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QNorthwestPipe Documentation of Corrective Actions Company San Joaquin County-Enviromnantal Health Department Aboveground Petroleum Storage Act Inspection Report(09/06/2019) General Requirements for SPCC Plans 602 CFR 112.7(aN2) Plan failed to discuss equivalent environnrerrtal protection,if applicable. The Spill Prevention, Control, and Countermeasure (SPCC) failed to discuss alternative environmental protection requirements. The SPCC Plan states that the 300 and 500 gallon tanks along with some 55 gallon drums do not have overfill protection as required by CFR 112.8(c)(8). The SPCC plan does not give the reasons for nonconformance and a detailed description of the alternate method is not discussed. Table 6.1 of the SPCC plan states that the 300 and 500 gallon tanks do not require inspections, given the use of environmental equivalent measures described in section 5.4 of the SPCC plan. Section 5.4 of the SPCC plan does not discuss the reasons for nonconformance and fails to describe a detailed alternative method. If the SPCC Plan does not conform to the applicable requirements, the reasons for nonconformance must [be] stated and the alternate methods to achieve equivalent environmental protection must be described in detail in the Plan Corrective Action. Im mediately amend the SPCC Plan to include a discussion of eg uivalent environmental p rotection. NWP will retract the Environmental Equivalence claim for meeting Overfill Protection System (OPS) requirements, because we currently meet 112.8(c)(8)(iii) by using a measuring stick &following procedures that prevent overfill. . The applicable procedure will be included in the upcoming SPCC Plan revision. 604 Plan failed to include oil type and storage capacity for each container. VIOLATIONABATED 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 CFR112.8(c)(2) Failed to provide and maintain adequate secondary containment VIOLATION ABATED 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 othertanks 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 newcontainment 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 Page 2 of 4