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Item#618: Failed to keep records of procedures, inspections or integrity tests for three years. • In preparation for the inspection, Courtney DePorto e-mailed copies of inspection and training records to Cesar Ruvalcaba on 04/01/2019. Current year inspections are maintained on-site in the Environmental compliance binder in the AC Plant control room. Additional years of records are stored electronically.The SPCC Plan language has been modified to reflect the accurate storage location of these records. Please see e- mail correspondence with copies of records attached to this electronic submittal. Item#706: Failed to provide and maintain adequate secondary containment. • The secondary containment structure has been altered so that AST-1 and AST-2 (manifolded diesel tanks) containment cells are now connected via five 1" holes at the bottom of the wall that separated the two containment cells.This has increased the secondary containment capacity which is sufficient to hold the total capacity of both tanks (40,000-gallons).Additionally, secondary containment calculations have been modified in Appendix G of the SPCC Plan. (See Photo#11-12) • The (6) six conduit pipes in the bottom of the secondary containment cells of the manifolded diesel tanks(AST-1 and AST-2) and AST-9 are capped and sealed.The secondary containment structure has not been breached or compromised. Additionally, a description of the conduit pipes has been added to the SPCC plan. Item#712: Failed to test or inspect each container for integrity based on industry standards. • A technical amendment has been compiled and a site inspection has been performed by our consultant. Once the PE has stamped the revised SPCC Plan,we will send a copy to the EHD. As part of the amendment,the PE is certifying an environmental equivalent alternative in the SPCC Plan to allow for a reduced inspection schedule as long as the tanks remain empty and the site remains unmanned. Item#714: Failed to provide each container with a high level monitoring device. • AST-6 level gauge has been repaired (See Photo#13).As described in the SPCC Plan,the remaining tanks do not have liquid level gauges but are visually inspected prior to and during oil transfer. Item#717: Failed to promptly correct visible discharges and/or remove accumulations of oil in diked areas. • The 10,000 gallon cutback oil tank(AST-14) is not subject to APSA because cutback oil is not a liquid at 60 degrees Fahrenheit (see attached e-mail from Peter Reich, EPA). Additionally,there are no active leaks on AST-14.The hardened/cured cutback oil will remain on the floor of the secondary containment structure because it is a solid and does not impact the secondary containment capacity. 2