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Tiger Lines, LLC <br /> 927 East Black Diamond Way <br /> Lodi, CA 95240 <br /> Item#611: CFR 112.7(b)Plan failed to include a description of potential equipment failure or <br /> provide equivalence. <br /> Summary of Violation <br /> Potential equipment failure and the resulting spill for tanks other than the 25,000 diesel tanks was <br /> not addressed in the Spill Prevention, Control, and Countermeasure (SPCC) Plan. The SPCC Plan <br /> must include a prediction of the direction, rate of flow, and total quantity of oil which could be <br /> discharged from the facility as a result of major equipment failure. Immediately amend the SPCC <br /> Plan to include this information and submit a copy of the revision to the EHD, or provide <br /> equivalence as allowed by 40 CFR 112.7(a)(2). <br /> This is a minor violation. <br /> Corrective Actions Taken for Each Violation: <br /> 1. The SPCC Plan will be amended to include a discussion about the catastrophic failure of the <br /> two 25,000-gallon diesel tanks and will include the other containers located at the facility that <br /> are 55-gallons or greater. <br /> Item#618: CFR 112,7(e), 112.8(c)(6) Failed to keep records of procedures, inspections, or integrity <br /> tests for three years. <br /> Summary of Violation <br /> The inspection forms being used are not the forms provided by the Spill Prevention, Control, and <br /> Countermeasure (SPCC) Plan, and in some instances, do not contain the same information. Facility <br /> is using daily forms that address the overall condition of the tanks but do not have the detail of the <br /> forms required by the SPCC plan or that meet the requirements for the STI SP-001 inspection <br /> forms. The STI SP-001 industry standard is referenced In the SPCC as the standard for the tanks. <br /> Inspections and tests must be conducted and stored in accordance with the written procedures <br /> developed for this facility in the SPCC Plan. Immediately begin conducting all inspections and tests <br /> in accordance with the procedures in the SPCC Plan or amend the Plan and have it recertified by a <br /> Professional Engineer to accurately reflect the inspection procedures currently followed at the <br /> facility. <br /> This is a Class II violation. <br /> Corrective Actions Taken for Each Violation: <br /> 1. Effective immediately,the facility will begin conducting all inspections and tests in <br /> accordance with the procedures in the SPCC Plan. <br /> 2. The consultant will recommend appropriate training of personnel on the proper use of the <br /> Inspection Forms according to STI SP-001 and will review the periodic testing requirements <br /> per the STISP-001industry standard. <br /> Page 3 of 5 <br />