TITLE 41: FIRE PROTECTION
CHAPTER I: OFFICE OF THE STATE FIRE MARSHAL
PART 172 PETROLEUM EQUIPMENT CONTRACTOR LICENSING
SECTION 172.APPENDIX A CONTRACTOR VIOLATIONS



Section 172.APPENDIX A  Contractor Violations

 

Listed in this Appendix are areas where a contractor could receive a Contractor Notice of Violation (CNOV). The identification of an area as Group A, B or C corresponds to the nature of the violation, e.g., administrative, quality control or safety. In addition to the violations identified in this Appendix, a contractor can receive a CNOV for any action that, in the opinion of the OSFM, poses imminent danger to the environment or the health and safety of citizens of Illinois.

 

a)         Group A Violations

 

1)         Violations Related to Design, Construction, Installation or Upgrade

 

A)        Contractor failed to conduct on-site inspection to insure accuracy of site plans; didn’t include sewers, places of assembly next door, school day care center, nursing home, basement, etc., within distance requirements. (See 41 Ill. Adm. Code 170.420(c)(5).)

 

B)        Contractor failed to have completed notification form. (See 41 Ill. Adm. Code 170.420(c)(16).)

 

C)        Contractor failed to complete contractor section of notification form. (See 41 Ill. Adm. Code 170.420(d).)

 

D)        Contractor failed to have an employee certified in the UST module in which work is being performed, on the job site, supervising non-certified employees and subcontractors. (See Section 172.50(c).)

 

E)         Contractor failed to make sure the certified employee possessed a valid wallet card verifying successful passage of OSFM approved exams. (See Section 172.50(d).)

 

F)         Certified employee failed to carry the valid wallet card on the UST job site at all times or failed to have it available to present to the OSFM representative upon request. (See Section 172.50(d).)

 

G)        Contractor and any of its employees failed to possess a valid OSHA Identification Card as described in Section 172.60. (See 41 Ill. Adm. Code 172.50(f).)

 

H)        Contractors, their certified employees, non-certified employees and subcontracted excavation operators all working in UST related operations failed to possess a valid 40-hour General Site Worker Program Identification Card or any valid Refresher Card on the UST job site at all times or failed to have it available to present to the OSFM representative upon request. (See Section 172.60(a).)

 

I)          Contractor failed to provide OSFM with written proof of re-certification for a used tank. (See 41 Ill. Adm. Code 170.420(a)(6).)

 

J)         Work began before securing proper permits. (See 41 Ill. Adm. Code 170.420(c)(4).)

 

K)        Work began before receiving stamped acknowledgement from OSFM. (See 41 Ill. Adm. Code 170.420(c)(4).)

 

L)         Work began before submission of job work schedule. (See 41 Ill. Adm. Code 170.420(c)(4).)

 

M)       Work began before work start date on job work schedule. (See 41 Ill. Adm. Code 170.420(c)(4).)

 

N)        Contractor failed to be ready for date certain/time certain activity of final inspection. (See 41 Ill. Adm. Code 170.420(c)(16) and (c)(19)(C).)

 

O)        Contractor failed to have rust resisting di-electric coating repaired before installation. (See 41 Ill. Adm. Code 170.420(a)(2).)

 

P)         Contractor failed to meet time certain/date certain activity deadline. (See 41 Ill. Adm. Code 170.420(c)(19)(C).)

 

2)         Violations Related to Vents and Piping

 

A)        Contractor failed to submit pipe construction and corrosion protection that is different from fiberglass or cathodically protected steel to OSFM for written approval. (See 41 Ill. Adm. Code 170.421(d)(2)(E).)

 

B)        Contractor failed to have written approval from OSFM available at job site. (See 41 Ill. Adm. Code 170.421(d)(2)(E).)

 

3)         Violations Related to Interior Lining

 

A)        Contractor failed to have a complete set of OSFM reporting forms on site before entering process began. (See 41 Ill. Adm. Code 170.430(b)(3).)

