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MONITORING & RESPONSE PLAN- IN <br /> ARCO PRODUCTS COMPANY FACILITY WITH <br /> SINGLE WALL TANKS AND SINGLE WALL LINES <br /> ARCO Facility ZI(c Address CH g2 — Qni <br /> 1 . DETECTION METHOD <br /> Tanks - Monthly Inventory Reconciliation and Annual Tank Integrity Testing in accordance <br /> with Sections 2646 and 2643(c)(2)(A) and (B), Article 4, Title 23, CCR. <br /> Lines - Automatic Pressure Line Leak Detectors and Annual Line Tightness Testing in <br /> accordance with Section 2643 (d)(1) and (3), Article 4, Title 23, CCR. <br /> 2 . MONITORING EQUIPMENT <br /> The Automatic line leak detectors will be maintained and inspected according to the <br /> manufacturer's instructions by an outside contractor once during each calendar year. <br /> 3 . MONITORING PROCEDURE - Inventory Reconciliation <br /> Inventory reconciliation will be performed in compliance with the details of Section 2646, <br /> Article 4, Title 23, CCR (copy attached and hereby incorporated). <br /> A The daily variation in inventory reconciliation shall be the difference between <br /> physically measured inventory in storage and the calculated inventory in storage. <br /> B. The physically measured inventory shall be determined at approximately the same time <br /> each day by taking liquid level measurement (stick reading) and converting it to <br /> gallons using a calibration chart. <br /> G The calculated inventory shall be determined at approximately the same time of day for <br /> each business day by adding the inputs and subtracting the withdrawals from the <br /> physically measured inventory determined the day before. <br /> D. These variations shall be summed for a period of one month. Monthly variations <br /> exceeding a variation of 1.0 percent of the monthly tank delivery plus 130 gallons <br /> must be investigated in accordance with instructions attached. <br /> See Exhibit A for reconciliation form. <br />