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Item Requiring Attention Recommendation Evidence of a suspected tank overfill was observed at an Industrial Oil AST in the Chemical Room. Installation of additional overfill prevention equipment is recommended to avoid future overfills. Install an overfill prevention valve at the AST fill ports of each of the Industrial Oil and Polyether Polyol ASTs or install a remote high liquid level audible/visual alarm located near and in view of the tank truck pump operator location. The high-level alarm must be connected to the electric Overfill prevention liquid level probe/transmitter and set to alarm at a high liquid level not to exceed equipment 900/a of the AST capacity. The alarm panel must be equipped with a power indicator and test circuit to readily test the function of the equipment. Install per manufacturer's recommendations by qualified personnel and/or specialty vendors. File product literature with SPCC files and retain documentation for the life of the equipment. Instruct facility oil-handling staff on proper operation and maintenance of the overfill prevention equipment Ref:40 CFR 112.8(c)(8)(ii) SPCC regulations require that the terminal connection at the transfer point be capped and marked (as to origin)when not in service or in standby service for an extended Polyol Railcar Pipe period.The wriumal connection of the Polyether Polyol is capped but is not marked. Install a sign, placard, or tag at the terminal connection stating `Polyether Polyol ASTs Not in Service", or a similar such statement, to identify origin and to prevent unauthorized connections to the fill port. Ref:40 CFR 112.8(d)(2) Floor crack in Chemical Repair the crack in the concrete floor of the Chemical Room Drum Storage Area to Room Drum Storage Area ensure the containment complies with the sufficiently impervious requirements. Ref: 40 CFR 112.8(c)(2) Provide a secondary means of containment for the bulk storage containers 55 gallons and larger (drums identified in Table 1) that currently lack the required secondary containment. The secondary containment must be sized to hold the entire capacity of Drum Storage Secondary the largest single container, including freeboard for precipitation, if applicable, and Containment deducting for the displaced volume from fixed objects within the containment area. The entire containment system, including walls and floor, must be sufficiently impervious and capable of containing oil until cleanup occurs. Examples of sized secondary containment could include,but are not limited to, suitably sized secondary containment pallets,curbs, and dikes. Ref:40 CFR 112.8(c)(2) Provide a suitably sized spill kit with a minimum absorbent capacity of 38 gallons. Spill equipment for tank truck In addition, provide a minimum of two storm drain covers suitably sized for the transfer area storm drains located in the facility parking area. Store the spill equipment/ spill kit in a location readily accessible to the oil transfer area at the south side of the building.Ref:40 CFR 112.7(c) During the site visit to gather information to prepare the Plan Amendment, a facility employee raised a concern regarding the adequacy of the exterior lighting relative to using the LPG tank at night. The LPG tank is not regulated under the SPCC rule; Security lighting however, it is located on the south side of the building adjacent to the tank truck loading/unloading area. Therefore, it is recommended that the facility investigate the appropriateness of exterior security lighting in this area to both prevent vandalism and assist in the discovery of oil discharges. Repair as required. Ref: 40 CFR 112.7(g) Where applicable, install tank labels on the Chemical Room ASTs identifying the Tank labels tank contents and tank ID number. Ref: 40 CFR 112.8(c)(8); NFPA 30, Chapter 21.7.2. Minor oil leaks were observed at the Chemical Room ASTs. Investigate to identify Oil leaks the source of the leaks. Service and repair the equipment as required to eliminate the source of the leaks. Following repairs, clean equipment and floor surfaces of oil and oil stains to aid in the detection of future leaks. Ref:40 CFR 112.8 c 10 SPCCP1oaAmeti*nsWRevision#1—Jape 2019 24 NR$I... Leggett&Plat,J.. NRS Project NaaJur 1106EC4440.00 2015 Abrih HwArthtr Wive, Rciry, Coliforida 95376