 

B)        Testing contractor failed to submit the test results within 10 days after a passed inspection. (See 41 Ill. Adm. Code 170.430(b)(6).)

 

C)        Contractor failed to submit documentation of all inspection data within 10 days after a passed inspection. (See 41 Ill. Adm. Code 170.430(b)(7).)

 

D)        Contractor failed to submit documentation within 10 days after repairs to the coating. (See 41 Ill. Adm. Code 170.430(b)(7).)

 

E)         Contractor failed to have all testing equipment on site and functional before opening the tank. (See 41 Ill. Adm. Code 170.430(b)(3).)

 

4)         Violations Related to Cathodic Protection

 

A)        Contractor failed to submit a job work schedule before starting work. (See 41 Ill. Adm. Code 170.460(e)(1).)

 

B)        Contractor failed to submit accurate drawings/plans because he failed to conduct an on-site inspection before applying for permit. (See 41 Ill. Adm. Code 170.460(e)(2).)

 

C)        Field-designed cathodic protection system installed by contractor was not designed by a corrosion expert recognized by OSFM. (See 41 Ill. Adm. Code 170.420(a)(2)(B).)

 

5)         Violations Related to Obtaining Permits

 

A)        Contractor did not schedule a date and time certain final inspection. (See 41 Ill. Adm. Code 170.541(h)(3)(D).)

 

B)        Contractor did not have a representative at the final inspection that was knowledgeable and had ability to work the equipment being inspected. (See 41 Ill. Adm. Code 170.541(h)(3)(D).)

 

C)        Replacement of any of the equipment described in section 170.541 (h)(1) was not reported in writing to the OSFM on an OSFM form within 24 hours. (See 41 Ill. Adm. Code 170.541(h)(4).)

 

D)        Contractor did not notify the OSFM within 8 working hours that an original 0.1 GPM electronic line leak detector had been replaced after a temporary mechanical line leak detector had been substituted. (See 41 Ill. Adm. Code 170.541(h)(5).)

 

6)         Violations Related to the Tester of UST Equipment

 

A)        The testing contractor did not submit test results to the OSFM on forms prescribed by the OSFM. (See 41 Ill. Adm. Code 170.544(b)(4).)

 

B)        Contractor did not have a representative at the final inspection that was knowledgeable and had ability to work the equipment being inspected. (See 41 Ill. Adm. Code 170.541(h)(3)(D).)

 

C)        The testing contractor failed to issue a copy of passing test results to the facility and owner. (See 41 Ill. Adm. Code 170.544(b)(1).)

 

D)        The contractor failed to replace an original 0.1 GPM electronic line leak detector after 10 working days while substituting with a mechanical line leak detector. (See 41 Ill. Adm. Code 170.541(h)(5).)

 

b)         Group B Violations

 

1)         Violations Related to Design, Construction, Installation or Upgrade

 

A)        Contractor replaced a spill basin with one of less than the minimum 5-gallon capacity. (See 41 Ill. Adm. Code 170.420(b)(1)(A).)

 

B)        Contractor installed a float vent valve for overfill prevention on a suction system. (See 41 Ill. Adm. Code 170.420(b)(1)(C).)

 

C)        Contractor failed to inspect the tanks, pipe or other equipment upon delivery and prior to installation. (See 41 Ill. Adm. Code 170.420(c)(7).)

 

D)        Contractor failed to properly test tanks before installation. (See 41 Ill. Adm. Code 170.420(c)(10).)

 

E)         Contractor failed to have pipe trenches wide enough or deep enough or sloped to tanks properly, or to have pipes spaced properly. (See 41 Ill. Adm. Code 170.420(c)(12).)

 

F)         Contractor failed to have the trenches backfilled with acceptable material. (See 41 Ill. Adm. Code 170.420(c)(12).)

 

G)        Contractor failed to have electrical equipment installed in accordance with NFPA 70. (See 41 Ill. Adm. Code 170.420(c)(15).)

