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Violation#712—CFR 112.8(c)(6) Failed to test or inspect each container for integrity based on industry <br /> standards. <br /> Page 29 of the SPCC plan states that tanks will be inspected per SP001 standards. Facility is currently only doing <br /> monthly inspections. SP001 standard requires annual inspections in addition to the monthly inspections.The monthly <br /> inspection checklist is not substantially equivalent to the SP001 checklist.These applicable items are missing: <br /> -Are drain valves(secondary containment)closed? <br /> -Is interstitial monitoring equipment in good working condition? <br /> -Is interstice free of liquid? <br /> The SPCC plan did not include an environmental equivalence discussion for deviation from the SP001 standard. <br /> Each aboveground container shall be tested and inspected for integrity on a regular schedule and whenever repairs <br /> are made.The qualifications of personnel performing tests and inspections,frequency and type of testing and <br /> inspections that take into account container size, configuration, and design shall be determined in accordance with <br /> industry standards. 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-destructive <br /> testing. Comparison records and other records of inspections and tests must be maintained on site. Immediately <br /> ensure that the industry standard selected in the SPCC plan is fully implemented at the facility and submit proof to <br /> the EHD, or provide equivalence as allowed by CFR 112.7(a)(2). <br /> If an owner or operator deviates from applicable industry standards to develop an integrity testing program,then a <br /> PE must certify an environmentally equivalent alternative in the SPCC Plan.The Plan must provide the reason for the <br /> deviation, describe the alternative approach, and explain how it achieves environmental protection equivalent to the <br /> applicable industry standard. <br /> This is a Class II violation. <br /> Response: <br /> Per Section 17.2.6 of the Plan, OI provides regular owner inspections of the oil-containing tanks to <br /> achieve equivalent environmental protection to formal inspections by a certified inspector.See copy of <br /> updated SPCC plan. <br /> Violation#717- CFR 112.8(c)(10) Failed to promptly correct visible discharges and/or remove accumulations of <br /> oil in diked areas. <br /> The 140 gallon emergency generator was observed with visible discharge around the base of the diesel belly tank. <br /> Visible discharges which result in a loss of oil from a container, including but not limited to seams, gaskets, piping, <br /> pumps, valves, rivets, and bolts, must be promptly corrected. Immediately fix the leak, clean up the discharge and <br /> manage according to the California Code of Regulations Title 22 hazardous waste regulations. <br /> This is a repeat violation, Class II. <br /> Response: <br /> Owens has promptly cleaned the visible discharge seen on the outside of the 140 gallon diesel tank(now <br /> updated to 100 gallon). We have disposed of the oily debris using manifest 013187875FLE(Figure 4). <br /> See Appendix C for a copy of the manifest and photo of the cleaned tank(Figure 5). <br /> Violation #718- CFR 112.8(c)(11) Failed to locate properly or provide sufficient secondary containment for <br /> mobile/portable <br /> containers. <br /> These containers were observed with insufficient secondary containment: <br /> -a The 275 gallon tote of Regnis AC and the 275 gallon tote of Kleenoil 450 were observed in area D7 on the map on <br /> a secondary containment pallet.The drain of the secondary containment pallet was missing the drain cap.This was <br /> corrected on site. <br /> -b One 55 gallon drum of oily water was observed in the machine shop on a 22 gallon spill pallet. <br /> -c One 55 gallon drum of petroleum product was observed outside area D7 on a wooden pallet without secondary <br /> containment. <br /> -d One 55 gallon drum of Transmission MDL was observed inside area D7 without secondary containment. <br /> -e One green metal 55 gallon drum of oily water was observed in area D3 with a 22 gallon secondary containment <br /> pallet. <br />