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aNorthwest Pipe Documentation of Corrective Actions <br /> Company San Joaquin County—Environmental Health Department <br /> Aboveground Petroleum Storage Act Inspection Report(09/06/2019) <br /> , <br /> 301 CFR 112.5(a) Failed to amend Plan as necessary <br /> The SPCC plan does not address all APSA qualified tanks.The SPCC plan failed to address an emergency <br /> generatorwith a belly tank containing diesel and capacity which appears to be over 55 gallons. Operational <br /> equipment in the Bell Expander and Hydrotest areas were not addressed in the SPCC plan. The <br /> operational equipment consists of two hydraulic fluid reservoirs of 300 gallons and another that may be <br /> between 400 and 500 gallons. The area referred to as the Hazardous Waste consolidation area was <br /> observed with several 55 gallon drums,some ofwhich were described as containing oily water and is not <br /> addressed in the plan. The Spill Prevention,Control,and Countermeasure(SPCC)Plan must be amended <br /> when there is a change in the facility design,construction,operation,or maintenance that materially affects <br /> its potential for a discharge,within 6 months of the change,and implemented as soon as possible,nat later <br /> than 6 months fallowing preparation of the amendment. <br /> CorrecBve Action: <br /> Immediately make all necessary amendments to the SPCC Plan to accurately represent the procedures and <br /> policies currently in place at the facility. Include all aboveground petroleum storage tanks with a capacity of <br /> 55 gallons or more. <br /> The facility's SPCC Plan will be amended to describe how oil-filled operational equipment meet 112.7(kx2) <br /> alternative requirements to general secondary containment as described below. <br /> 1. Establish &Document facility procedures for inspections/monitoring to detect failure:we meet <br /> this with periodic visual inspections. <br /> 2. Need to have an Oil Spill Contingency Plan (SPCC CP) or equivalent. NWP's Haz Waste <br /> Contingency Plan(HW CP)nearly meets the requirements for the SPCC CP.Additional info to <br /> the HW CP will be included in either in the body of the HW CP itself,or in an addendum to it.A <br /> cross reference between the 40 CFR 109.5 SPCC CP requirements, and how" meet that in <br /> the HW CP,will be included as part of the SPCC. <br /> 3. A written commitment of manpower, equipment, &materials to expeditiously control &remove <br /> an quantity of oil discharged. Tracy's current SPCC Plan does not include this particular <br /> language,but will revise SPCC plan accordingly <br /> The SPCC plan facility bulk storage container and OFOE inventorywill be updated to include the following <br /> - 55-Gal. Drum(Used oil accumulation) <br /> - 80-Gal. Emergency Generator belly(Diesel) <br /> - 2000-Gal Mobile refueler(gas and diesel) <br /> - 120-Gal.Helical weld oil tank(Lube oil recirculating tank) <br /> - 11 4-Gal. Byard weld oil tank(Hydraulic oil) <br /> - 200-Gal. Bell expander west side(Hydraulic oil) <br /> - 350-Gal. Bell expander east side(Hydraulic oil) <br /> - 200-Gal.Hydrotest oil tank(Hydraulic oil) <br /> - 110-Gal. Flash welder hydraulic tank (Hydraulic oil) <br /> - 11¢Gal.Skimmer hydraulic tank(Hydraulic oil) <br /> - 96-Gal.Small expander(Hydraulic oil) <br /> - 80-Gal.Flare machine(Hydraulic oil) <br /> - 134-Gal.Big expander(Hydraulic oil) <br /> - 170-Gal.D-load machine(Hydraulic oil) <br /> - 256-Gal.Tip-dorm machine(Hydraulic oil) <br /> Page 1 of 4 <br />