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ARCO Facility <br />2. <br />3. <br />MONITORING & RESPONSE PLAN- III <br />ARCO PRODUCTS COMPANY FACILITY WITH <br />SINGLE WALL TANKS AND SINGLE WALL LINES <br />Address <br />r <br />DETECTION METHOD <br />Tanks - Monthly Inventory Reconciliation and Annual Tank Integrity Testing in accordance <br />with Sections 2646 and 2643(c)(2)(A) and (B), Article 4, Title 23, CCR. <br />Lines - Automatic Pressure Line Leak Detectors and Annual Line Tightness Testing in <br />accordance with Section 2643 (d)(1) and (3), Article 4, Title 23, CCR. <br />MONITORING EQUIPMENT <br />The Automatic line leak detectors will be maintained and inspected according to the <br />manufacturer's instructions by an outside contractor once during each calendar year. <br />MONITORING PROCEDURE - Inventory Reconciliation <br />Inventory reconciliation will be performed in compliance with the details of Section 2646, <br />Article 4, Title 23, CCR (copy attached and hereby incorporated). <br />A. The daily variation in inventory reconciliation shall be the difference between <br />physically measured inventory in storage and the calculated inventory in storage. <br />B. The physically measured inventory shall be determined at approximately the same time <br />each day by taking liquid level measurement (stick reading) and converting it to <br />gallons using a calibration chart. <br />O The calculated inventory shall be determined at approximately the same time of day for <br />each business day by adding the inputs and subtracting the withdrawals from the <br />physically measured inventory determined the day before. <br />D. These variations shall be summed for a period of one month. Monthly variations <br />exceeding a variation of 1.0 percent of the monthly tank delivery plus 130 gallons <br />must be investigated in accordance with instructions attached. <br />See Exhibit A for reconciliation form. <br />