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The following is an itemized list of aboveground petroleum storage act violations that have not been addressed for BET STOCKTON TERMINAL as of May06, 2017. Open violations from January 07, 2016 inspection Violation #618 - Failed to conduct inspections or maintain records for 3 years. The inspection forms being used are not the forms provided by facility Spill Prevention, Control, and Countermeasure (SPCC) Plan, and in some instances, do not contain the same information. The facility is using "Monthly In -Service Vertical Aboveground Atmospheric Tank Inspection Form. The form being used does not contain everything that the facility SPCC plan contains in Figure 4.1 -2 -Inspection Procedures which itemizes what should be inspected during the routine visual inspection and annual inspections. Inspections and tests must be conducted and stored in accordance with the written procedures developed for this facility in the SPCC Plan. Immediately begin conducting all inspections and tests in accordance with the procedures in the SPCC Plan, or amend the Plan and have it recertified by a Professional Engineer to accurately reflect the inspection procedures currently followed at the facility. Violation #619 - Failed to train personnel on discharge prevention. The documentation for oil handling personnel training on the facility Spill Prevention Control and Counter Measure Plan were not provided upon request during the inspection. At a minimum, oil handling personnel shall be trained in the operation and maintenance of equipment to prevent discharges; discharge procedure protocols; applicable pollution control laws, rules, and regulations; general facility operations; and the contents of the Spill Prevention, Control, and Countermeasure Plan. Immediately provide this training to all oil handling personnel and submit a copy of the training log to the EHD. Violation #711 - Failed to perform scheduled tank tests and inspections by appropriately qualified personnel. -The SPCC Plan does not detail the specific testing requirements and time frames for tank integrity testing. -Tank 8 was not tested on schedule for integrity testing. An API 653 inspection conducted on 10/15/07 stated that the next external visual inspection was due on or before 5/24/12. A partial inspection result (Preliminary Summary/Recommendations) dated 9/6/12 was found, but the full report was not found on site. The notes stated that "coating failures on the shell should be properly removed and recoated". -Tanks7 and was not tested on schedule for integrity testing. The tank integrity test report available on site was dated 9/14/94. -The API 653 integrity testing report for Tank dated 7/14/09 indicated 28 conditions requiring correction, including 11 which were classified as "recommendations used to accumulate shutdown lists of recommendations that must be included in future budgeting plans and turnaround/outage plans for equipment and facilities". No documents or additional reports were available indicating these corrections have been made. Each aboveground container shall be tested and inspected for integrity on a regular schedule and whenever 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). Violation #724 - Failed to regularly inspect aboveground valves, piping, and appurtenances. Facility inspection reports indicate that personnel inspect the tank lines at all supports for metal loss due to corrosion or wearing. Inspection reports indicate no issues with the facility piping. During the inspection, it was observed that some of the facility piping northeast of tank number three and beneath the metal walkways next to tank three and eight have rust and parts of the exterior coating are peeling off. All aboveground valves, piping, and appurtenances shall be regularly inspected. Immediately inspect aboveground valves, piping, and appurtenances and ensure inspections are done regularly, or provide equivalence as allowed by CFR 112.7(a). Page 1 of 1