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i i. i I The following is an itemized list of aboveground petroleum storage act violations that E have not been addressed for CALAMCO as of April 26, 2019. Open violations from December 17, 2018 inspection Violation #726 -Plan failed to adequately describe overfill prevention methods for each container. Overfill prevention methods are not discussed int the SPCC plan. Engineer or update each container installation in accordance with good engineering practice to avoid discharges. You must provide at least one of the following devices: (i) High liquid level alarms with an audible or visual signal at a constantly attended operation or surveillance station. In smaller facilities an audible air vent may suffice. (ii) High liquid level pump cutoff devices set to stop flow at a predetermined container content level. (iii) Direct audible or code signal communication between the container gauger and the pumping station. (iv)A fast response system for determining the liquid level of each bulk storage container such as digital computers, telepulse, or direct vision gauges. If you use this alternative, a person must be present to monitor gauges and the overall filling of bulk storage containers. (v)You must regularly test liquid level sensing devices to ensure proper operation. Amend the SPCC plan to meet the requirements of 40 CFR 112. Open violations from July 11, 2016 inspection Violation #711 -Failed to perform scheduled tank tests and inspections by appropriately qualified personnel. Integrity testing has not been conducted on the tank on site. The SPCC Plan did not include the specific integrity testing required for the tanks on site. 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 I 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). I i i i i l I i E t I i i Page 2 of 2