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Ameron April 26, 2010 Page 4 specified in the SPCC plan, and that all inspections and tests will be documented and maintained for a minimum of three years. #32. Failed to: (1) train personnel on discharge prevention; (2) designate a person to be accountable for discharge prevention; or (3) schedule prevention discharge prevention briefings at least annually Ameron has designated Mr. Cliff Dumlao, an Ameron employee, as the person responsible for discharge prevention and for ensuring that required inspections are conducted and documented. Training of oil-handling personnel occurred on April 14-15, 2010 by HGA and on April 22, 2010 by One Stop Environmental. Collectively, the training covered the operation and maintenance of equipment to prevent discharges; discharge procedure protocols; applicable pollution control laws, rules and regulations; general facility operations; contents of an SPCC Plan; hazard communication and right-to-know, hazardous waste handling and storage, hazardous waste labeling, and emergency response procedures. #33. Failed to describe how the oil handling, processing and storage areas are secured and controlled; how master flow and drain valves are secured; how unauthorized access to starter controls on oil pumps are prevented; how out-of-service and loading/unloading connections are secured; the appropriateness of security lighting; or provide equivalence as allowed by CFR 112.7(a)(2) The revised SPCC plan will include a more detailed description of security measures for oil-handling, processing, storage, valves, controls, and connections for the facility. In addition to the general security measures provided by Ameron personnel during operating hours and a private security company after hours, the revised SPCC plan will document all physical measures taken to secure valves and controls and to lock dispensing equipment when not in use to prevent unauthorized access. #48. Failed to: test each aboveground container for integrity on a regular schedule or when repairs were made; inspect containers and container supports; or keep records of inspections and tests,or provide equivalence as allowed by CFR 112.7(a)(2) As mentioned in the response to item #29, inspection procedures and documentation is being developed by the PE and will be included in the revised SPCC plan. The Designated Environmental Coordinator and his Alternate are aware of the importance of record keeping and document maintenance. This has also been stressed to employees during training. Records of inspection will be maintained onsite for a minimum of three years, and will provided to inspectors upon request. #50. Failed to install and regularly test approved liquid level sensing devices, or provide equivalence as allowed by CFR 112.7(a)(2)