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Attached is a list of open violations from the 2015,2016 and 2017 Aboveground Petroleum Storage Act <br /> (APSA)and Spill Prevention,Control,&Countermeasure(SPCC) inspection reports.Although the SPCC <br /> plan has been submitted and some of the violations were able to be closed,the remaining violations <br /> require statements or proof of compliance. <br /> 1. #603-The facility diagram or map is not complete.The facility diagram is missing the contents <br /> of the of above ground storage tanks. It is also missing the contents of the underground storage <br /> tank and the underground storage tank is not marked as exempt. <br /> 2. #613,#706- A statement will be required which indicates that adequate secondary <br /> containment has been provided for all aboveground petroleum storage containers 55 gallons or <br /> larger. <br /> 3. #618- A statement will be required which indicates that required inspections and testing are <br /> being conducted and that records will be maintained on site for three years. <br /> 4. #619—Although a training log was provided,under"subjects covered","spill clean-ups' is <br /> written in.This is part of the training but does not cover all the requirements for training. <br /> Regulations require at a minimum,oil handling personnel to be trained in the operation and <br /> maintenance of equipment to prevent discharges;discharge procedure protocols;applicable <br /> pollution control laws,rules,and regulations;general facility operations;and the contents of the <br /> Spill Prevention,Control,and Countermeasure Plan. Once a training that meets the <br /> requirements has been conducted,provide a statement <br /> 5. #621-Although a training log was provided,under"subjects covered" "spill clean-ups' is <br /> written in. Regulations require that briefings must highlight and describe known discharges or <br /> failures,malfunctioning components,and any recently developed precautionary measures. <br /> Once a briefing that meets the requirements has been conducted,provide a statement. <br /> 6. #624—A statement will be required which indicates that the facility's SPCC plan is being <br /> implemented for all of the requirements outlined in the site's SPCC plan. <br /> 7. #714- A statement will be required which indicates that all tanks meets the requirements of <br /> having an allowed high level monitoring device. <br /> 8. #715- A statement will be required which indicates that all necessary testing of liquid level <br /> sensing devices is being conducted. <br /> 9. #717- A statement will be required which indicates that all leaks have been fixed,pooled <br /> discharges cleaned and manage according to the California Code of Regulations Title 22 <br /> hazardous waste regulations. <br /> 10. #723-A statement will be required which indicates that all aboveground valves,piping,and <br /> appurtenances have been inspected and that you will ensure inspections are done regularly. <br /> 11. #724-A statement will be required which indicates why the buried piping has not had an <br /> integrity testing performed at the time of installation,modification,construction,relocation or <br /> replacement.Testing results can be provided as well. <br /> 12. #725—The provided SPCC plan call for Warning Signs posted at appropriate locations <br /> throughout the facility to prevent vehicles from damaging aboveground piping <br /> and appurtenances.A statement will be required which indicates that signs have been posted. <br /> 13. #708 from 2016 inspection--A statement will be required which indicates if records of <br /> drainage from diked areas are being kept. Regulations require records if the following is <br /> occurring at the facility is allowing"... uncontaminated rainwater from the diked area into a <br /> storm drain or discharge of an effluent into an open watercourse,lake,or pond,bypassing the <br /> facility treatment system.." If facility meets this criteria provide statement indicating records <br /> are kept,otherwise provide statement of why facility does not need to keep records. <br /> Read over all open violations to ensure that all issues have been addressed through statements or <br /> supportive documents. <br /> Feel free to contact me with any questions or concerns. <br /> 2 <br />