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i I The following is an itemized list of aboveground petroleum storage act violations that have not been addressed for Ramos Oil Co- 1505 Navy Drive as of March 25, 2019. I I I Open violations from January 14, 2019 inspection Violation #201 -Failure to have a licensed PE properly review and certify the SPCC plan. The SPCC plan has not been certified by a Professional Engineer(PE). The PE certification must include all of the aspects in 40 CFR 112.3(d)(1), including attesting that the PE is familiar with 40 CFR Part 112, he or his agent has i visited and examined the facility, the Spill Prevention, Control, and Countermeasure(SPCC) Plan has been i prepared in accordance with good engineering practice, including consideration of applicable industry standards, procedures have been established for required inspections and testing, and the Plan is adequate for the facility. Immediately obtain a complete PE certification for the facility's SPCC Plan. Submit a copy of the completed certification to the EHD. Violation#603 -Failed to adequately describe the physical layout of the facility in the Plan. The SPCC plan does not include connecting piping in the facility map. The Spill Prevention, Control, and Countermeasure (SPCC) Plan shall include a facility diagram which must mark the location and contents of each fixed storage container and the storage area where mobile or portable containers are located. It must identify the location of and mark as"exempt" underground tanks. It must also include all transfer stations and connecting pipes, including intra-facility gathering lines. Immediately update the facility diagram to include all of the required information. Submit a legible copy of the updated facility diagram to the EHD for review. Violation#607 -Plan failed to include countermeasures for discharge discovery, response and cleanup. Countermeasures for discharge discovery, reposnse and cleanup up was not addressed for the pipe trench in between the despensers. Address in the SPCC plan, countermeasures for discharge discovery, response, and cleanup (both the facility's capability and those that might be required of a contractor).Amend the SPCC Plan to include discussion of all applicable regulations. Violation #706 -Failed to provide and maintain adequate secondary containment. Appendix D of the plan, "SPCC Contingency List" describes the secondary containment wall for the two 10,000 gallon diesel tanks as not being sufficient and the wall needed to be raised by approximately 5 inches. The two 10,000 gallon tanks appeared to be permanently manifolded. All bulk storage tanks must be provided with a secondary means of containment for the entire capacity of the tank and sufficient freeboard to contain precipitation. j Immediately provide sufficient secondary containment for this and all other tanks at this facility. Note: Permanently manifolded tanks are tanks that are designed, installed, or operated in such a manner that the multiple containers function as a single storage unit(67 FR 47122, July 17, 2002).Accordingly, the total capacity of manifolded containers is the design capacity standard for the sized secondary containment provisions (plus freeboard in certain cases). Violation#710 -Plan failed to adequately discuss procedures to test or inspect each container for integrity. The SPCC plan references STI SP-001 industry standard for testing and inspections. The qualifications of personnel performing tests and inspections, frequency and type of testing and inspections taking into account container size, configuration, and design are not determined in accordance with industry standards. 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 i 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 amend the SPCC plan to include discussion to meet the requirements of this section and conduct the necessary testing, if needed. If testing is conducted, submit a copy of the test results to the EHD, or provide equivalence as allowed by CFR 112.7(a)(2). s Open violations from May 10, 2017 inspection I I Page 1 of 2 i i