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4. APSA#519- Summary and Response a. The SPCC Plan did not include discussion of adequate security lighting. The plan must include descriptions of how you secure and control access to the oil handling, processing, and storage areas, secure master flow and drain valves, prevent unauthorized access to starter controls on oil pumps, secure out-of-service and loading/unloading connections of oil pipelines, and address the appropriateness of security lighting to both prevent acts of vandalism and assist in the discovery of oil discharges. i. Response- 1. Page G-1 and K-1 of the Plan indicates all bulk loading operations are not applicable. The facility is not equipped with Bulk Loading equipment. a. There are no master flow and drain valves to secure. b. There are no starter controls for oil pumps, loading or unloading connections to pipelines, nor pipelines to guard against vandalism or malfunction. 2. Page G-2 of the Plan discusses the drum storage sites used at the facility. a. The virgin oil storage (Site ID 012) is located inside the building. (no need for special lighting) b. The Used Oil (Site ID 016) is located outside, is secondarily contained, and is monitored on a regular basis. c. The Plan is amended to a description of the inside and outside lighting on Appendix K, page K-1. 3. Page G-7 Shows the facility analysis for the above sources (012 and 016) a. A breach of a drum would be wholly contained by the secondary containment. b. The routine and non-routine inspections would initiate a response to a fully contained drum breach. b. STATUS: Complete c. Attachments: i. Page G-1 of the SPCC, Bulk Storage and Loading/Unloading Facilities. ii. Page G-2 of the SPCC, Container Storage and Other Handling Facilities. iii. Page G-7 of the SPCC, Facility Analysis Inventory Source ID 012, 016. iv. Page K-1 of the Plan, Security.