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Ameron April 26, 2010 Page 2 #10. Failed to complete a review and evaluation of SPCC plan at least once every 5 years The formal review and evaluation of the SPCC plan which should have occurred in 2007 did not take place. The revised SPCC plan will be reviewed every five years, and reviews noted and certified within the document. Should the review identify the need for administrative or technical amendments, the SPCC plan will be appropriately amended within six months of the review and the amended plan appropriately certified. Implementation of the amendments will occur no later than six months after the SPCC plan is amended. All administrative and technical amendments will be recorded and certified on an amendment log by the appropriate certifying authority (Designated Emergency Coordinator or PE, respectively). #19. SPCC Plan failed to include description of product type and storage capacity for each container The material inventory included in the SPCC plan reviewed by DEH inspectors has been updated and modified where appropriate. Bulk storage capacity is shown rather than the volume of product typically present on site. Since the inspection, and to the extent possible, the Ameron-Tracy facility is taking proactive steps to reduce the overall storage capacity of petroleum products at the facility. #20. SPCC Plan failed to include procedures for routine handling of products and discharge prevention measures The revised SPCC plan will include written standard operating procedures (SOPS) for the handling, storage, loading, unloading, and transfer for all petroleum-based products by Ameron personnel. In addition, Ameron is contacting all appropriate suppliers to request the SOPS used by their personnel during the loading, unloading, and transfer of petroleum-based products delivered to the facility. At a minimum, vendor SON must comply with the Ameron SON for routine handling and discharge prevention measures at the Tracy facility. The procedures will include the mobile refueler, tanks, and mobile or portable containers. #21. SPCC Plan failed to show discharge or drainage controls (secondary containment), equipment,and procedures for the control of a discharge The revised SPCC plan will include an appropriate discussion of discharge and drainage controls such as secondary containment around containers and other applicable structures, and the equipment available onsite for the control of any discharges. Sized containment will be used for all fixed and portable bulk containers and appropriate general containment will be used for all other locations where petroleum-based products are used/stored (mobile refueler, loading, and unloading areas). Procedures will be written within the SPCC plan and also presented graphically in easy-to-read flow chart format.