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25 October 2019 AdvancedGeo AGE Project No. 99-0637 F n v i ro n m e n t a l Page 7 of 19 4.0. DISCHARGE PREVENTION - GENERAL SPCC PROVISIONS The following measures are implemented to prevent oil discharges during the handling, use or transfer of oil products at the Facility. Oil-handling employees have received training in the proper implementation of these measures. 4.1. COMPLIANCE WITH APPLICABLE REQUIREMENTS - 40 CFR 112.7(a)(2) The ASTs meet the specifications provided in EPA's memorandum concerning its policy on double-walled tanks; general containment is provided by double-wall construction and SPCC absorbents. As later described in Section 4.4 of this Plan, the operational and emergency oil storage capacity of the containment areas are sufficient to handle the quantity of oil expected to be discharged in AST areas from tank overfills or transfer operations. AST non-destructive integrity evaluation and regular inspections are performed based on the Facility inspection schedule as described in Table 9. ASTs are inspected regularly and following a regular schedule in accordance with the Steel Tank Institute (STI) SP-001 tank inspection standard as described in this Plan. Any leakage from ASTs would be detected through monitoring of the containment spaces performed on a monthly basis. Storage drums are elevated on spill pallets and have all sides visible, and any leak would be readily detected by Facility personnel before discharging to navigable waters or adjoining shorelines. Corrosion poses minimal risk of failure since drums are single-use and remain on site for a relatively short period of time (less than one year). The drum storage area is inspected monthly. This is in accordance with accepted industry practice for drum storage and provides an effective means of verifying container integrity, as noted by EPA in the preamble to the SPCC rule at 67 FR 47120. 4.2. SPILL REPORTING - 40 CFR 112.7(a)(4) The discharge notification form included in Appendix D is completed upon immediate detection of a discharge and prior to reporting a spill to the proper notification contacts after evaluation by Facility Management and as applicable to limits described in Section 2.0. 4.3. POTENTIAL DISCHARGE VOLUMES AND DIRECTION OF FLOW - 40 CFR 112.7(b) Table 5 presents expected volume, discharge rate, general direction of flow in the event of equipment failure and means of secondary containment for different parts of the Facility where oil and/or petroleum fuel is stored, used or handled.