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Rev date: 12.3.15 Attachment S. LLNL Violation Tracking Spreadsheet - Aboveground Petroleum Storage Act (APSA) September -October 2015 LLNL Site 300 RECEIVED Color Code Legend: Kr -----.highlight -Violation acknowledged and corrected. Orange highlight - Request to rescind violation. Yellow highlight - Corrective action in progress. SUMMARY OF VIOLATIONS (CLASS I, CLASS Il, or MINOR - Notice to Comply) JAN 14 2016 ENVIRONMENTAL HEALTH DEPARTMENT Violation Report Regulation/Code Remarks Inspection Report Action Item Status Item N Violation Class 201 CFR 112.3(d) PLAN CERTIFICATION 8Y A PROFESSIONAL ENGINEER (PE) MISSING OR INCOMPLETE CFR 112.3(d) Plan certification by a Professional Engineer (PE) missing or incomplete. The Professional Engineer (PE) certification is incomplete. The Create Sitewide SPCC Plan that includes PE certification. Violation acknowledged. facility has calculated the APSA regulated capacity separately for each building at the facility. Only buildings 801 and 883 were calculated by the facility to have APSA regulated capacity. A PE certified SPCC Plan was prepared for building 801. The SPCC Plan prepared for building 883 was a Tier Revised SPCC Plan in progress -- Requesting I template and not PE certified. The PE certification must include all of the aspects in 40 CFR 112.3(d) (1), including attesting that the PE is familiar due date from COPA of May 4, 2016 (SPCC with 40 CFR Part 112, he or his agent has visited and examined the facility, the Spill Prevention, Control, and Countermeasure (SPCC) Plan has been regulations allow six months after any prepared in accordance with good engineering practice, including Consideration of applicable industry standards, procedures have been material change to update plan) established for required inspections and testing, and the Plan Is adequate for the facility. Immediately obtain a complete PE certification for the facility's SPCC Pian. Submit a copy of the completed certification to the EHD. 604 CFR 112.7(a)(3) NO FACILITY DIAGRAM OR DIDN'T SHOW LOCATION AND CONTENTS OF CONTAINERS, TRANSFER STATIONS, AND PIPES CFR 112.7(a)(3) No facility diagram or didn't show location and contents of containers, transfer stations, and pipes. The facility has calculated the Create sitewide facility diagram that contains all required Violation acknowledged. APSA regulated capacity separately for each building at the facility and prepared separate SPCC Plans. Only buildings 801, 846, 865, and 883 have content. SPCC Plans (according to the inventories, buildings 846 and 865 do not have APSA regulated capacity I. The inventories of the additional buildings Revised SPCC Plan in progress -- Requesting at the facility were not Included on the map included in the SPCC Plans. The Spill Prevention, Control, and Countermeasure (SPCC) Plan shall include due date from CUPA of May 4, 2016 a facility diagram which must mark the location and contents of each fixed storage container and the storage area where mobile or portable containers are located. It must Identify the location of and mark as "exempt" underground tanks. It must also include all transfer stations and connecting pipes, including Intra -facility gathering lines. Immediately update the facility diagram to include all of the required Information. Submit a legible copy of the updated facility diagram to the EHD for review. 605 CFR 112.7(a)(3) PLAN FAILED TO ADDRESS FACILITY LAYOUT, OPERATIONS DISCHARGE PREVENTION METHODS AND CONTAINERS Class 11 CFR 112.7(a)(3) Plan failed to address facility layout, operations discharge prevention methods and containers. The facility has calculated the APSA Create sitewide SPCC Plan that includes all required containers Violation acknowledged. regulated capacity separately for each building at the facility and prepared separate SPCC Plans. Only buildings 801, 846, 865, and 883 have SPCC and operations discharge prevention methods for those Plans (according to the inventories, buildings 846 and 865 do not have APSA regulated capacity). The APSA regulated storage at the additional containers. Revised SPCC Plan in progress -- Requesting buildings at the facility were not Included In the SPCC Plan inventories. The following shall be addressed in the Spill Prevention, Control, and due date from CUPA of May 4, 2016 Countermeasure (SPCC) Plan: - type of oil in each fixed container and it's storage capacity. For mobile or potable containers, the type of oil and storage capacity for each container or an estimate of the potential number of mobile or portable containers, the types of oil, and anticipated storage capacities -discharge prevention measures including procedures for routine handling of products - discharge or drainage controls such as secondary containment, equipment, and procedures for the control of a discharge - - countermeasures for discharge discovery, response, and cleanup - methods of disposal of recovered materials - contact list and phone numbers for the facility response coordinator, National Response Center, cleanup contractors, and all appropriate Federal, State, and local agencies. Immediately amend the SPCC Plan to include all required information. Aboveground Petroleum Storage Act Inspection Report