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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 /> ijff' This violation was corrected ❑ This violation will be corrected by ( date ) : <br /> ❑ Supporting documents included / l <br /> Describe actions taken or will be taken to correct violation : �` rj L& e4 f 4` 4 54-c^+e, <br /> LJ <br /> v. 6 -� �. e -� 2 rvi,: , �,e S c�-� Ok 4�-r-c� (� c !2 L Q ,rte <br /> res tA, f4 cLvt <br /> S4 mv+ edka- E! - 4,, . L \- close cfq(� - e- �'�. Il Qv< 1 .��► ; � y. <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 : ( 0 ( 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 : �LwtP lciy ete,S to w,r "t-1� kyA ,e�l <br /> No P .rte �,�:� -1 -vim` W� ci S -o (not 5 c a vw S 5 vok a <br /> u%. Zn L*AL h e, `Zc7 Z Z <br /> Page 4 of 7 <br />