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that assessment in regards to this facility was the recommendation that five tanks 11 K diesel, 4K motor oil, 4K <br />hydraulic oil, IK gasoline, and a 2K diesel be permanently closed because they would not meet current fire code <br />requirements. As a result these tanks were taken out of service. <br />In response to the stated violation the tank integrity testing schedule within the plan was modified in Section 8.3.3 <br />and in accordance with that schedule all the tanks with the exception of the 30,000 gallon asphalt tanks are only <br />required visual monthly and annual inspections as per the STI SP001 guidelines. Copies of monthly and annual <br />inspection records are presented in Attachment "Facility Inspection Checklist', <br />710. Plan failed to adequately discuss procedures to test or inspect each container for integrity. <br />As stated above the SPCC plan was modified in Section 8.3.3 to include a complete tank integrity testing schedule in <br />accordance with the Steel Tank Institute SP001 guidelines. <br />715. Failed to regularly lest liquid level sensing devices to ensure proper operation. <br />The monthly inspection sheet procedure and report is being modified to include inspection of the liquid level sensing <br />devices to ensure proper operation. CRI is working with their consultant to complete the update to the app used for <br />inspection sheets. <br />In addition to the corrections of the above mentioned violations that following changes were made within the plan <br />and to the CERS database: <br />I.) Section 2.3 of the plan, facility contacts, was changed (Rob Thomas new plant Foreman). <br />2.) CERS Owner Operator Form was updated to include the new facility contact. <br />2.) Section 8.3.3 of the plan, Inspections/Record Keeping, was updated to include the tank integrity testing schedule <br />for all stationary tanks in service. <br />3.) Section 8.3.3 was also updated with procedures to inspect each container for integrity. <br />4.) Sections 8.2.2, 8.2.4, and 8.3.1 were updated to include the addition of the new 5K gal extender oil tank. <br />5.) Sections 8.2.2, 8.2.4. and 8.3.1 wcrc updated to reflect the removal of the I lk gal diesel tank, the 4K gal motor <br />oil tank, the 4K gal hydraulic oil tank, the IK gal gasoline tank, and the 2K gal diesel tank from the fuel/lube storage <br />area. <br />6.) Site map Figure 5 was updated to include the new 5K gal extender oil tank, and the removal of (lie five tanks <br />mentioned above (I IK, 4K, 4K, 1K, & 2K). <br />7.) The chemical inventory table in Section 4 has been updated to reflect the current chemical inventory at the <br />facility. <br />8.) The CERS chemical inventory was corrected to include the new 5K gal extender oil tank and the removal of the <br />five tanks mentioned above (I I k, 4K, 4K, I K. & 210. <br />Sincerely, <br />Randy Tilford <br />George Reed, Ine. <br />Page 2 of 2 <br />