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Ameron April 26, 2010 Page 3 #24. SPCC Plan failed to include required contact list and phone numbers of the facility's response coordinator,cleanup contractors,and agencies to notify in case of discharge The revised SPCC plan will contain a revised and updated contact list with phone numbers for appropriate individuals to notify in the event of a discharge. That list will contain, but is not limited to, the 24-hour contact numbers for the Designated and Alternate Emergency Coordinators, cleanup contractors, and all appropriate federal, state, and local agencies including the San Joaquin County Office of Emergency Services and Environmental Health Department. #27. SPCC Plan failed to include a description of potential equipment failure (direction,flow rate,quantity),or provide equivalence as allowed by CFR 112.7(a)(2) The revised SPCC plan will include a description of potential equipment failures for each potential source of discharge. The description will include a prediction of the direction, flow rate, and total quantity for each major type of failure for all petroleum- containing products and waste. #28. Failed to provide secondary containment and/or diversionary structures that are capable of containing discharge from primary containment until it is cleaned up Since the DEH inspection, drums containing solvent mineral spirits and form oil containers have been placed in appropriately sized secondary containment capable of holding 100% of the volume of the largest container plus adequate freeboard for precipitation. In general, secondary containment can hold a minimum of 110% of the volume of the largest container within the containment. #29. Failed to provide explanation, conduct periodic integrity testing of containers and/or periodic integrity and leak testing for valves and piping if containment or discharge prevention structures were determined to be impracticable on an SPCC Plan or sections of one that is PE certified Appropriate inspection and integrity testing procedures for containers, valves, and piping are being developed by HGA's PE. These procedures and appropriate documentation (procedures and inspection forms) will be included in the new SPCC plan being developed for the facility. #31. Failed to conduct inspections and tests in accordance with written procedures and/or maintain signed records of inspections and tests as required by the facility's SPCC Plan on site for 3 years The SPCC plan contains an inspection schedule. The schedule will be updated in the revised SPCC plan. To the extent possible, inspection procedures and schedules will be streamlined to facilitate the inspection and documentation process. Ameron will make sure that inspections occur in accordance with the inspection schedule and frequency