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SPCC Plan Valley Pacific Petroleum Services Escalon Facility Page 10 2.6 INSPECTION RECORDS [40 CFR 112.7(e)] Records of monthly visual inspections will be maintained at the Facility for a period of 3 years. Visual inspection findings will be entered on a form provided in Appendix 6 or an alternative form. Visual inspection records will be signed and dated by an in-house inspector.Visual inspections will include: • Written documentation and, when appropriate, photo documentation of the external condition of all oil containers that meet or exceed a capacity of 55 gallons. Visual inspections will be used to document any observed oil container deterioration associated with metal and rubber components. The written documentation will also include the action(s) taken to mitigate the deteriorated oil container,i.e.,removal of the oil container from service, repair of the oil container, etc.; and, • When present, the visual inspection will also focus on oil container valves, pipes, and appurtenances,the general condition of such items as flange joints, expansion joints,valve bodies and glands, catch pans, and pipeline supports (Photo 10). The visual inspection will also include checks of the proper locking of oil container valves. 2.7 TRAINING [40 CFR 112.7(f)] At the time of hire, Facility oil product transfer instructions are given to VPPS personnel who will be working around and with oil containers.The oil product transfer instructions are periodically reviewed with VPPS personnel working around and handling oil containers. On an annual basis, training specific to the handling of the Facility oil products includes procedures in the proper operation and maintenance of equipment to prevent discharges, a discussion to facilitate the adequate understanding of the Facility's SPCC Plan,procedures for accidental spill and release response,product health hazards, and the Facility's security policy. A copy of the training documentation form is included in Appendix 7. Management is responsible for discharge prevention and ensuring that training occurs and is documented. 2.8 SECURITY [40 CFR 112.7(g)] Security for the Facility includes the following: • The oil storage and bulk loading/unloading areas are fenced and locked. • The Facility has sufficient security lighting where oil is stored. • The electrical supply for the bulk storage transfer pumps is normally deactivated and the panel locked preventing unauthorized access to the starter controls. • AST valves must be closed and locked when not in use. • AST transfer hoses are completely disconnected when not in use. 2.9 TANK TRUCK LOADING/UNLOADING [40 CFR 112.7(h)] The Facility has two bulk product loading/unloading areas.Tanker semi-trucks unload fuel through flexible hose connections to the bulk storage tanks located near the west entrance of the Facility(Photo 11).Transfer activities at this location are subject to the general secondary containment requirements of 40 CFR 112.7(c). The bobtail truck loading area, centrally located, is equipped with a loading rack and therefore subject to the additional requirements of 40 CFR 112.7(h). 4M #6 41 CN4