VIOLATION 1: PRIOR TO MARCH 24, 2009, THE RADFORD ARMY AMMUNITION PLANT FAILED TO COMPLY WITH TANK UPGRADING REQUIREMENTS BY FAILING TO PERFORM A RE-INSPECTION WITH TEN YEARS OF INSTALLATION ON TWO UNDERGROUND STORAGE TANKS AS REQUIRED BY 9 VAC 25-580-60(2)(a)(2), IN VIOLATION OF 9 VAC 25-580-60(2)(a)(2) AND 40 CFR PART 280.21(b)(1)(ii).
VIOLATION 2: PRIOR TO MARCH 24, 2009, THE RADFORD ARMY AMMUNITION PLANT FAILED TO COMPLY WITH OPERATION AND MAINTENANCE OF CORROSION PROTECTION BY FAILING TO PERFORM CATHODIC PROTECTION TESTING EVERY THREE YEARS ON TWO UNDERGROUND STORAGE TANKS AS REQUIRED BY 9 VAC 25-580-80(B)(2), IN VIOLATION OF 40 C.F.R. PART 280.31(b).