COMPLIANCE INFO - Laserfiche WebLink

Home Browse Search

I i The following is an itemized list of aboveground petroleum storage act violations that have not been addressed for PANELLA TRUCKING LLC as of May10, 2019. Open violations from October 19 2018 inspection Violation#710 -Plan failed to adequately discuss procedures to test or inspect each container for integrity. Tests or inspections described in the SPCC plan do not reference an industry standard to determine the appropriate qualifications for personnel performing tests and inspections, the frequency and type of testing and inspections, which take into account container size, configuration, and design. Table 9 references the Steel Tank Institute j SP-001 Standard certifed inspector testing and frequency, but will only be performed after shell repairs or as I directed by the local enforcement agency. This is not an inspection frequency that is part of the SP001 standard. A claim of environmental equivalence was not made. 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 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 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. Immediately include an industry standard and perform necessary testing, if required. Submit a copy of the SPCC plan and test results, if conducted, to the EHD, or provide equivalence as allowed by CFR 112.7(a)(2). Note: If an owner or operator deviates from applicable industry standards to develop an integrity testing program, then a PE must certify an environmentally equivalent alternative in the SPCC Plan. The Plan must provide the reason for the deviation, describe the alternative approach, and explain how it achieves environmental protection equivalent to the applicable industry standard. Violation#714 -Failed to provide each container with a high level monitoring device. i The SPCC plan states that all tanks have an audible/visual sensor for overfill. The 100 gallon tanks were observed without a high level monitoring device. At least one of the following devices must be installed in each container.- - ontainer:- High liquid level alarm with audible or visual signal - High liquid level pump cutoff device set to stop flow at a predetermined content level - Direct audible or code signal communication between the container gauger and the pumping station - Fast response system, such as digital computer, telepulse, or direct vision gauge. If a direct vision gauge is ; being used for determining the liquid level of each tank, a person must be present to monitor gauges and the overall 1 filling of the tanks. j Immediately install an approved liquid level sensing device in accordance with CFR 112.8 and implement necessary j procedures to ensure that the devices are fully functional and in use at all times during tank filling operations, or provide equivalence as allowed by CFR 112.7(a)(2). Violation#718 - Failed to locate properly or provide sufficient secondary containment for mobile/portable j containers. The qualifying 55 gallons drums outside of the shop area and the 100 gallon diesel and waste oil containers on wheels were observed with insufficient secondary containment. The SPPC plan calls for drums to be on spill containment pallets and the 100 gallon rolling tanks to be on concrete and have spill kits available. The drums were ± not observed on spill containment pallets and no other secondary containment was evident. The 100 gallon tanks I require secondary containment to contain the capacity of the largest single compartment or container. The SPCC plan does not cover the amount of material for the spill kit that is needed for the containment of the 100 gallon tank. Position or locate mobile or portable oil storage containers to prevent a discharge... Except for mobile refuelers and other non-transportation-related tank trucks, you must furnish a secondary means of containment, such as a dike or catchment basin, sufficient to contain the capacity of the largest single compartment or container with sufficient freeboard to contain precipitation Immediately provide sufficient secondary containment for this and all other i portable containers at this facility, or provide equivalence as allowed by CFR 112.7(2)(2). i i Page 2 of 2 I