 

H)        Contractor failed to have sealant compound installed in all seal-offs. (See 41 Ill. Adm. Code 170.420(c)(15).)

 

I)          Contractor failed to have junction boxes closed properly. (See 41 Ill. Adm. Code 170.420(c)(15).)

 

J)         Contractor failed to install acceptable observation wells or the proper number of wells. (See 41 Ill. Adm. Code 170.420(c)(18).)

 

K)        Contractor failed to install containment under dispensers at the time of new installation. (See 41 Ill. Adm. Code 170.420(c)(19).)

 

L)         Contractor failed to install containment under dispensers of existing sites when pipe is replaced. (See 41 Ill. Adm. Code 170.420(c)(19).)

 

M)       Contractor failed to meet the hydrostatic testing requirements on all containment before backfilling. (See 41 Ill. Adm. Code 170.420(c)(19).)

 

N)        Contractor failed to provide adequate lighting to be able to continue working after sunset. (See 41 Ill. Adm. Code 170.420(c)(21).)

 

2)         Violations Related to Corrosion Protection

 

A)        Contractor failed to protect pipe that is in contact with the ground, backfill, or water from corrosion. (See 41 Ill. Adm. Code 170.420(d) and 170.460(d).)

 

B)        Contractor failed to di-electrically protect all steel risers, vents and fillpipes in contact with the ground, backfill or water. (See 41 Ill. Adm. Code 170.421(d) and 170.460(d).)

 

C)        Contractor installed unacceptable shrink-wrap or boots for cathodic protection in a water environment. (See 41 Ill. Adm. Code 170.460(d).)

 

D)        Contractor used less than #10 stranded wire for installation of wiring connected to anodes of an impressed current system. (See 41 Ill. Adm. Code 170.460(e)(4)(A).)

 

E)         Contractor failed to install the associated electrical equipment in conformance with NFPA 70. (See 41 Ill. Adm. Code 170.460(e)(4)(A)-(E).)

 

3)         Violations Related to Piping, Vents and Pumps

 

A)        Contractor failed to install a positive shut-off valve on the product line at the submersible or at the tank for suction systems on new installations or existing installations when pipe is replaced. (See 41 Ill. Adm. Code 170.421(g).)

 

B)        Contractor failed to make the shut-off valve accessible to grade. (See 41 Ill. Adm. Code 170.421(g).)

 

C)        Contractor failed to have vent lines ready for date certain/time certain test activity. (See 41 Ill. Adm. Code 170.421(h).)

 

D)        Contractor failed to conduct a precision line test before the pipe was put back into service. (See 41 Ill. Adm. Code 170.421(k).)

 

E)         Contractor manifolded vent pipes underground. (See 41 Ill. Adm. Code 170.424(a).)

 

F)         Contractor installed vent pipes in locations not approved on the permit. (See 41 Ill. Adm. Code 170.424(d).)

 

G)        Contractor attached vents of Class II and Class III products to vents of Class I products (i.e., motor oil and diesel to gasoline). (See 41 Ill. Adm. Code 170.424(e)(1)(C).)

 

H)        Contractor failed to provide adequate collision protection for vent pipe risers. (See 41 Ill. Adm. Code 170.424(g).)

 

I)          Contractor failed to secure OSFM approval for remote fill pipes. (See 41 Ill. Adm. Code 170.425(a).)

 

J)         Contractor failed to color code or label the fill pipes. (See 41 Ill. Adm. Code 170.425(d).)

 

K)        Contractor failed to install a power source interrupter (emergency cut-off switch) 20-100 feet away from the dispensing area. (See 41 Ill. Adm. Code 170.426(a) and 170.428(g).)

 

L)         Contractor installed a dispensing device at a marina where there isn’t enough room for safe ingress and egress of watercraft. (See 41 Ill. Adm. Code 170.426(j).)

 

M)       Contractor failed to properly seal openings beneath the dispensing pumps at marinas. (See 41 Ill. Adm. Code 170.426(j).)

