COMPLIANCE INFO_2021 - Laserfiche WebLink

Home Browse Search

The following is an itemized list of aboveground petroleum storage act violations that have not been addressed for A L POWELL TRUCKING as of December 13, 2021. Open violations from October 04, 2021 inspection Violation#619-Failure to keep written records of procedures, inspections,and tests for at least three years. OBSERVATION: The facility failed to keep written procedures and records of inspections and tests, including integrity tests,for at least three years. Copies of inspection and testing records for 10/2018-10/2021 were not found on site. Page 26 of the SPCC Plan states annual inspections will be done in June and page 30 of the SPCC Plan states the annual inspections will be done in April. Monthly, annual and July 2019 formal inspection records were not available during the inspection. REGULATION GUIDANCE: 112.7(e), Conduct inspections and tests required by this part in accordance with written procedures that you or the certifying engineer develop for the facility.You must keep these written procedures and a record of the inspections and tests, signed by the appropriate supervisor or inspector,with the SPCC Plan for a period of three years. Records of inspections and tests kept under usual and customary business practices will suffice for purposes of this paragraph. 112.8(c)(6)Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs.You must determine, in accordance with industry standards,the appropriate qualifications for personnel performing tests and inspections,the frequency and type of testing and inspections,which take into account container size, configuration, and design (such as containers that are: shop-built,field-erected, skid-mounted, elevated, equipped with a liner, double-walled, or partially buried). 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.You must keep comparison records, and you must also inspect the container's supports and foundations. In addition, you must frequently inspect the outside of the container for signs of deterioration, discharges, or accumulation of oil inside diked areas. Records of inspections and tests kept under usual and customary business practices satisfy the recordkeeping requirements of this paragraph. CORRECTIVE ACTION: Inspections and tests must be conducted in accordance with the written procedures developed in the Spill Prevention, Control, and Countermeasure(SPCC) Plan. Records of these inspections and tests must be signed by the appropriate supervisor or inspector and kept on-site with the SPCC Plan for three years. Immediately locate a copy of all inspection and testing records for the last three years, maintain them on-site, and submit copies to the EHD. ❑ This violation was corrected ❑This violation will be corrected by(date): ❑ Supporting documents included Describe actions taken or will be taken to correct violation: Violation#620-Failed to train personnel on all discharge prevention details listed in this section. OBSERVATION: It appears that the oil handling personnel were not adequately trained, as required. Page 25 of the SPCC Plan required HazWoper training for at least one person on site. Page 31 of the SPCC Plan requires training records to be kept for 3 years. No SPCC Plan or HazWoper Training records were available for review during the inspection. REGULATION GUIDANCE: (f)(1)At a minimum,train your oil-handling personnel in the operation and maintenance of equipment to prevent discharges; discharge procedure protocols; applicable pollution control laws, rules, and regulations; general facility operations; and,the contents of the facility SPCC Plan. CORRECTIVE ACTION: Immediately provide adequate training to all oil handling personnel and submit a copy of the training log and training content to the EHD. Page 4 of 6