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Facility Response to CUPA Visit 2011 <br /> Above Ground Petroleum Storage Act (APSA) Program Inspection <br /> Report and Hazardous Waste Program Inspection Report of <br /> September 7, 2011 <br /> 1. APSA#513- Summary and Response- <br /> a. The Plan lacks description of equipment failure for above ground <br /> containers/equipment. <br /> i. Response-The Plan describes potential container failures on page <br /> G-7. <br /> b. Discharge and drainage controls and potential equipment failure are not <br /> addressed for any of the unlisted containers. <br /> i. Response- These controls are listed in the Plan on page G-2. <br /> c. The SPCC Plan must include the correct type of oil and storage capacity <br /> of each fixed storage container or an estimate of the potential number of <br /> portable containers, types of oil, and anticipated storage capacities. <br /> i. Response-These elements of the Plan are found on page E-1. <br /> d. The Plan must include discharge or drainage controls, such as secondary <br /> containment around all containers and other structures, equipment, and <br /> procedures for the control of a discharge, and a prediction of the direction, <br /> rate of flow, and total quantity of oil which would be discharged as a <br /> result of each type of major equipment failure. <br /> i. Response-These elements of the Plan are on pages G-2 through G- <br /> 5. Page G-7 shows the Maximum Quantity and Rate in the event of <br /> a failure. All Plan elements exclude pumping rates or large storage <br /> facilities as we are not so equipped. <br /> e. Immediately update the discharge information in the SPCC Plan to <br /> accurately represent the petroleum storage at the facility. <br /> i. Response- The plan is compliant on these points precluding the <br /> need for an update. <br /> L STATUS: Complete <br /> g. Attachments: <br /> i. Page G-2 to G-7 of the SPCC Plan <br /> ii. Page E-1 of the SPCC. <br />