 

N)        Contractor failed to install a hose retracting device for hoses longer than 18 feet. (See 41 Ill. Adm. Code 170.426(n).)

 

O)        Contractor installed dispenser pumps too close (within 5 feet) of the building. (See 41 Ill. Adm. Code 170.426(o).)

 

P)         Contractor failed to provide adequate collision protection for dispenser pumps. (See 41 Ill. Adm. Code 170.426(o) and 170.428(h).)

 

Q)        Contractor failed to install a readily accessible shut-off valve for product supply from shore to the pier dispensers. (See 41 Ill. Adm. Code 170.428(e).)

 

R)        Contractor failed to install emergency breakaway devices on the dispensing hose. (See 41 Ill. Adm. Code 170.428(j).)

 

4)         Violations Related to Interior Lining

Contractor failed to present to the STSS the confined space entry permit for the job, while employee inside tank. (See 41 Ill. Adm. Code 170.430(c)(2).)

 

5)         Violations Related to Obtaining Permits

Contractor failed to secure an inspection permit when using an alternate method for inspection. (See 41 Ill. Adm. Code 170.430(b)(9).)

 

c)         Group C Violations

 

1)         Violations Related to Design, Construction, Installation or Upgrade

 

A)        Contractor did not have equipment heavy enough to lift tank and dropped it. (See 41 Ill. Adm. Code 170.420(a)(3).)

 

B)        Contractor excavated too close to existing foundation and caused damage, building shift or building collapse. (See 41 Ill. Adm. Code 170.420(c)(1).)

 

C)        Contractor failed to have equipment with sufficient lift. (See 41 Ill. Adm. Code 170.420(c)(6).)

 

D)        Contractor failed to provide excavation sloping, benching, stepping, or shoring sides. (See 41 Ill. Adm. Code 170.420(c)(9).)

 

E)         Contractor failed to install anchoring or ballasting in water environment and tanks floated. (See 41 Ill. Adm. Code 170.420(c)(11).)

 

2)         Violations Related to General Requirements for Dispensing

Contractor has rigged emergency shut-off valve to remain open at all times. (See 41 Ill. Adm. Code 170.428(k).)

 

3)         Violations Related to Interior Lining

 

A)         Contractor failed to comply with entry procedures outlined in API 2015 and 2015A. (See 41 Ill. Adm. Code 170.430(a)(1)(A).)

 

B)         Contractor failed to check oxygen levels inside tank. (See 41 Ill. Adm. Code 170.430(a)(1)(A).)

 

C)        Contractor failed to have positive pressure air supplied equipment on site and/or functioning. (See 41 Ill. Adm. Code 170.430(a)(1)(A).)

 

D)        Contractor failed to have a full face enclosure on his employee. (See 41 Ill. Adm. Code 170.430(a)(1)(A).)

 

E)         Contractor failed to have a safety harness on the employee who enters the tank. (See 41 Ill. Adm. Code 170.430(a)(1)(A).)

 

F)         Contractor failed to have sufficient numbers of employees to provide an attendant while employee was in the tank. (See 41 Ill. Adm. Code 170.430(a)(1)(A).)

 

G)        Contractor has failed to require employees to wear clothing that covers the arms, legs, torso, and head of tank entry personnel. (See 41 Ill. Adm. Code 170.430(a)(1)(A).)

 

H)        Contractor failed to require employee to remove clothing saturated with product upon immediate departure of tank. (See 41 Ill. Adm. Code 170.430(a)(1)(A).)

 

I)          Contractor failed to familiarize employees with ANSI Z117.1 – Safe Confined Space Entry. (See 41 Ill. Adm. Code 170.430(a)(1)(A).)

 

J)         Contractor failed to periodically monitor with a CGI and O2 monitor. (See 41 Ill. Adm. Code 170.430(a)(1)(A).)

 

K)        Contractor failed to cap or plug all other product lines and openings to ensure no liquid or vapor enters the tank. (See 41 Ill. Adm. Code 170.430(a)(1)(A).)

