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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 XPO Logistics Freight, Inc.-UST as of April 09, 2019. i Open violations from December 06, 2017 inspection Violation#102 -Failed to prepare a written SPCC Plan in accordance with CFR Part 112. This facility has an Aboveground Petroleum Storage Act(APSA) regulated shell capacity of 10,220 gallons ( one 10,000 gallon diesel tank and four 55 gallon oil drums. A Spill Prevention, Control, and Countermeasure (SPCC) Plan was not available on site. All facilities which have an APSA regulated shell capacity of 1,320 gallons or greater shall prepare a written SPCC Plan which meets all of the requirements of the 40 CFR Part 112. This plan shall be certified by a professional engineer in accordance with 40 CFR 112.3(d). Immediately prepare a SPCC Plan in accordance with 40 CFR Part 112, which that includes all aboveground petroleum storage containers 55 gallons or i larger. Submit a copy of the Professional Engineer (PE) certified SPCC Plan to the EHD for review. (This copy will be returned to the facility after review.) A copy shall be maintained on site at all times. Violation #201 -Failure to have a licensed PE properly review and certify the SPCC plan. The Professional Engineer(PE) certification is incomplete. An SPCC PE certified plan was not found on site. 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 visited and examined the facility, the Spill Prevention, Control, and Countermeasure (SPCC) Plan has been 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 #706 -Failed to provide and maintain adequate secondary containment. Four 55 gallon drums of product oil located near the truck wash area were observed with insufficient secondary containment. The vehicle wash area drain was downgrade and approximately twenty feet away from the drums. The secondary containment provided for each 55 gallon drum could not contain the entire capacity of the drum if it leaked. All bulk storage containers must be provided with a secondary means of containment for the entire capacity of the container and sufficient freeboard to contain precipitation. Immediately provide sufficient secondary containment for this and all other petroleum containers and tanks at this facility. Violation#712 - Failed to test or inspect each container for integrity based on industry standards. Each aboveground container shall be tested and inspected for integrity on a regular schedule and whenever repairs are made. 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 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 conduct the necessary testing and submit a copy of the test results to the EHD, or provide equivalence as allowed by CFR 112.7(a)(2). Page 1 of 1