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Attachment 2A Citation Deficiency Plan Field 112.7(h)(3) No inspection of lowermost drains/outlets prior to filling and departure of any tank car/truck 112,7(1) Plan has no or inadequate procedures to evaluate brittle fracture or catastrophic failure 112.76) No discussion of conformance with applicable State rules, regulations, and guidelines 112.7(k) Olf-filled operational equipment (OFOE) has no or inadequate secondary containment in accordance with 112.7(c)and does not meet eligibility criteria in 112,7(k)(1) 112.7(k)(2)(i) No established and documented procedures for inspections or monitoring program for qualified OFOE to detect equipment failure and/or a discharge 112.7(k)(2)(ii)(A) No or inadequate. contingency plan per 40 CFR part 109 or FRP under 112.20 112.7(k)(2)(ii)(B) No written commitment of manpower, equipment, and materials 112.8(b)(1) Drainage from diked areas not restrained by valves or manual pumps/ejectors 112.8(b)(2) Valves used to drain diked areas are not of manual, open-and-closed design 112.8(b)(3) Drainage from undiked areas not designed to flow to ponds, lagoons, or catchment basins inside facility; or catchment basins located in area subject to periodic flooding 112.8(b)(4) No diversion systems to return spills to the facility 112.8(b)(5) Two"lift"pumps not provided if more than one treatment unit needed or facility drainage not engineered to prevent discharge as described in 112.1(b) 112.6(c)(1) Material/construction of containers not compatible with oil stored and/or storage conditions 112.8(c)(2)or No secondary containment inadequately sized contain largest single container with 112.6(a)(3)(ii) freeboard for precipitation.. 112,8(c)(2) Materials or construction of secondary containment are not sufficiently impervious 112.8(c)(3)(i) Bypass valve not sealed closed when drainage is to a storm drain or open watercourse I 12.8(c)(3)(ii) Retained rainwater not inspected to ensure presence will not cause a discharge 112.8(c)(3)(N) Bypass valves not opened and later resealed under supervision 112.8(c)(3)(iv) Adequate records of drainage events are not maintained 112,8(c)(4)& Completely or partially buried metallic tanks are not protected from corrosion or are not I 12.8(c)(5) subject to regular leak testing 112.8(c)(6) Aboveground containers not integrity tested on a regular schedule or when repaired. 112.8(c)(6) Testing/inspection not in accordance with industry standards to identify the appropriate qualifications for inspection/testing personnel or frequency or type of testing/inspection 112.8(c)(6) Containers and container supports not inspected. 112.8(c)(6) Outside of container not frequently inspected for signs of deterioration, or oil discharges 112.8(c)(6) No records of inspections/tests or comparison records not kept 112.8(c)(7) Steam return and exhaust lines of internal heating coils which discharge into an open water course are not monitored or passed through a separation system 112.8(c)(8)or No liquid level sensing devices or other overfill prevention systems provided or not 112.6(a)(3)(iii) regularly tested 112 8(c)(9) Effluent treatment facilities which discharge directly to waters not observed frequently enough to detect system upsets 112.8(c)(10) Leaks in diked area are not promptly corrected or oil in diked areas not removed 112:8(c)(11)or Mobile or portable containers not positioned to prevent discharge as described in 112.1(b) 112.6(a)(3)(ii) or no/inadequate secondary containment for mobile or portable containers. 112.8(d)(1) Buried piping installed or replaced after August 16, 2002 is not corrosion protected 112.8(d)(1) Exposed buried piping not inspected for deterioration or corrected 112.8(d)(2) Out-of service or standby piping not capped or blank flanged or marked as to origin 112.8(d)(3) Pipe supports not properly designed 112.8(d)(4) Aboveground valves, piping, and appurtenances not inspected 112.8(d)(4) Buried piping not integrity/leak tested when installed, modified, relocated, or replaced 112.8(d)(5) Vehicles not warned of aboveground piping or other oil transfer operations 112.20(e) No certification of the applicability of the substantial harm criteria Deficienciwq fmind rhirinn the inenprfinn mrA martmA wifk ren °LY"