 

L)        Contractor failed to stop work that released flammable vapors while heater was being used to cure the lining material. (See 41 Ill. Adm. Code 170.430(a)(1)(B).)

 

M)       Contractor failed to attend the heater when in operation. (See 41 Ill. Adm. Code 170.430(a)(1)(B).)

 

N)        Contractor failed to secure a lining inspection permit in order to complete the 10-year or 5-year internal inspection. (See 41 Ill. Adm. Code 170.430(a)(1)(G).)

 

O)        Contractor used spark producing welding to repair inside the tank. (See 41 Ill. Adm. Code 170.430(b)(2)(A)(ii).)

 

P)         Contractor used spark producing cutting device to repair inside the tank. (See 41 Ill. Adm. Code 170.430(b)(2)(A)(ii).)

 

Q)        Contractor failed to maintain exclusion zone. (See 41 Ill. Adm. Code 170.430(c)(4).)

 

R)        Contractor caught smoking inside the exclusion zone. (See 41 Ill. Adm. Code 170.430(c)(4).)

 

S)         Contractor used spark-producing/non-explosion proof equipment inside the exclusion zone. (See 41 Ill. Adm. Code 170.430(c)(4).)

 

T)         Contractor failed to isolate the product lines. (See 41 Ill. Adm. Code 170.430(c)(5).)

 

U)        Contractor failed to isolate manifolds. (See 41 Ill. Adm. Code 170.430(c)(5).)

 

V)       Contractor failed to isolate siphons. (See 41 Ill. Adm. Code 170.430(c)(5).)

 

W)       Contractor failed to isolate manifolded vent systems. (See 41 Ill. Adm. Code 170.430(c)(5).)

 

X)        Contractor failed to remove residual liquids from tank with explosion-proof pump. (See 41 Ill. Adm. Code 170.430(c)(6).)

 

Y)        Contractor failed to regularly monitor the excavation area with a CGI. (See 41 Ill. Adm. Code 170.430(c)(7).)

 

Z)         Contractor failed to maintain the levels of 5% LEL (lower explosive lmits) or O2. (See 41 Ill. Adm. Code 170.430(c)(7).)

 

AA)      Vapor freeing not done in accordance with API 1631 Section 2.4. (See 41 Ill. Adm. Code 170.430(c)(8).)

 

BB)      Contractor failed to have all devices bonded to the tank when using compressed air or inert gas under pressure. (See 41 Ill. Adm. Code 170.430(c)(8).)

 

CC)     Contractor failed to have the tank grounded to a separate ground when vapor freeing. (See 41 Ill. Adm. Code 170.430(c)(8).)

 

DD)     Contractor failed to have a pressure gauge on the cylinder for inert gas. (See 41 Ill. Adm. Code 170.430(c)(8).)

 

EE)      Contractor failed to have an operational pressure gauge on the cylinder for inert gas. (See 41 Ill. Adm. Code 170.430(c)(8).)

 

FF)      Contractor used higher than 5 psi discharge into the tank for vapor freeing. (See 41 Ill. Adm. Code 170.430(c)(8).)

 

GG)      Contractor did not test grounding and bonding for continuity. (See 41 Ill. Adm. Code 170.430(c)(8).)

 

HH)      Contractor commenced cutting/opening procedures/cleaning procedures before STSS arrived. (See 41 Ill. Adm. Code 170.430(c)(9).)

 

II)         Contractor used plastic tile or plywood for manway access to the surface – neither are non-collapsible structures. (See 41 Ill. Adm. Code 170.430(c)(10).)

 

JJ)        Personal protective equipment was not provided for personnel in accordance with API 1631. (See 41 Ill. Adm. Code 170.430(c)(11).)

 

KK)     Contractor failed to maintain a positive continual flow of fresh air into the tank once classified as non-hazardous and in lieu of supplied air. (See 41 Ill. Adm. Code 170.430(c)(15).)

 

LL)       Contractor failed to provide continuous monitoring during the operation. (See 41 Ill. Adm. Code 170.430(c)(15).)

