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... . CUPA Findings b. . Aten Response APSA Findings 517. Copies of inspection and testing records for the monthly tank inspections were not found on site. The inspections being conducted are not covering all of the tanks and areas required. Inspections and tests must be conducted in accordance with the written procedures developed in the SPCC Plan. Records of these inspections and tests must be signed by the appropriate supervisor or inspector and kept on site with the SPCC Plan for a period of three years. Immediately locate a copy of all inspection and testing records for the last three years, maintain them on site, and submit copies to the EHD. Records of Inspections are filed in the maintenance work order system. Physical documents are not retained. Appendix A contains the printed work order that is closed or performed by the tank inspectors. Any deficiencies are noted in the work order itself. The development of a new form is complete for all tanks containing hazardous materials. • 518. Records for annual SPCC training were not available on site. At a minimum, oil-handling personnel must be trained in the operation and maintenance of equipment to prevent discharges, discharge procedure protocols, applicable pollution control laws, rules & regulations, general facility operations, and the contents of the facility's SPCC Plan. Annual briefings must be conducted to assure adequate understanding of the SPCC Plan and highlight and describe any known discharges or failures, malfunctioning components, and any recently developed precautionary measures. Immediately conduct necessary training for all oil handling personnel. Submit copies of training records to the EHD. See Appendix B for copies of the SPCC Training record for this year. 609. Copies of integrity test records were not found on site. According to the Plan, all tanks are inspected on a 10 year schedule according to API 653 standards. All aboveground containers are to be inspected on a regular basis. Comparison records and other records of inspections and tests must be maintained on site with the SPCC Plan. Immediately locate a copy of all integrity inspection and testing records, maintain them on site, and submit copies to the EHD. The records were on site in a digital format. I could not retrieve these records at the time of the inspection due to not knowing where the records were located and who knew the location of the records. The actual reports are in Appendix C. . 501. The cross reference for the SPCC Plan is not entirely accurate and does not always list specific locations. The listing for the facility maps was over 60 pages before the location of the maps in the Plan. If you do not follow the sequence specified in 40 CFR 112 for the Plan, you must prepare an equivalent Plan and supplement it with a section cross-referencing the location of M requirements in 40 CFR 112 and the equivalent Plan. Immediately amend the Plan to include a cross-reference that lists the specii, accurate locations of the Plan requirements, or to follow the required sequence. O v The current SPCC is being revised and should be completed by the end of August and an accurate cross reference will be 0 Z n developed. a � Z �• _ Zr o