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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 Violation Report Regulation/Code Item k Violation Class Remarks Inspection Report Action Item Status CFR 112.7(()(2) 615 Class II FAILEDTO DESIGNATE A PERSON ACCOUNTABLE FOR DISCHARGE PREVENTION CFR 112.7(9(2) Failed to designate a person accountable for discharge prevention. This facility does not have a designated person for discharge The sitewide SPCC Plan will include an individual's or individuals Violation acknowledged. prevention. The SPCC Plan for building 801 states that the designated person is the "Operations Facility Manager" but does not specify a specific names that are accountable for discharge prevention. person by name. The Spill Prevention, Control, and Countermeasure (SPCC) Plan shall designate a person at the facility who is accountable for Revised SPCC Plan in progress -- Requesting discharge prevention and who reports to facility management. Immediately designate a person to be accountable for discharge prevention and due date from CUPA of May 4, 2016 update the SPCC Plan to Include this information. CFR 112.7(g) 617 Class 11 PLAN FAILED TO ADDRESS SECURITY OF SITE AND VALVES, LOCK OUT/TAG OUT, AND LIGHTING CFR 112.7(g) Plan failed to address security of site and valves , lock out/tag out, and lighting. The sitewide SPCC Plan will include a description of lighting in Violation acknowledged. The Spill Prevention, Control, and Countermeasure (SPCC) Plan did not include a complete discussion of security lighting. The SPCC Plan for building the context of vandalism and assisting in the discovery of oil 801 discussed the lighting provided for tank transfer I fuel delivery operations, but did not address vandalism prevention or discharge discovery. discharges. Revised SPCC Plan in progress -- Requesting The SPCC Plan must include descriptions of how you secure and control access to the oil handling, processing & storage areas, secure master Row due date from CUPA of May 4, 2016 & drain valves, prevent unauthorized access to starter controls on oil pumps, secure out -of -service and loading/unloading connections of oil pipelines, and address the appropriateness of security lighting to both prevent acts of vandalism and assist in the discovery of oil discharges. Immediately update the SPCC Plan to include all of the required security information, or provide equivalence as allowed by 40 CFR 112.7(a)(2) . CFR [)(6) 713 Class 1I Class I FAIL TO PERFORM SCHEDULED TANK TESTS AND INSPECTIONS BY APPROPRIATELY QUALIFIED PERSONNEL CFR 112.8(c)(6) Failed to perform scheduled tank tests and inspections by appropriately qualified personnel. The Dlala oil tank for building 801 was The sitewide SPCC Plan will clearly define at what point Integrity Violation acknowledged. not tested for Integrity. According to the SPCC Plan, visual inspections will be used for Integrity testing unless problems are detected. The monthly testing is required If there is an Indication of an issue with a tank Inspection records being maintained by Mr. Tom McWilliams (the building APSA "operator") have marked for many months that there is liquid piece of equipment. These decision points should be clearly Revised SPCC Plan in progress -- Requesting visible in the secondary containment or berm and that the exterior coating is bubbling, cracked, or damaged. When questioned about what kind of defined and based on the judgment of the PE. due date from CUPA of May 4, 2016 "problems" noted during the monthly Inspections would trigger additional integrity testing, Mr. McWilliams stated that he monitors the tank inventory levels and would take action If the levels indicated a loss of product. Each aboveground container shall be tested and Inspected for integrity on a regular schedule and whenever r repairs are made. The qualifications of personnel performing tests and Inspections, frequency and type of testing and inspections that take Into account container size, configuration , and design shall be determined in accordance with industry standards. Examples of these Integrity tests include, but are not limited to: visual Inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other systems of non-destructive testing. Comparison records and other records of inspections and tests must be maintained on site. Immediately conduct the necessary testing and submit a copy of the test results to the EHD, or provide equivalence as allowed by CFR 112.7(a)(2). CFR 112.8(c)(8)(v) 717 Class II FAILED TO REGULARLY TEST LIQUID LEVEL SENSING DEVICES TO ENSURE PROPER OPERATION CFR 112.81 Failed to regularly test liquid level sensing devices to ensure proper operation. Liquid level sensing devices have not been tested. The sitewide SPCC Plan will identify what overfill prevention Violation acknowledged. According to Mr. Tom McWilliams, the APSA "operator" at building 801, the liquid level sensing devices are looked at for determining inventory method Is used for each container. Sensing devices must be levels, but are not tested or checked for accuracy. Procedures and frequency of testing for these devices were not addressed in the Spill tested as per manufacturer's recommendations and/or industry Revised SPCC Plan in progress -- Requesting Prevention, Control, and Countermeasure (SPCC) plan. Uquid level sensing devices must be Installed in accordance with CFR 112.8 and shall be standards to ensure they are functioning properly. due date from CUPA of May 4, 2016 regularly tested to ensure proper operation. Immediately conduct all necessary testing of liquid level sensing devices, or provide equivalence as RECEIVEDallowed by CFR 112.7(a)(2). JAN 14 2016 ENVIRONMENTAL HEALTH DEPARTMENT Aboveground Petroleum Storage Act Inspection Report