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QNorthwestPipe Documentation of Corrective Actions Company San Joaquin County-Environmamal Health Department Aboveground Petroleum Storage Act Inspection Report(07/30/2019) General Requirements r SPCC Plans Corrective Action: r Immediately amend the SPCC Plan to include a discussion of equivalent environmental rotection. The SPCC Plan was amended to include a discussion of the documented monthly inspections of the 300 and 500-gallon tanks as equivalent environmental protection. The SPCC now describes how Northwest Pipe Company personnel will perform monthly inspections, documenting the condition of the exterior of the each container for signs of deterioration, discharges, or accumulation of oil inside secondary containment. 604 Plan failed to include oil type and storage capacity for each container. No remarks found in'Summary of Violations". The SPCC plan now includes the oil type and storage capacity for all aboveground petroleum storage tanks/ containers with a capacity of 55 gallons or more. SPCC plan now includes the oil type and storage capacity for all qualified oil-filled operational equipment with a capacity of 55 gallons or more. 706 CFR 112.8(c)(2) Failed to provide and maintain adequate secondary containment The emergency generator was observed with insufficient secondary containment. There was no evident secondary containment for the belly tank of the generator. All bulk storage tanks must be provided with a secondary means of containment for the entire capacity of the tank and sufficient freeboard to contain precipitation. Corrective Action. Immediately rovide sufficient secondary containment for this and all other tanks at this facility. A proper containment method for the emergency generator fuel (belly) tank has been identified, and is described the discharge or drainage control section;the new containment system is also mentioned in SPCC plan. Northwest Pipe Company hereby commits to custom fabricate containment with a capacity of-100 gallons, enough to contain the entire capacity of the 80 gallon belly tank plus sufficient freeboard to contain precipitation. 711 CFR 112.8(c)(6) Failed to perform scheduled tank tests or inspections by appropriately qualified personnel. The 10,000 gallon tank was not tested on schedule by qualified personnel. The SPCC Plan calls for formal STI SP-001 inspections by a certified SP-001 inspector every 10 years. The tank is older than ten years and a formal inspection has not been conducted. Also,the inspection/testing of the onsite mobile refueler must be addressed in the SPCC plan. Each aboveground container shall be tested and inspected for integrity on a regular schedule and whenever repairs are made. The qualifications of personnel performing tests and inspections,frequency and type of testing and inspections that take into account container size,configuration, and design shall be determined in accordance with industry standards. 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. Comparison records and other records of inspections and tests must be maintained on site. Comective Action. Immediately conduct the necessary testing and submit of a copy of the test results to the EHD and address testing/inspections for all qualified tanks per industry standards or provide equivalence as allowed by CFR 112.7a 2 . Integrity testing was conducted by a certified SP-001 inspector on March 8,2019. A copy of the test results was forwarded to the EHD on May 7-,2019. Testing/inspections for all qualified tanks per industrial standards are addressed in the SPCC Plan. Page 2 of 4