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210 East Wetmore Street PR0544025 <br /> June 26, 2019 Program: APSA <br /> PHOTO 1: Deviation from SP001 industry standard (in SPCC plan) without environmental a uiM" <br /> valence. <br /> NE <br /> 09 July 2012 <br /> VJ AGE-NC Project No. 12-2072 <br /> Page 13 of 24 <br /> 3.7.4. Periodic Integrity Testing <br /> Non-destructive integrity evaILKItions fire not performed on ASTs. Facility management has <br /> deemed that routine AST inspections are srlfficient for identifying potential spills. Any <br /> leakage from ASTs are detected through 1»onitoring of the containment spaces performed <br /> on a monthly basis. Storage drums have all sides visible. Leaks, if present, are readily <br /> detected by facility personnel before discharging to navigable waters or adjoining <br /> shorelines. Appendix F includes all historical integrity tests performed on facility ASTs. <br /> 3.8. PERSONNEL, TRAINING, AND DISCHARGE PREVENTION PROCEDURES <br /> [40 CFR 112.7(F)] <br /> The EC is responsible for oil discharge prevention, control and response preparedness <br /> activities at the facility. <br /> Facility management has instructed oil-handling facility personnel in the operation and ' <br /> maintenance of oil pOIIIItIOn prevention equipment, discharge procedure protocols, <br /> applicable pollution control laws, rules and regulations, general facility operations and the <br /> content of the Plein, as necessary. Any new facility personnel with oil-handling <br /> responsibilities are provided with training prior to oil handling operations. <br /> Refresher discharge prevention briefings are held by the EC for all facility personnel <br /> ._., _ . .�.i -A Tho hrinfinnc ara ckimari nt unciminn rnntiniita <br /> Lydia Baker, REHS Page 1 of 5 <br />