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i i i The following is an itemized list of aboveground petroleum storage act violations that have not been addressed for WILLIAMS TANK LINES as of April03, 2019. i Open violations from September 27, 2018 inspection I Violation#301 -Failed to amend Plan as necessary. The section in the plan dedicated to and labeled as 112.8(c)(11) states that"there is no mobile container within this system". Several 55 gallon drums and two IBC totes having a capacity of over 55 gallons, all storing petroleum products, were observed at the facility and were mentioned in other sections of the SPCC plan. The IBC totes are described as having a capacity of 240 gallons in portions of the plan and as having a capacity of 270 gallons in other I portions of the plan. Page 31 of the SPCC plan states"the facility does not operate any underground piping system. No corrosion protection is needed" and page 14 of the SPCC plan states"that only buried piping on site is the underground#2 diesel fuel piping that connects the main dispenser to the slave dispenser."The facility j representative stated that the slave dispenser is no longer in use and that the piping has been disconnected and capped. The Spill Prevention, Control, and Countermeasure (SPCC) Plan must be amended when there is a i change in the facility design, construction, operation, or maintenance that materially affects its potential for a discharge, within 6 months of the change, and implemented as soon as possible, not later than 6 months following preparation of the amendment. Immediately make all necessary amendments to the SPCC Plan to accurately represent the procedures and policies currently in place at the facility. j Violation #710 -Plan failed to adequately discuss procedures to test or inspect each container for integrity. The SPCC plan does not reference an industry standard used to test or inspect each aboveground container for i integrity. The SPCC plan does not address the appropriate qualifications for personnel performing tests and inspections, the frequency and type of testing and inspections per industry standards. Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs. You must determine, in accordance with industry standards, the appropriate qualifications for personnel performing tests and inspections, the frequency and type of testing and inspections, which take into account account container size, configuration, and design (such as containers that are: shop-built, field-erected, skidmounted, elevated, equipped with a liner, double-walled, or partially buried).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. You must keep comparison records and you must also inspect the container's supports i and foundations. In addition, you must frequently inspect the outside of the container for signs of deterioration, discharges, or accumulation of oil inside diked areas. Records of inspections and tests kept under usual and customary business practices satisfy the recordkeeping requirements of this paragraph. Include omitted information i in the SPCC plan and submit SPCC plan for to the EHD, or provide equivalence as allowed by CFR 112.7(a)(2). Note : An SP001 certified inspector inspection report was reviewed for the 12,000 gallon diesel tank during the inspection. The report was dated 05/05/2015. I I f 1 i I i I i Page 1 of 1