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The following is an itemized list of aboveground petroleum storage act violations that have not been addressed for VALLEY PACIFIC PETROLEUM ESCALON as of May 06, 2017. Open violations from February 01, 2016 inspection Violation #627 - Failed to provide vehicular departure system loading and unloading racks. The adequacy of the onsite vehicle departure system in the loading/unloading area was not discussed in the reviewed SPCC plan. The facility must provide an interlocked warning light or physical barrier system, warning signs, wheel chocks or vehicle brake interlock system in the loading/unloading area to prevent vehicles from departing before complete disconnection of flexible or fixed oil transfer lines. Immediately provide a means of preventing vehicle departure prior to transfer line disconnection that is in accordance with 40 CFR Part 112 and your Spill Prevention, Control, and Countermeasure Plan, or provide equivalence as allowed by CFR 112.7(a)(2). Violation #628 - Failed to inspect lowermost drains and outlets prior to filling and departure of vehicles. No procedures for inspecting the lowermost drains and all outlets of fuel delivery vehicles for discharges were outlined in the reviewed SPCC plan. Prior to filling and departure of any tank car or tank truck, the lowermost drains and all outlets of such vehicles shall be closely inspected for discharges and to ensure that they are tightened, adjusted, or replaced to prevent liquid discharge while in transit. Ensure that these vehicles are inspected prior to filling and departure, or provide equivalence as allowed by CFR 112.7(a)(2). Violation #710 - Failed to perform tank inspections that take into account size, configuration, and design. The reviewed SPCC plan didn't specify the testing schedule or address how such schedule would conform to the applicable industry standard. Each aboveground container shall be tested and inspected for integrity on a regular schedule and whenever 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). Violation #714 - Failed to provide each container with a high level monitoring device. The SPCC plan didn't discuss the overfill prevention and the overfill prevention could not be verified at the time of inspection. Mr. Eliason indicated that any overfill prevention device installed on this system is not being routinely tested. At least one of the following devices must be installed in each container: - High liquid level alarm with audible or visual signal - High liquid level pump cutoff device set to stop flow at a predetermined content level - Direct audible or code signal communication between the container gauger and the pumping station - Fast response system, such as digital computer, telepulse, or direct vision gauge. If a direct vision gauge is being used for determining the liquid level of each tank, a person must be present to monitor gauges and the overall filling of the tanks. Immediately install an approved liquid level sensing device in accordance with CFR 112.8 and implement necessary procedures to ensure that the devices are fully functional and in use at all times during tank filling operations, or provide equivalence as allowed by CFR 112.7(a)(2). Submit proof of correction to the EHD. Violation #715 - Failed to regularly test liquid level sensing devices to ensure proper operation. The SPCC plan didn't discuss the overfill prevention and the overfill prevention could not be verified at the time of inspection. Mr. Eliason indicated that any overfill prevention device installed on this system is not being routinely tested. Procedures and frequency of testing for these devices were not addressed in the Spill Prevention, Control, and Countermeasure (SPCC) plan. Liquid level sensing devices must be installed in accordance with CFR 112.8 and shall be regularly tested to ensure proper operation. Immediately conduct all necessary testing of liquid level sensing devices, or provide equivalence as allowed by CFR 112.7(x)(2). Violation #725 - Failed to conduct integrity and leak test on buried piping any time it is worked on. No integrity testing for the buried piping was available for review at the time of inspection. Buried piping shall be tested for integrity and leaks at the time of installation, modification, construction, relocation, or replacement. Immediately perform integrity and leak testing of this piping and ensure that piping is tested when required, or provide equivalence as allowed by CFR 112.7(a)(2). Submit proof of correction to the EHD. Page 2 of 2