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The following is an itemized list of aboveground petroleum storage act violations that <br />have not been addressed for WILLIAMS TANK LINES as of June12, 2018. <br />Open violations from April 14, 2015 inspection <br />Violation #301 - Failed to amend Plan as necessary. <br />The SPCC Plan has not been amended to accurately represent the current operations at the facility. The plan lists <br />Mike Thomas as a designated spill personnel; according to Garth Williams, Mr. Thomas has been gone <br />approximately a year. The Plan states that the diesel tank is used a "Veeter-Root" system which gets an annual <br />overfill alarm system certification; no such system is at the facility. The Plan lists varied volume amounts for the <br />used oil totes and the volumes of their spill pallet; the totes observed on site were 220 gallons. The Spill <br />Prevention, Control, and Countermeasure (SPCC) Plan must be amended when there is a change in the facility <br />design, construction, operation, or maintenance that materially affects its potential for a discharge, within 6 months <br />of the change, and implemented as soon as possible, not later than 6 months following preparation of the <br />amendment. Immediately make all necessary amendments to the SPCC Plan to accurately represent the <br />procedures and policies currently in place at the facility. <br />Violation #302 - Failed to review Plan once every five years and/or implement any resulting amendments. <br />The Spill Prevention, Control, and Countermeasure (SPCC) Plan was written on February 22, 2010 and has not had <br />a full review and evaluation. A review and evaluation of the SPCC Plan must be conducted at least once every 5 <br />years. As a result of this review and evaluation, the SPCC Plan must be amended within 6 months of review, and <br />recertified by a Professional Engineer if any technical amendments were made. Immediately conduct a review of <br />the facility SPCC Plan and make any necessary amendments. <br />Violation #619 - Failed to train personnel on discharge prevention. <br />Oil handling personnel were not trained. The training logs provided in the SPCC Plan are not being used (Personnel <br />Response Training Log and Discharge Prevention & Safety Meeting Log. At a minimum, oil handling personnel <br />shall be trained in the operation and maintenance of equipment to prevent discharges; discharge procedure <br />protocols; applicable pollution control laws, rules, and regulations; general facility operations; and the contents of the <br />Spill Prevention, Control, and Countermeasure Plan. Immediately provide this training to all oil handling personnel <br />and submit a copy of the training log to the EHD. <br />Violation #621 - Failed to schedule and conduct discharge prevention briefings at least annually. <br />Discharge prevention briefings are not scheduled at least once a year. SPCC training was last conducted on July <br />27, 2010. Discharge prevention briefings for oil handling personnel must be scheduled and conducted at least once <br />a year to assure adequate understanding of the SPCC Plan for that facility. Such briefings must highlight and <br />describe known discharges or failures, malfunctioning components, and any recently developed precautionary <br />measures. Immediately schedule and conduct a discharge prevention briefing, ensure that they are scheduled and <br />conducted at least once a year. <br />Violation #711 - Failed to perform scheduled tank tests and inspections by appropriately qualified <br />personnel. <br />No integrity testing was observed for the petroleum tanks on site. Each aboveground container shall be tested and <br />inspected for integrity on a regular schedule and whenever repairs are made. The qualifications of personnel <br />performing tests and inspections, frequency and type of testing and inspections that take into account container <br />size, configuration, and design shall be determined in accordance with industry standards. Examples of these <br />integrity tests include, but are not limited to: visual inspection, hydrostatic testing, radiographic testing, ultrasonic <br />testing, acoustic emissions testing, or other systems of non-destructive testing. Comparison records and other <br />records of inspections and tests must be maintained on site. Immediately conduct the necessary testing and submit <br />a copy of the test results to the EHD, or provide equivalence as allowed by CFR 112.7(a)(2). <br />Violation #715 - Failed to regularly test liquid level sensing devices to ensure proper operation. <br />Liquid level sensing devices are not being regularly tested. According to the monthly tank gauge inspection form, <br />the tank gauge was inspected from June 2011 through June 2012, and has not been tested since. Procedures and <br />frequency of testing for these devices were not addressed in the Spill Prevention, Control, and Countermeasure <br />(SPCC) plan. Liquid level sensing devices must be installed in accordance with CFR 112.8 and shall be regularly <br />tested to ensure proper operation. Immediately conduct all necessary testing of liquid level sensing devices, or <br />provide equivalence as allowed by CFR 112.7(a)(2). <br />Page 1 of 2 <br />