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The following is an itemized list of aboveground petroleum storage act violations that <br /> have not been addressed for CUNHA DRAYING INC as of May 27, 2022. <br /> Open violations from March 08, 2022 inspection <br /> Violation#612-Plan doesn't have discharge prediction, including direction, rate of flow,and quantity of oil. <br /> OBSERVATION: The Spill Prevention, Control, and Countermeasure(SPCC) Plan failed to predict the direction, <br /> rate of flow, and the total quantity of the oil that could be discharged for each type of major equipment failure. The <br /> potential equipment failure and the resulting spill from all APSA regulated storage containers was not completely <br /> addressed in the SPCC Plan. <br /> REGULATION GUIDANCE: (b)Where experience indicates a reasonable potential for equipment failure(such as <br /> loading or unloading equipment,tank overflow, rupture, or leakage, or any other equipment known to be a source of <br /> a discharge), include in your Plan a prediction of the direction, rate of flow, and total quantity of oil which could be <br /> discharged from the facility as a result of each type of major equipment failure. <br /> CORRECTIVE ACTION: Ensure the SPCC Plan completely describes equipment failure predictions for all APSA <br /> regulated storage on site including direction, rate of flow and total quantity that could be discharged. Submit proof of <br /> correction to the EHD. <br /> ❑ This violation was corrected ❑This violation will be corrected by(date): <br /> ❑ Supporting documents included <br /> Describe actions taken or will be taken to correct violation: <br /> Violation#620-Failed to train personnel on all discharge prevention details listed in this section. <br /> OBSERVATION: It appears that the oil handling personnel were not adequately trained, as required. The SPCC <br /> plan requires documentation of annual training. No training records were available for review during the inspection. <br /> REGULATION GUIDANCE: (f)(1)At a minimum,train your oil-handling personnel in the operation and maintenance <br /> of equipment to prevent discharges; discharge procedure protocols; applicable pollution control laws, rules, and <br /> regulations; general facility operations; and,the contents of the facility SPCC Plan. <br /> CORRECTIVE ACTION: Immediately provide adequate training to all oil handling personnel and submit a copy of <br /> the training log and training content to the EHD. <br /> ❑ This violation was corrected ❑This violation will be corrected by(date): <br /> ❑ Supporting documents included <br /> Describe actions taken or will be taken to correct violation: <br /> Page 4 of 7 <br />