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There is no containment system in place during tank truck loading or offloading operations that is capable of holding <br /> the'entire contents of a truck tank or truck compartment.Therefore,a release could occur at the dealership during loading <br /> or offloading due to a tank truck structural failure,equipment failure, or human error. However, delivery/pickup trucks <br /> are equipped with the means to allow the driver to immediately stop transfer operations in the event of a spill or a leak. <br /> Given the varied locations from which vehicles conduct loading or unloading operations, the relative infrequency of <br /> these operations,and the ongoing vehicle traffic throughout the facility,a containment system dedicated to this operation <br /> is considered impractical.The loading/unloading procedures detailed above,especially the presence of a second person, <br /> are considered adequate precautions to prevent or contain a reasonably anticipated spill event during loading or <br /> offloading. <br /> 6. Spill Response Kit: The dealership maintains a portable spill response kit that contains sufficient absorbent materials <br /> to clean-up or control a typical spill.This response kit is readily available for use in the event of a spill or other release. <br /> The spill response kit contents are inspected monthly to ensure sufficient material is available and written records are <br /> maintained for at least three years by the Responsible Person. <br /> 7. Inspections and Records <br /> All aboveground pipelines, bulk storage tanks, and containers are in locations that are frequently observed during <br /> working hours. Any leak or other tank/container failure would be quickly detected. A more formal visual inspection is <br /> conducted at least monthly by the Responsible Person or his designee. Each such inspection includes a visual check for <br /> leakage and deterioration of all components of the tanks and containers, liquid level sensing devices to ensure proper <br /> operation, containment structures including the tank berm, valves,the spill response kit, and aboveground piping. Any <br /> overfill prevention devices are also tested to ensure their proper operation. In addition,the oil-water separator is checked <br /> for possible excessive accumulation of oil and/or bottom sludge. The date and findings of each inspection are recorded <br /> on the Inspection Log form, a copy of which is included as Attachment (132). These inspection logs shall be retained <br /> with this SPCC Plan for at least three years by the Responsible Person. <br /> All equipment and service deficiencies shall be promptly addressed as specified by the Responsible Person. Any <br /> accumulation of oil due to a leak,spill,or other release shall be addressed as specified in Attachment(C). <br /> Additionally,each aboveground tank is inspected by a qualified independent tank inspection and testing service at least <br /> once every five years, and whenever a repair is made. Supplementary nondestructive testing may be undertaken if <br /> recommended by the inspection service. The Responsible Person shall ensure that the initial independent inspection of <br /> each aboveground tank has been completed within five years of the tank's original installation at the facility. If such <br /> inspection has not been completed, it shall be done within one year of the adoption of this SPCC Plan. <br /> 8. Employee Training: The Responsible Person shall make sure that all oil handling personnel at the dealership receive <br /> annual training on the following: <br /> a. The location and contents of this Spill Prevention, Control, and Countermeasures Plan. <br /> b. Operation and maintenance of oil storage equipment to prevent oil discharges. <br /> c. Spill response training which focuses on quick reaction response to contain a release. Training also notes that the <br /> dealership relies primarily upon community emergency response agencies to carry out cleanup activities. Employee <br /> training includes emergency response activities, use of personal protective equipment, and information about the <br /> potential hazards of the petroleum products stored. <br /> d. The requirements for monthly and annual inspections of the tank systems. <br /> Tracy Chevrolet SPCC Plan <br /> 08-14 <br />