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QNorthwestPipe Documentation of Corrective Actions Company San Joaquin Courry—Environments]Health Department Aboveground Petroleum Storage Act Inspection Report(0 910 612 01 9) SPCC Plan Requirements for Onshore Facilities (excluding production facilities) 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. Corrective Action. Immediately conduct the necessary testing and submit of a copy of the test results to the EHD and address testing/inspections far all qualified tanks per industry standards or provide equivalence as allowed by CFR 112.7(a)(2). NWP will revise on SPCC plan the Integrity Testing frequency stated by Certified Inspector far the 10,000 gal. diesel tank;the mobile refueler will be part of Integrity Testing,visual inspections,etc. NWP will revise the SPCC Plan to reflect annual Inspections,as described under STI SP001.This means we will have 12 months of visual inspections+a 13th annual visual inspection, each year. 717 CFR 112.8(cH10) Failed to promptly correct visible discharges andror remove accumulations of of diked areas.VIOLATION ABATED A sheen was observed on the water in the retention pond. Sheen was observed between the boom and the pipe which water flaws into the pond. Corrective Action. Promptly correct visible discharges which result in a loss of oil from the container, including but not limited to seams,gaskets, piping, pumps, valves, rivets,and bolts. You must promptly remove any accumulations of oil in diked areas. Immediately remove oily substance from pond, and manage according to the Califomia Code of Regulations Title 22 hazardouswaste regulations. The presence of this slight sheen is considered an anomaly. This pond does not meet USEPA's definition of a navigable water of the US (WOTUS); still, to prevent any impact to the environment, Northwest Pipe Coryparty plans to monitor far sheen daily and remove any significant discoloration if discovered. 726 CFR 112.8(c)(8) Plan failed to adequately describe overfill preverition methods for each container. The SPCC plan does not discuss the overfill protection far the mobile refueler. Engineer or update each container installation in accordance with good engineering practice to avoid discharges. You must provide at least one of the fallowing devices: (i) High liquid level alarms with audible or visual signal at a constantly attended operation or surveillance station. In smaller facilities an audible air vent may suffice. (ii) High liquid level pump cutoff devices set to stop flaw at a predetermined container content level. (iii) Direct audible or code signal communication between the container gauge and the pumping station. (iv) Afast response system far determining the liquid level of each bulk storage containersuch as digital computers,telepulse,or direct vision gauges. If you use this alternative,a person must be present to monitor gauges and the overall filling of bulk storage containers. (v) You must regularly test liquid level sensing devices to ensure proper operation. Corrective Action. Amend the SPCC plan to include discussion of allowed overfill protection for all regulated tanks or provide equivalence as allowed by CFR 112.7(ax2). Nate: The only tank for which overfill prevention is discussed is the 10,000 gallon tank. The other tanks appear to have an environmental equivalence claim,except for the mobile refueler. Page 3 of 4