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Page 2 <br /> Item#and Finding Corrective Action Taken <br /> 706(Part 1)-CFR 112.8(cx2)The portable generators mentioned in Corrected—The SPCC Plan no longer classifies these <br /> the SPCC plan are classified as operational equipment and only tanks as oil-filled operational equipment.The tanks are <br /> general secondary containment is addressed.The diesel belly tanks now classified as portable containers.The containers <br /> for the portable generators meet the definition of bulk storage are now subject to monthly and annual inspections and <br /> containers and require sized secondary containment,and sufficient full secondary containment requirements. <br /> freeboard to contain precipitation,to be addressed in the SPCC plan. <br /> The following sections of the SPCC Plan were updated <br /> or added to accurately reflect the integrity inspection <br /> requirements for these tanks <br /> Append A—Oil Inventory and Planned Response <br /> Append F—Monthly Facility Inspection Checklist <br /> Append F-1—Annual AST and Portable Container <br /> Inspection Checklist(NEW) <br /> Append F-2—Incoming Portable Container Inspection <br /> Checklist(NEW) <br /> Append J—Bulk Storage Container Integrity Testing <br /> and Inspection <br /> Stockton Steel completed an assessment of the diesel <br /> belly tanks and confirmed that these tanks are double- <br /> walled tanks(see separate report).The tanks meet the <br /> STI definition of a Category 1 container.The tanks <br /> have spill control(double walled-tank with overfill <br /> prevention)and the annular space on all tanks can be <br /> inspected. STI SP001 compliant monthly and annual <br /> portable container inspections are now performed. <br /> These tanks provide the secondary containment <br /> required by the SPCC rule. <br /> 706(Part 2)-The two 100-gallon oil containers in the lube area did Corrected—The secondary containment was relocated <br /> not appear to have adequate secondary containment. Portions of the to be directly under the two 100-gallon oil containers. <br /> two tanks were not within the secondary containment tank thatwas Both tanks are nowwithin the secondary containment. <br /> directly underneath them.The bottom corners of tanks closest to the <br /> wall did not appear to be within the secondary containment area.The <br /> SPCC plan stated the pit areawould contain any oil not contained by <br /> the tank.The pit area had a metal berm around it thatwould prevent <br /> liquid from going into it. <br /> 710-There is no industry standard selected or referenced for the Corrected-The Bulk Storage Container Integrity <br /> inspections/tests of most of the APSA regulated tanks. Testing and Inspection Schedule(Appendix J)was <br /> updated to state that the all referenced AST and <br /> The 10,000-gallon tank has a hybrid plan developed for it which portable container inspections must meet the <br /> mentions the Steel Tank Institute SP001 standard.The standard is requirements of STI SP001. <br /> deviated from and a full discussion of environmental equivalence is The AST and portable container sections of the Monthly <br /> not provided in the SPCC plan. Facility Inspection Checklist(Appendix F)have been <br /> updated to meet the requirements of STI SP001. <br /> An STI SP001 compliant Annual AST and Portable <br /> Container Inspection Checklist(Appendix F-1)has <br /> been added. <br /> The AST Integrity Testing Protocol J-1 for the 10,000- <br /> gallon tank was removed from the SPCC plan.The <br /> integrity testing and inspection requirements in <br /> Appendix J for this tank now reflect the requirements of <br /> STI SP001 for a Category 1 tank. <br />