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The following is an itemized list of aboveground petroleum storage act violations that have not been addressed for LIONUDAKIS FIREWOOD as of May 20, 2019. Open violations from July 27,2018 inspection Violation#622-Failure to conduct complete annual discharge prevention briefings for oil-handling personnel. Discharge prevention briefings are not scheduled at least once a year. Discharge prevention briefings for oil handling personnel must be scheduled and conducted at least once a year to assure adequate understanding of the SPCC Plan for that facility. Such briefings must highlight and describe known discharges or failures, malfunctioning components, and any recently developed precautionary measures. Immediately schedule and conduct a discharge prevention briefing, ensure that they are scheduled and conducted at least once a year. Violation#623-Plan failed to address security of site and valves,lock out/tag out,and lighting. The Spill Prevention, Control, and Countermeasure(SPCC) Plan did not include discussion of lighting or the security of master flow&drain valves. The SPCC Plan must include descriptions of how you secure and control access to the oil handling, processing&storage areas, secure master flow&drain valves, prevent unauthorized access to starter controls on oil pumps,secure out-of-service and loading/unloading connections of oil pipelines, and address the appropriateness of security lighting to both prevent acts of vandalism and assist in the discovery of oil discharges. Immediately update the SPCC Plan to include all of the required security information, or provide equivalence as allowed by 40 CFR 112.7(a)(2). Violation#706-Failed to provide and maintain adequate secondary containment. The 250 gallon gasoline tank was observed with insufficient secondary containment. Tank appears to be single walled and no evidence of secondary containment was observed. All bulk storage tanks must be provided with a secondary means of containment for the entire capacity of the tank and sufficient freeboard to contain precipitation. Immediately provide sufficient secondary containment for this and all other tanks at this facility. Violation#710-Plan failed to adequately discuss procedures to test or inspect each container for integrity. Tank integrity inspections and procedures are not discussed in the plan and do not take into account the size, configuration, or design of the tank. 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). Violation#714-Failed to provide each container with a high level monitoring device. High level monitoring devices are not discussed in the SPCC plan. At least one of the following devices must be installed in each container: -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 filling of the tanks. Immediately install an approved liquid level sensing device in accordance with CFR 112.8 and implement necessary 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#715-Failed to regularly test liquid level sensing devices to ensure proper operation. Liquid level sensing devices have not been tested for any of the tanks. Procedures and frequency of testing for these devices were not addressed in the Spill Prevention, Control, and Countermeasure(SPCC)plan. Liquid level sensing devices must be installed in accordance with CFR 112.8 and shall be regularly tested to ensure proper operation. Immediately conduct all necessary testing of liquid level sensing devices, or provide equivalence as allowed by CFR 112.7(a)(2). Page 3 of 3