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i 1 i I I The following is an itemized list of aboveground petroleum storage act violations that ! have not been addressed for CALAMCO as of April 26, 2019. 4' f Open violations from December 17, 2018 inspection I Violation #601 -Failure of Plan to fulfill basic requirements including a cross-referencing section. The Spill Prevention, Control, and Countermeasure (SPCC) Plan does not follow the order or requirements in 40 CFR Part 112, and a cross-reference was not provided. If you do not follow the sequence specified in 40 CFR 112 for the Plan, you must prepare an equivalent Plan and supplement it with a section cross-referencing the location of requirements in 40 CFR 112 and the equivalent Plan. Immediately amend the SPCC Plan to include a cross-reference or to follow the required sequence. Violation #613 -Failure to provide appropriate secondary containment, diversionary structures or equipment. Secondary containment was not observed for the 110 gallon diesel tank connected to a generator. A facility shall provide appropriate containment and/or diversionary structures or equipment to prevent a discharge. The entire containment system, including walls and floor, must be capable of containing oil and must be constructed so that I any discharge from a primary containment system will not escape the containment system before cleanup occurs. Immediately provide adequate secondary containment for all aboveground petroleum storage containers larger than 55 gallons. Violation #623 - Plan failed to address security of site and valves, lock out/tag out, and lighting. The Spill Prevention, Control, and Countermeasure (SPCC) Plan did not include discussion of security lighting. The SPCC Plan must include descriptions of how you secure and control access to the oil handling, processing & storage areas, secure master flow&drain valves, prevent unauthorized access to starter controls on oil pumps, secure out-of-service and loading/unloading connections of oil pipelines, and address the appropriateness of security lighting to both prevent acts of vandalism and assist in the discovery of oil discharges. Immediately update the SPCC Plan to include all of the required security information, or provide equivalence as allowed by 40 CFR 112.7(a)(2). ii Violation #706 - Failed to provide and maintain adequate secondary containment. The SPCC plan does not state whether or not the secondary containment is sufficient for the waste oil tank which is estimated to be 1,000 gallons, the two generators, one with capacity of 110 gallons and the other estimated to be over 200 gallons and drums. The plan states that secondary containments exists for several of the tanks but does not certify that the entire capacity of the tanks and sufficient freeboard to contain precipitation. Secondary containment for the 110 gallon generator tank is not addressed in the plan. All bulk storage tanks must be provided ` with a secondary means of containment for the entire capacity of the tank and sufficient freeboard to contain i precipitation. Immediately provide sufficient secondary containment for this and all other tanks at this facility. i I Violation#710 -Plan failed to adequately discuss procedures to test or inspect each container for integrity. The SPCC references the STI SP-001 standard but fails to follow the standards requirements. Yearly inspections of the tanks are not addressed in the plan. Qualifications of personnel performing tests and inspections, frequency and type of testing and inspections are not discussed in the plan. The 20,000 gallon diesel tank was said to be over 20 years old and may be due for a formal inspection. 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 i 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). i Page 1 of 2