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CORRECTIVE ACTION STATEMENTS Item 301. CFR 112.5(a) Failed to amend Plan as necessary. Minor Violation We have identified all the hydraulic reservoirs onsite, including the emergency generator, waste accumulation drums and operational equipment with a capacity of 55 gallons or more; we are collaborating with an environmental consulting firm to amend the inclusion of identified reservoirs; a PE will certify the SPCC plan accordingly. Item 602. CFR 112.7 (a) (2) Plan failed to discuss equivalent environmental protection, if applicable. We are collaborating with an environmental consulting firm to revise section 5.4 of the SPCC plan, to describe applicable equivalent environmental protection to 300 and 500 gallons tanks;a PE will certify the SPCC plan accordingly. Item 706. CFR 112.8 (c) (2) Failed to provide and maintain adequate secondary containment. Class II violation. We are in the process to identify secondary containment for emergency generator, as well as all other storage reservoirs identified in the facility over 55 gallons, we will include this into SPCC Plan and a PE will certify accordingly. Item 711.CFR 112.8 (c) (6) Failed to perform scheduled tank tests or inspections by appropriately qualified personnel. Class II violation. We have found a company to perform required 10000 gallons tank testing, by SP-001 certified technician on mid-later February; results from inspection will be included into SPCC plant and submitted to EHS as supportive documentation. We are in the process to identify mobile refueler inspection/testing procedures; we will include this in the SPCC plan and a PE will certify accordingly. We will identify a schedule for periodic integrity testing to all AST's in accordance to industry standards or provide evidence of applicable equivalent inspection as per CFR 112.7(a) (2) to EHS; we will include this into SPCC plan and a PE will certify accordingly. Item 717. CFR 112.8(c) (10) Failed to promptly correct visible discharges and/or remove accumulations of oil in diked areas. Class II violation. We are in the process of removing any visible accumulation of oil sheen from water pond; we will use absorbent pillows to soak up observed sheen and will dispose of them as per Title 22 Hazardous Waste Regulations. To prevent recurrence, we will add the water pond area into or weekly inspection checklist for Containment tanks and bermed areas Pg.50 of SPCC plan. In addition, we will evaluate a more robust method to prevent any oily sheen discharge into water pond.