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California Accidental Release Prevention Program (CalARP) • RMP five-year update was submitted late. Program 3 facility consider how late and the hazard. • RMP not updated within six months of an accidental release. • Owner/operator did not meet the internal 3-year internal compliance audit requirements for Program 3. • Owner/operator did not maintain investigation reports for releases. • Failure of the owner or operator to correct deficiencies found from an RMP review during the specified time frame. • PHA or Hazard Review not revalidated every 5 years. • Failure of the owner or operator to revise/correct /update the RMP thirty days of a UPA inspection where the inspection report identifies a revision/correction/update is required. Hazardous Waste Program • Hazardous waste in secondary containment was not cleaned up within 24 hours or in as timely a manner as is possible to prevent harm to human health or the environment (this could be a Class I depending on volume and type of waste). • Failure to update closure costs annually for inflation for PBR or CA (although this may be a Class I if such costs are substantial). • Failure to provide annual training(at least a Class II and potentially Class 1). • Failure to maintain training documentation for multiple years for Large Quantity Generators (at least a Class II and potentially Class I). • Failure to make a hazardous waste determination(could be a Class I if the facility has failed to make hazardous waste determinations on multiple waste streams). • Storage of hazardous waste greater than allowable times (90, 180 or 270 days) for low hazard facilities or a low hazard chemical. Also consider the contents of the container and how many. (This could be a Class I depending on type of hazards.) • Any minor violation that has not been corrected within 30 days or provides an economic benefit to the violator. Aboveground Petroleum Storage Act(APSA) • Failure to have an SPCC Plan but have secondary containment and a tank inspection program. • Failure to have management approval of an SPCC Plan. • Failure to have aboveground storage tanks tested or inspected for integrity. • Failure to provide secondary containment to hold capacity of largest container and sufficient freeboard for precipitation on bulk storage container. Violation Classification Guidance for UPAS Page 11