF file)
<br /> The facility has calculated the APSA regulated capacity separately for each building at the facility.Only buildings 801 and 883 were calculated by
<br /> the facilityto have APSA regulated capacity.A PE certified SPCC Plan was prepared for building 801.The SPCC Plan prepared for building 883 was
<br /> a Tier I template and not PE certified.The PE certification most include all of the aspects in 40 CFR 112.3(d)(1),including attesting that the PE is
<br /> familiar with 40 CFR Part 112,he or his agent has visited and examined the facility,the Split Prevention,Control,and Countermeasure(SPCC)Plan
<br /> has been 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 for the
<br /> facility's SPCC Plan.Submit a copy of the completed certification to the EHD.
<br /> 604 CFR 112.7(a)(3) NO FACILITY DIAGRAM OR DIDNT 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 Map C-2,Site 300 Facility Diagram is in Appendix C(Page 56 of PDF file).
<br /> APSA regulated capacity separately for each building at the facility and prepared separate SPCC Plans.Only buildings 801,846,865,and 883 have
<br /> SPCC Plans(according to the inventories,buildings 846 and 865 do not have APSA regulated capacity).The Inventories of the additional buildings
<br /> at the facility were not included on the map included in the SPCC Plans.The Spill Prevention,Control,and Countermeasure(SPCC)Plan shall
<br /> include a facility diagram which must mark the location and contents of each fixed storage container and the storage area where mobile or
<br /> portable containers are located.It must identify the location of and mark as"exempt"underground tanks. It must also include all transfer
<br /> stations and connecting pipes,including intra-facility gathering lines.Immediately update the facility diagram to include all of the required
<br /> information.Submit a legible copy of the updated facility diagram to the EHD for review.
<br /> 605 CFR 112.7(x)(3) PLAN FAILED TO ADDRESS FACILITY LAYOUT,OPERATIONS DISCHARGE PREVENTION METHODS AND CONTAINERS
<br /> Class II
<br /> CFR 112.7(a)(3)Plan failed to address facility layout,operations discharge prevention methods and containers.The facility has calculated the --Complete sitewide SPCC inventory included in Attachment C tables(Tables C-1,C-2,and C-3,
<br /> APSA regulated capacity separately for each building at the facility and prepared separate SPCC Plans.Only buildings 801,846,865,and 883 have Pages 57-62 of PDF).Table C-1 includes contents and capacity of stationary and portable
<br /> SPCC Plans(according to the inventories,buildings 846 and 865 do not have APSA regulated capacity).The APSA regulated storage at the containers.
<br /> additional buildings at the facility were not included in the SPCC Plan inventories.The following shall be addressed in the Spill Prevention, --Section 3 of the plan(pages 18-25 of the PDF)addresses discharge prevention.
<br /> Control,and Countermeasure(SPCC)Plan: --Section 4 of the plan(pages 25-32 of the PDF)addresses discharge controls,including drainage
<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 design,secondary containment,overfill and leak prevention.
<br /> container or an estimate of the potential number of mobile or portable containers,the types of oil,and anticipated storage capacities --Section 5 of the plan(pages 32-38 of the PDF)and the Contingency Plan(Attachment F,pages
<br /> -discharge prevention measures including procedures for routine handling of products 102-135 of the PDF)address discharge response and cleanup.
<br /> -discharge or drainage controls such as secondary containment,equipment,and procedures for the control of a discharge --Section 5.2 of the plan(page 36 of the PDF)addresses waste disposal.
<br /> -countermeasures for discharge discovery,response,and cleanup —Section 5.3(pages 36-38 of the PDF)and the tables in the Contingency Plan(Attachment F,pages
<br /> -methods of disposal of recovered materials 102-135 of the PDF)address spill notification and reporting requirements and include contact
<br /> -contact list and phone numbers for the facility response coordinator,National Response Center,cleanup contractors,and all appropriate information for spill response and notification.
<br /> Federal,State,and local agencies.
<br /> Immediately amend the SPCC Plan to include all required information.
<br /> 615 CFR 112.7(f)(2) FAILED TO DESIGNATE A PERSON ACCOUNTABLE FOR DISCHARGE PREVENTION
<br /> Class 11
<br /> CFR 112.7(f)(2)Failed to designate a person accountable for discharge prevention.This facility does not have a designated person for discharge Section 2,Facility Information(page 12 of the PDF)
<br /> prevention.The SPCC Plan for building 801 states that the designated person is the"Operations Facility Manager"but does not specify a specific
<br /> person by name.The Spill Prevention,Control,and Countermeasure(SPCC)Plan shall designate a person at the facility who is accountable for
<br /> discharge prevention and who reports to facility management.Immediately designate a person to be accountable for discharge prevention and
<br /> update the SPCC Plan to include this Information.
<br /> Aboveground Petroleum Storage Act Inspection Report 1
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