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The following is an itemized list of aboveground petroleum storage act violations that have not been addressed for T&T TRUCKING INC as of July 26, 2019. Open violations from December 04,2018 inspection Violation#301 -Failed to amend Plan as necessary. The SPCC plan states that buried piping is not part of the Aboveground Storage Tank system. Piping leading from aboveground storage tanks to dispensers was observed to be buried,and corrosion protection for the buried pipes is not discussed in the SPCC plan.The SPCC plan states that the facility does not have mobile or portable above ground storage tanks. Several 55 gallon drums were observed at the facility and mentioned in other sections of the Plan.The Spill Prevention, Control, and Countermeasure(SPCC)Plan must be amended when there is a change in the facility design, construction, operation, or maintenance that materially affects its potential for a discharge,within 6 months of the change, and implemented as soon as possible, not later than 6 months following preparation of the amendment. Immediately make all necessary amendments to the SPCC Plan to accurately represent the procedures and policies currently in place at the facility. Violation#618-Failed to keep records of procedures,inspections,or integrity tests for three years. The inspection forms being used do not meet the requirements of the STI SP-001 standard called for by Spill Prevention,Control, and Countermeasure(SPCC)Plan. The 1,000 gallon gasoline tank is being inspected using Air Resources phase I and phase II inspection form. Other tanks are being visually inspected daily and the inventories of the tanks being recorded but a checklist that meets the requirements of the STI SP-001 standard is not being used. 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 and that meet the requirements of the referenced STI SP-001 industry standard. Violation#706-Failed to provide and maintain adequate secondary containment. Parts of the SPCC plan describe a berm as the secondary containment for the area described as the tank farm containing 20,000 gallon, 10,000 gallon, 12,000 gallon and 500 gallon tanks.The bermed area is described in the SPCC plan as having a capacity of 13,900 gallons,which is insufficient for the 20,000 gallon diesel tank.The plan also states that secondary containment is achieved through a retention basin with a capacity of 748,000 gallons.At the time of the inspection,the retention basin seemed to be near capacity because of recent rains and due to the water from the oil/water separator draining into the basin.This water storage diminishes the storage capacity from a potential release event from petroleum storage tanks.This storage of water in the basin is not discussed in the SPCC plan,to ensure there is sufficient capacity to contain the entire capacity of the largest tank.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 precipitation. Every tank should have a secondary containment that fulfills the requirements of the regulations and this should be reflected in the SPCC plan. Violation#711 -Failed to perform scheduled tank tests or inspections by appropriately qualified personnel. The 20,000 gallon, 12,00 gallon and 10,000 gallon tanks were not tested on schedule by a certified SP-001 inspector.The SPCC plan calls for formal inspections by a certified SP-001 inspector every 20 years. The age of the tanks could not be determined at the time of the 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 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 provide evidence that the tanks are not yet due for formal inspections or 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). Page 1 of 1