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Documentation of Corrective Actions aNorthwest Pipe San Joaquin County—Environmental Health Department Company Aboveground Petroleum Storage Act Inspection Report(03/31/2020) Pending corrections as per Cesar Ruvalcaba/Lydia Baker SPCC Plan Requirements for Onshore Facilities (excluding production facilities) 726 CFR 112.8(c)(8) Plan failed to adequately describe overfill prevention methods for each container. The SPCC plan does not discuss the overfill protection for the mobile refueler. Engineer or update each container installation in accordance with good engineering practice to avoid discharges. You must provide at least one of the following devices: (i) High liquid level alarms with audible or visual signal at a constantly attended operation or surveillance station. In smaller facilities an audible air vent may suffice. (ii) High liquid level pump cutoff devices set to stop flow at a predetermined container content level. (iii) Direct audible or code signal communication between the container gauge and the pumping station. (iv) A fast response system for determining the liquid level of each bulk storage container such as digital computers,telepulse,or direct vision gauges. If you use this alternative, a person must be present to monitor gauges and the overall filling of bulk storage containers. (v) You must regularly test liquid level sensing devices to ensure proper operation. Corrective Action: Amend the SPCC plan to include discussion of allowed overfill protection for all regulated tanks or provide equivalence as allowed by CFR 112.7(a)(2). Note: The only tank for which overfill prevention is discussed is the 10,000 gallon tank. The other tanks appear to have an environmental equivalence claim, except for the mobile refueler. Overfill protection in accordance with 40 CFR 112.8(c)(8)(iii) and 112.8(c)(8)(iv)to avoid discharges are in use at this facility. The SPCC plan was amended to include discussion of overfill protection procedures followed during transfer operations involving all APSA regulated tanks. The mobile refueler will be considered as Category 1 for integrity testing (<5,000 gallons, with spill control (i.e.-spill kit) and with Continuous Release Detection Method (it is located off the ground, all sides/bottom visually available,employees work nearly and would quickly react to and use the nearby Spill Kit,for any observed leaks). The containment method for the mobile refueler has been identified on SPCC plan. Overall InspectionComments: Northwest Pipe Company is now the owner and operator of the facility. At the time the inspection was conducted and the report was generated the paperwork for name change had not been submitted [to]the Environmental Health Department. Paperwork for name change was submitted to the Environmental Health Department by Northwest Pipe Company on January 15, 2019. Complete and submit a copy of the Return to Compliance Certification form to the EHD with a statement documenting the corrective actions that have been or will be taken for each violation, and any supporting paperwork, by March 30,2020. A copy of the signed Return to Compliance Certification form was submitted to the EHD on March 31 2020. Page 4of4