 

4)         Violations Related to Cathodic Protection

 

A)        Contractor failed to vapor free the tank before introducing an electrified video camera into the interior for the purpose of inspection prior to installing cathodic protection. (See 41 Ill. Adm. Code 170.460(a)(1)(B)(ii).)

 

B)        Contractor had a remote camera with a short in the electrical system. (See 41 Ill. Adm. Code 170.460(a)(1)(B)(ii).)

 

C)        Contractor had a lighting source that was not suitable for this

application. (See 41 Ill. Adm. Code 170.460(a)(1)(B)(ii).)

 

5)         Violations Related to Emergency Repairs Allowed

Contractor failed to notify OSFM of request for authorization to proceed for emergency repair. (See 41 Ill. Adm. Code 170.481(d).)

 

6)         Violations Related to Installer, Repairer, Liner or Remover of USTs and Obtaining Permits

 

A)        Contractor failed to obtain a permit in advance to install a UST. (See 41 Ill. Adm. Code 170.541(a).)

 

B)        Contractor failed to obtain a permit in advance to repair a UST. (See 41 Ill. Adm. Code 170.541(a).)

 

C)        Contractor failed to obtain a permit in advance to line a UST. (See 41 Ill. Adm. Code 170.541(a).)

 

D)        Contractor failed to obtain a permit in advance to perform lining touch up work on a UST. (See 41 Ill. Adm. Code 170.541(a).)

 

E)         Contractor failed to obtain a permit in advance to perform a lining inspection on a UST. (See 41 Ill. Adm. Code 170.541(a).)

 

F)         Contractor failed to obtain a permit in advance to install cathodic protection on a UST. (See 41 Ill. Adm. Code 170.541(a).)

 

G)        Contractor failed to obtain a permit in advance to abandon-in-place a UST. (See 41 Ill. Adm. Code 170.541(a) and 170.670(d)(2)(H)(i).)

 

H)        Contractor failed to obtain a permit in advance to upgrade a UST. (See 41 Ill. Adm. Code 170.541(a).)

 

I)          Contractor failed to obtain a permit in advance to remove a UST. (See 41 Ill. Adm. Code 170.541(a).)

 

J)         Contractor did regulated UST activities with an expired permit. (See 41 Ill. Adm. Code 170.541(a)(7).)

 

K)        The contractor performed UST activities that were not in compliance with the conditions of a permit issued to that contractor. (See 41 Ill. Adm. Code 170.541(e).)

 

7)         Violations Related to Notification and Establishment of Time Certain and Date Certain for UST Activity

 

A)        The contractor failed to schedule a date certain with the OSFM to

perform UST activities relating to removals, abandonment‑in‑place, repair or lining of any tank entry. (See 41 Ill. Adm. Code 170.543(a)(2)(A).)

 

B)        The contractor performed work without the OSFM STSS present, while removal, abandonment-in-place, tank entry, interior lining, lining inspect, or installation of manway (except in cases where manway installation is a part of aligning permit or lining inspection permit) activities were being performed. (See 41 Ill. Adm. Code 170.543(a)(2)(B).)

 

8)         Violations Related to Tester of USTs and UST Equipment

The contractor had an employee performing precision tank and piping test who was not trained by the manufacturer of the testing equipment he was using to conduct the test. (See 41 Ill. Adm. Code 170.544(a)(2)(B).)

 

9)         Violations Related to Removal or Abandonment-in-Place of USTs

 

A)        Contractor did not remove all petroleum or hazardous substance from the tank or connecting lines prior to the removal process. (See 41 Ill. Adm. Code 170.670(a)(1).)

 

B)        The contractor did not follow all parts of recommended practice API 1604 before the removal process and at any time thereafter. (See 41 Ill. Adm. Code 170.670(a)(4).)

 

C)        The contractor did not establish an exclusion zone around the tank excavation during the removal process. (See 41 Ill. Adm. Code 170.670(c)(3).)

