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QNorthwestPipe Documentation of Corrective Actions <br /> Company San Joaquin County-Environmantal Health Department <br /> Aboveground Petroleum Storage Act Inspection Report(0 713 012 01 9) <br /> IMEMME1 M- 1 ErRiMIMM-MM, Mae <br /> 717 CFR 112.8(cN10) Failed to promptly correct visible discharges and/or remove accumulations of oil in <br /> diked areas. <br /> A sheen was observed on the water in the retention pond. Sheen was observed between the boom and the <br /> pipe which water flaws into the pond. <br /> Corrective Action. <br /> Promptly correct visible discharges which result in a loss of oil from the container, including but not limited to <br /> seams,gaskets, piping, pumps, valves, rivets,and bolts. You must promptly remove any accumulations of <br /> oil in diked areas. Immediately remove oily substance from pond, and manage according to the Califamia <br /> Code of Regulations Title 22 hazardouswaste regulations. <br /> The presence of this slight sheen is considered an anomaly. This pond does not meet USEPA's definition of <br /> a navigable water of the US (WOTUS); still, to prevent any impact to the environment, Northwest Pipe <br /> Comloany plans to monitor for sheen daily and remove any significant discoloration if discovered. <br /> 726 CFR 112.8(c)(8) Plan failed to adequately describe overfill prevention methods for each container. <br /> The SPCC plan does not discuss the overfill protection for the mobile retueler. Engineer or update each <br /> container installation in accordance with good engineering practice to avoid discharges. You must provide at <br /> least one of the fallowing devices: <br /> (i) High liquid level alarms with audible or visual signal at a constantly attended operation or <br /> surveillance station. In smaller facilities an audible air vent may suffice. <br /> (ii) High liquid level pump cutoff devices set to stop flow at a predetermined container content level. <br /> (iii) Direct audible or code signal communication between the container gauge and the pumping station. <br /> (iv) Afast response system for determining the liquid level of each bulk storage containersuch as digital <br /> computers,telepulse,or direct vision gauges. If you use this alternative,a person must be present <br /> to monitor gauges and the overall filling of bulk storage containers. <br /> (v) You must regularly test liquid level sensing devices to ensure proper operation. <br /> Corrective Action. <br /> Amend the SPCC plan to include discussion of allowed overfill protection for all regulated tanks or provide <br /> equivalence as allowed by CFR 112.7(ax2). <br /> Note: The only tank for which overfill prevention is discussed is the 10,000 gallon tank. The other tanks <br /> appear to have an environmental equivalence claim except for the mobile refueler. <br /> The mobile refueler is not defined as a bulk storage container.When not in use(parked)it will be located or <br /> positioned to prevent discharges as described in 112.7(b) <br /> The containment method for the mobile refueler has been identified on SPCC plan. Northwest Pipe <br /> Company hereby commits to park the mobile refueler under the awning-250'west of SW Corner of employee <br /> parking lot. <br /> Overfill protection in accordance with 40 CFR 112.8(cx8)(iv)to avoid discharges are in use at this facility. <br /> The SPCC plan was amended to include discussion of overfill protection procedures followed during transfer <br /> operations involving all APSA regulated tanks. <br /> Page 3 of 4 <br />