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SPCC Plan Valley Pacific Petroleum Services Escalon Facility Page 8 detection. Portable tanks greater than 55 gallons containing product should be stored within properly sized secondary containment(100 percent capacity of the largest container). • Underground pipes servicing the commercial fuel dispensers are installed in secondarily contained piping.Failures of the primary pipe would flow through secondary pipe to collection sumps (Photo 6 and 7). Level sensors installed at both sumps report to a control panel located in the warehouse. Specific (sized) secondary containment requirements are based on the type of containers, activities, or equipment in place at the Facility. The SPCC Rule specifies a required minimum size for this type of secondary containment. Facility specific secondary containment includes: • The 55-gallon drums are located within the interior of the warehouse. The drums should be stored on properly sized containment structures (i.e. spill pallets). Spills are most likely to occur during product transfer into the drums. Spill containment should be utilized in the drum filling area(Photo 8) of the warehouse dock(i.e. a properly sized spill pallet with adequate containment volume). • ASTs#1 through#6 positioned within an outdoor masonry block secondary containment structure with an estimated capacity of 28,900 gallons. A full release of any one of the six tanks would be fully contained within the structure with sufficient freeboard for precipitation. • The bobtail tank truck loading area(Photo 9)is equipped with a loading rack.As such,the loading rack is required to have 100-percent containment capacity of the largest tank compartment on the truck.VPPS reported a maximum single tank truck compartment volume of 1,800 gallons. Surface flows in the loading rack area are directed to a concrete subsurface sump by concrete rollover berms and curbing. Accumulations of product too large to be contained by the berms are transferred to the tank farm secondary containment via a sump pump designed for use with petroleum.The berms and overflow to the tank farm secondary containment provide the required 1,800 gallons of capacity. 2.5 ABOVEGROUND TANKS INTEGRITY INSPECTIONS [40 CFR 112.7(d)] All fixed Facility oil container ASTs are shop-built tanks and tanks or tank supports are sited on or above a concrete slab. Table 3 on the following page provides a reference of the inspection type required for Facility containers. A Steel Tank Institute (STI) or an American Petroleum Institute (API) certified tank shell inspector is required to regularly inspect the Facility ASTs greater than 5,000 gallons. Facility tanks AST#1 through AST#6 are in this category. Integrity inspection of the tanks was performed in July 2013. The Facility should evaluate and implement inspector recommendations as necessary. Visual inspections performed by trained Facility personnel are functionally equivalent to the certified inspector AST shell inspections for all ASTs that do not exceed 5,000 gallons. This applies to the Facility portable tanks and 55-gallon drums. #6 41 CON 4