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Violation #518 - Failed to: (1) train personnel on discharge prevention; (2) designate a person <br /> to be accountable for discharge prevention; or(3) schedule prevention discharge prevention <br /> briefings at least annually <br /> According to the SPCC Plan the facility will hold semi-annual training; only one training was <br /> conducted in the last year. Aboveground petroleum storage training was last conducted on June 17, <br /> 2009. At a minimum, oil-handling personnel must be trained in the operation and maintenance of <br /> equipment to prevent discharges, discharge procedure protocols, applicable pollution control laws, <br /> rules and regulations, general facility operations, and the contents of the facility's SPCC Plan. Annual <br /> briefings must be conducted to assure adequate understanding of the SPCC Plan and highlight and <br /> describe any known discharges or failures, malfunctioning components, and any recently developed <br /> precautionary measures. Immediately conduct necessary training for all oil handling personnel in <br /> accordance with the facility SPCC Plan. Submit copies of training records to the EHD within 30 days. <br /> Violation #609 - Failed to: test each aboveground container for integrity on a regular schedule <br /> or when repairs were made; inspect containers and container supports; or keep records of <br /> inspections and tests, or provide equivalence as allowed by CFR 112.7(a)(2) <br /> Integrity testing has not been conducted on the aboveground petroleum tanks. The SPCC Plan states <br /> that visual inspections are being conducted in lieu of integrity testing. The facility shall test or inspect <br /> each aboveground container for integrity on a regular schedule and whenever you make material <br /> repairs. The facility must determine, in accordance with industry standards, the appropriate <br /> qualifications for personnel performing tests and inspections, the frequency and type of testing and <br /> inspections, which take into account container size, configuration, and design (such as containers that <br /> are: shop-built, field-erected, skid-mounted, elevated, equipped with a liner, double-walled, or partially <br /> buried). Examples of these integrity tests include, but are not limited to: visual inspection, hydrostatic <br /> testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other systems of non- <br /> destructive testing. Comparison records and other records of inspections and tests must be <br /> maintained on site with the SPCC Plan. Immediately conduct all necessary integrity testing and <br /> maintain records on site as required. <br /> Violation #614 - Failed to locate portable containers to prevent discharge or provide sufficient <br /> secondary containment capacity that will hold the volume of the largest container plus <br /> sufficient freeboard to contain precipitation <br /> The 55 gallon drum of fuel contaminated water was observed next to aboveground diesel tank without <br /> secondary containment. Portable oil storage containers must be positioned or located to prevent a <br /> discharge and shall be furnished with a secondary means of containment sufficient to contain the <br /> capacity of the largest single container with sufficient freeboard to contain precipitation. Immediately <br /> provide sufficient secondary containment for this and all other portable containers at this facility. <br /> Page 2 of 2 <br />