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r <br /> CFR 112.80(2) Diked area is not Secondary containment was sealed with proper <br /> sufficiently impervious to contain caulking material that will withstand weathering <br /> #704 discharge oil. and application on vertical surfaces. <br /> CFR 112.8(c)(2)Failed to provide and Secondary containment was sealed with proper <br /> maintain adequate secondary caulking material that will withstand weathering <br /> #706 containment. Same as#609. and application on vertical surfaces. <br /> The SPCC does not require detailed specific testing <br /> requirements and time frames for tank integrity <br /> testing. Buckeye Terminal LLC's company <br /> integrity management plan does have the specific <br /> testing requirements and time frames. <br /> Regarding Tank 4, enclosed,you will find the <br /> Inspection Package Repairs dated 09/11/2009 from <br /> BP US Pipelines and Logistics. <br /> Regarding Tank 7,there are three inspections in the <br /> Buckeye Emissions for Storage Tanks Database. <br /> CFR 112.8(c)(6)Failed to perform There are Out of Service (OOS) inspection reports <br /> scheduled tank tests and inspections by for 1999,an in-service inspection in 2004, and an <br /> appropriately qualified personnel. The <br /> SPCC Plan does not detail specific OOS inspection in 2010. <br /> testing requirements and time frames Regard Tank 8 <br /> g , You will find the API 653 Out of <br /> for tank integrity testing. Tank 8 was <br /> not tested on schedule for integrity Service Inspection for from 10/17/2007. On page 13 <br /> testing. Tank 7 was not tested on is a recommendation that the next external visual <br /> schedule for integrity testing. Tank 4 inspection should be completed on or before <br /> API 653 integrity testing report dated 5/24/12. It was completed on 9/6/12 due to <br /> 7/14/09 indicated 28 conditions scheduling issues. <br /> requiring correction. What happened <br /> #713 to corrections? <br /> CFR 112.8(d)(4)Failed to regularly <br /> inspect aboveground valves,piping, Facility was inspected in May of 2015 by a <br /> and appurtenances. Observed some of Buckeye corrosion specialist. His report concluded <br /> facility piping northeast of Tank 3 and that piping integrity was sound. The report did <br /> beneath the metal walkways next to indicate that there was moderate, surface rust on <br /> Tank 3 and Tank 8 have rust and parts some piping that should be addressed before the <br /> #726 of the exterior coating are peeling off. next corrosion specialist inspection. <br /> After your review of the response, Buckeye Terminal,LLC personnel would like to meet with you personally to <br /> discuss. If there should be any questions or should you require information,please contact Mr. Steve Poling, <br /> HSSE Specialist at spoling_na,buckeye.com or(409)277-9699. <br /> Sincerely, <br /> Dale Thurman <br /> Director of Field Operations <br />