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The following is an itemized list of aboveground petroleum storage act violations that have not been addressed for PELICAN RENEWABLES LLC as of May 01, 2024. Open violations from October 26, 2022 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 were not found on site. 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: Per Edker,the facility staff has not had SPCC training, as required. Facility failed to provide annual training to the oil-handling personnel regarding the following: 1. The operation and maintenance of equipment to prevent discharges. 2. Discharge procedure protocols. 3.Applicable pollution control laws, rules, and regulations. 4. General facility operations. 5. The contents of the SPCC Plan. 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 6 of 8