 

D)        The contractor had employees and/or subcontractor employees smoking within the exclusion zone during the removal process. (See 41 Ill. Adm. Code 170.670(c)(3).)

 

E)         The contractor did not use explosion-proof pumps to remove liquids      from the tanks prior to removal process. (See 41 Ill. Adm. Code 170.670(c)(5).)

 

F)         The contractor used a plastic pipe to suck product out of a tank prior to removal. (See 41 Ill. Adm. Code 170.670(c)(5).)

 

G)        The contractor did not properly monitor the tank atmosphere down to the bottom of the tank or the excavation area. (See 41 Ill. Adm. Code 170.670(c)(6) and (d)(2)(H)(vii).)

 

H)        While vapor freeing a tank with compressed air, the contractor did not bond all devices to the tank or properly ground the tank to a separate ground. (See 41 Ill. Adm. Code 170.670(c)(8) or (d)(2)(H)(viii).)

 

I)          While vapor freeing a tank for removal, plastic pipes were used as vent tubes on eductors. (See 41 Ill. Adm. Code 170.670(c)(8).)

 

J)         The contractor excavated along the side or end of a tank prior to vapor freeing or inerting the tank itself. (See 41 Ill. Adm. Code 170.670(c)(10).)

 

K)        The contractor began cutting and cleaning operations before OSFM STSS was on site for a tank removal inspection. (See 41 Ill. Adm. Code 170.670(c)(11).)

 

L)         The contractor did not have one or more of the following elements for personal protection of the tank cleaning personnel on site:

 

Supplied air with full face mask.

 

Level B personal protective equipment with body harness and tag line.

 

Protective booties.

 

Continual monitoring of LEL and O2 during cleaning.

 

Attendant/observer.

 

Confined space entry permit to include MSDS sheets.

 

Positive flow of fresh air supplied during the cleaning operations. (See 41 Ill. Adm. Code 170.670(c)(12)(G).)

 

M)       The contractor did not follow API 1604 Section 4.2.3 when using continuous spark producing equipment to cut the tank open after removal. (See 41 Ill. Adm. Code 170.670(c)(16).)

 

N)        When it was found that a tank had been removed without a permit and the tank was still on site and aboveground, the contractor who removed the tank illegally did not put the tank back into the excavation and cover it with backfill until a proper removal permit was obtained. (See 41 Ill. Adm. Code 170.670(c).)

 

O)        While filling a tank for abandonment-in-place, the contractor failed to follow API-recommended practice 1604. (See 41 Ill. Adm. Code 170.670(d)(2)(C).)

 

P)         The contractor did not establish an exclusion zone around the tank excavation during the abandonment-in-place process. (See 41 Ill. Adm. Code 170.670(d)(2)(H)(iv).)

 

Q)        The contractor was found using spark-producing/non-explosion proof equipment in the vapor hazard area during an abandonment-in-place process. (See 41 Ill. Adm. Code 170.670(d)(2)(H)(iv).)

 

R)        The contractor had employees and/or subcontractor employees smoking within the exclusion zone during the abandonment-in-place process. (See 41 Ill. Adm. Code 170.670(d)(2)(H)(iv).)

 

S)         The contractor did not use explosion-proof pumps to remove liquids from the tanks prior to the abandonment-in-place process. (See 41 Ill. Adm. Code 170.670(d)(2)(H)(vi).)

 

T)         The contractor did not follow API 1604 while vapor freeing a tank for abandonment-in-place. (See 41 Ill. Adm. Code 170.670(d)(2)(H)(viii).)

 

U)        The contractor began cutting and cleaning operations before OSFM STSS was on site for abandonment-in-place inspections. (See 41 Ill. Adm. Code 170.670(d)(2)(H)(x).)

 

V)        During the cleaning procedures for an abandonment-in-place job, the contractor did not follow API-recommended practice 2015 that requires a type of respiratory equipment that provides positive air pressure to a full-face mask throughout the breathing cycle. (See 41 Ill. Adm. Code 170.670(d)(2)(H)(xii).)