COMPLIANCE INFO_2024 - Laserfiche WebLink

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The following is an itemized list of aboveground petroleum storage act violations that have not been addressed for PELICAN RENEWABLES LLC as of May 01, 2024. Open violations from October 26, 2022 inspection Violation#601 -Failure of Plan to fulfill basic requirements including a cross-referencing section. OBSERVATION: The Spill Prevention, Control, and Countermeasure(SPCC)Plan reviewed at the time of inspection,dated 9/28/2018, did not follow the order or requirements of 40 CFR Part 112.7. The plan doesn't include adequate cross-reference. The following items are inaccurate: -The requirements for verbal discharge reporting were referenced as being in section 4.2.5 but were actually located in section 4.2.2. -The Inspections, Tests, and Records section references Table 6.1 but there is no Table 6.1 in the SPCC plan. -The Facility Layout is listed as being in section 3.1 but was actually referenced in section 3.2 of the SPCC plan. REGULATION GUIDANCE: If you are the owner or operator of a facility subject to this part you must prepare a Plan in accordance with good engineering practices.The Plan must have the full approval of management at a level of authority to commit the necessary resources to fully implement the Plan.You must prepare the Plan in writing. If you do not follow the sequence specified in this section for the Plan, you must prepare an equivalent Plan acceptable to the Regional Administrator that meets all of the applicable requirements listed in this part, and you must supplement it with a section cross-referencing the location of requirements listed in this part and the equivalent requirements in the other prevention plan. If the Plan calls for additional facilities or procedures, methods, or equipment not yet fully operational,you must discuss these items in separate paragraphs and must explain separately the details of installation and operational start-up. CORRECTIVE ACTION: Ensure that your SPCC Plan complies with the following requirements: 1. It follows the required SPCC rule sequence and/or includes adequate cross-reference. Provide proof of correction to the EHD. ---------------------------------------------- OBSERVATION: The Spill Prevention, Control, and Countermeasure(SPCC)Plan failed to have the full approval of management at a level of authority to commit the necessary resources to fully implement the Plan. Page 2, Section 1.3 Management Approval was not signed. REGULATION GUIDANCE: If you are the owner or operator of a facility subject to this part you must prepare a Plan in accordance with good engineering practices.The Plan must have the full approval of management at a level of authority to commit the necessary resources to fully implement the Plan.You must prepare the Plan in writing. If you do not follow the sequence specified in this section for the Plan, you must prepare an equivalent Plan acceptable to the Regional Administrator that meets all of the applicable requirements listed in this part, and you must supplement it with a section cross-referencing the location of requirements listed in this part and the equivalent requirements in the other prevention plan. If the Plan calls for additional facilities or procedures, methods, or equipment not yet fully operational,you must discuss these items in separate paragraphs and must explain separately the details of installation and operational start-up. CORRECTIVE ACTION: Immediately obtain required management approval for the SPCC Plan for this facility. Provide proof of correction to the EHD. ❑ This violation was corrected ❑This violation will be corrected by(date): ❑ Supporting documents included Describe actions taken or will be taken to correct violation: Page 2 of 8