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711 Materials, Inc. Q,
<br /> ALTA
<br /> Spill Prevention, Control and Countermeasure Plan ENVIRONMENTAL
<br /> 7.0 TANK INTEGRITY PROGRAM, INSPECTIONS, TRAINING
<br /> 7.1 Monthly Tank Integrity Program
<br /> Ref:40 CFR 112.8(c)(6); Ref:EPA Response to Industry Questions,
<br /> Sep.30,2002: Guidance on integrity testing,Section 112.8(c)(6).
<br /> With the exception of the 12,000-gallon diesel fuel tank, all tanks are shop-built and are
<br /> elevated or on impervious corrosion resistant surfaces (concrete). A tank integrity program
<br /> has been established for the aboveground storage tanks at the Facility. The SPCC
<br /> Designated Person(s) or designee conducts and documents a monthly inspection of all oil
<br /> storage tanks. All shop-built containers with 30,000 gallons or less, that are elevated so that
<br /> all sides are visible, will be visually inspected on a monthly basis, at a minimum (unless more
<br /> frequent inspection is necessary to discover leaks/spills and liquid or debris in secondary
<br /> containment or to satisfy other regulatory requirements such as weekly inspection of portable
<br /> hazardous waste/used oil containers). ASTs will also be visually inspected whenever a
<br /> material repair is made to the tank. The testing program is based on the U.S. EPA letter,
<br /> dated September 30, 2002, to the Petroleum Marketer's Association of America (PMAA). In
<br /> this letter, the U.S. EPA provides guidance stating that for well-designed shop-built
<br /> containers of less than 30,000 gallons, visual inspection plus elevation of a shop-built
<br /> container in a manner that decreases corrosion potential (as compared to a container in
<br /> contact with soil) and makes all sides of the container visible during inspection would be
<br /> considered "equivalent environmental protection" to the methods outlined in 40 CFR
<br /> 112.8(c)(6) as allowed by 40 CFR 112.7(a)(2). A copy of the U.S. EPA letter is included in
<br /> Attachment J.
<br /> Monthly inspections will include:
<br /> • Visual integrity inspection of ASTs and secondary containment, which will focus on
<br /> tank appurtenances such as instrumentation and gauges for signs of malfunction, tank
<br /> supports and foundation, and on the exterior tank surface for signs of deterioration,
<br /> leaks, or accumulation of oil inside secondary containments.
<br /> • Inspection of aboveground valves, pipes, and appurtenances, which will focus on the
<br /> general condition of such items as flange joints, expansion joints, valve bodies and
<br /> glands, catch pans, and pipeline supports, regular inspection of proper locking of
<br /> valves, and regular inspection of the condition of rubber and metal surfaces. If
<br /> corrosion is found, undertake additional examination and corrective action, as
<br /> indicated by the magnitude of the damage.
<br /> • Promptly correct visible discharges which result in a loss of oil from a container,
<br /> including but not limited to seams, gaskets, pipes, pumps, valves, bolts, etc. Promptly
<br /> remove any accumulation of oil in berm protected areas.
<br /> • Inspection of the Bay Saver®for significant oil accumulation.
<br /> The 12,000-gallon diesel fuel tank was manufactured and installed by ConVault®, Inc.
<br /> Qualified facility personnel will visually inspect the 12,000-gallon diesel fuel tank during
<br /> monthly inspections and perform minor maintenance (e.g replacing signs/decals, repairing
<br /> small cracks, etc.) according to ConVault® Owner's Manual procedures, as needed.
<br /> Completed inspection checklists are maintained with the SPCC Plan on-site for a minimum
<br /> of 3 years. Records will be signed and dated by an in-house inspector (Facility personnel).
<br /> The facility personnel performing these inspections are knowledgeable about storage facility
<br /> Alta Environmental 18
<br /> BASR-19-8895
<br /> July 3, 2019
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