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Rev date:11/29/16 LLNL Violation Tracking Spreadsheet-Aboveground Petroleum Storage Act(APSA) Inspection Date:September-October 2015 LLNL Site 300 Violation Report Regulation/Code Remarks Location where Violation was addressed in the SPCC Plan Item a violation Class 617 CFR 112.7(8) PIAN 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. Section 2.8.3,Facility Lighting(page 24 of PDF) The Spill Prevention,Control,and Countermeasure(SPCC)Plan did not include a complete discussion of security lighting.The SPCC Plan for building 801 discussed the lighting provided for tank transfer I fuel delivery operations,but did not address vandalism prevention or discharge discovery.The SPCC Plan must include descriptions of how you secure and control access to the oil handling,processing&storage areas,secure master flow&drain valves,prevent unauthorized access to starter controls on oil pumps,secure out-of-service and loading/unloading connections of oil pipelines,and address the appropriateness of security lighting to both prevent acts of vandalism and assist in the 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) FAIL TO 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 C iala oil tank for building 801 The previous SPCC Plan for 8801 stated that aboveground oil containers are inspected visually and was not tested for integrity.According to the SPCC Plan,visual inspections will be used for integrity testing unless problems are detected.The if problems are found or suspected,additional testing will be employed,as applicable.It also monthly tank inspection records being maintained by Mr.Tom McWilliams(the building APSA"operator")have marked for many months that stated that integrity tests of bulk storage containers are conducted in accordance with STI SP001. there is liquid visible in the secondary containment or berm and that the exterior coating is bubbling,cracked,or damaged.When questioned In fact,for all but one of the bulk storage containers onsite,periodic visual inspections are about what kind of"problems"noted during the monthly inspections would trigger additional integrity testing,Mr.McWilliams stated that he adequate according to STI SPOOL.This has been clarified in the revised SPCC Plan in Section 4.2.6, monitors the tank inventory levels and would take action if the levels indicated a loss of product. Each aboveground container shall be tested Bulk Storage Containers Periodic Integrity Testing(page 27-29 of the PDF).The plan now states and inspected for integrity on a regular schedule and whenever repairs are made.The qualifications of personnel performing tests and that,for all bulk storage containers with the exception of 801-T1A3,formal inspections are not inspections,frequency and type of testing and inspections that take into account container size,configuration,and design shall be determined in routinely required unless experience,container damage,or other indications suggest that further accordance with industry standards. Examples of these integrity tests include,but are not limited to:visual inspection,hydrostatic testing, inspection is necessary.Appendix H(pages 138-151 of the PDF)provides detailed instructions and radiographic testing,ultrasonic testing,acoustic emissions testing,or other systems of non-destructive testing.Comparison records and other inspection forms that clarify that non-conforming items important to tank integrity require further records of inspections and tests must be maintained on site.Immediately conduct the necessary testing and submit a copy of the test results to evaluation by a qualified person. 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 Section 4.2.8(pages 30-31 of the PDF)addresses overfill prevention through various means tested.According to Mr.Tom McWilliams,the APSA"operator"at building 801,the liquid level sensing devices are looked at for determining including gauges,and Appendix H inspection procedure instructions(page 140 of the PDF)states inventory levels,but are not tested or checked for accuracy.Procedures and frequency of testing for these devices were not addressed in the Spill that sensing devices must be regularly tested.Inspection form HA(annual bulk storage Inspection Prevention,Control,and Countermeasure(SPCC)plan.Liquid level sensing devices must be installed in accordance with CFR 112.8 and shall be form,page 151 of the PDF)includes an inspection item to check for calibrations.As annual regularly tested to ensure proper operation.Immediately conduct all necessary testing of liquid level sensing devices,or provide equivalence as inspections occur,this ftem is being addressed. allowed by CFR 112.7(a)(2). Aboveground Petroleum Storage Act Inspection Report 2