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Tracy Material Recovery& Transfer Station SPCC Plan 4.0 SPILL PREVENTION MEASURES 4.1 Weekly Tank Inspections Inspections of the Facility's aboveground storage containers will be conducted in accordance with 40 CFR §112.7(e) and 40 CFR §112.8(d). A record of the inspections, signed by the appropriate supervisor or inspector,will be made part of the SPCC Plan and will be maintained on site for a period of three years per 40 CFR§112.7(e). Visual inspections will be conducted on the ASTs, tank exteriors, valves, fittings, associated piping, and supports to check for signs of leaks and deterioration per 40 CFR §112.8(c). In addition, the foundation pads and containment systems will be inspected for chipping, rust, cracks, or other signs of deterioration. Any accumulation of fluids within the containment system will be cleaned up as soon as practicable with absorbent. The cause of the release will be identified and corrected in a timely manner per 40 CFR§112.8(c). The AST inspections are required to be documented per 40 CFR §112.7(e). The AST inspection form includes a standard checklist for the tank. A list of typical inspection criteria that will be used at the TMR Facility is included in Appendix 5. Any exceptions will be described by the inspector in the comments section along with the corrective action measure(s)taken. The inspection form will be signed and dated by the Facility employee assigned to conduct the inspections. The actual master version of the inspection form will be maintained electronically by TMR. The hardcopy version in the SPCC binder may be outdated. All facility oil storage tanks are double walled, or are single-walled with secondary containment structures, and are elevated above the underlying floor slab. With double-walled tanks, the annular space provides secondary containment;the air gap between the outer tank wall and the foundation slab allows another level of protection against oil spills through visible leak detection. This extra level of protection is equivalent to that which would be achieved through tank integrity testing required under Section 112.8(c)(6). Ongoing visual inspections are performed and documented by a qualified professional service provider in accordance with industry standards. Individual 55-gallon oil storage containers, by their nature, are used on site for relatively short periods of time. They are staged on spill pallets that provide spill containment and, if leakage occurs, 100%of the exterior of each container can be subjected to visual inspection, providing an extra level of protection against oil spills. This extra level of protection is equivalent to that which would be achieved through tank integrity testing required under Section 112.8(c)(6). Therefore, provided ongoing visual inspections are performed and documented, tank integrity testing is not required for the tanks at this facility. Therefore, provided ongoing visual inspections are performed and documented, tank integrity testing is not required for the tanks at this facility. October 2019 4-1