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Documentation of Corrective Actions <br /> TI <br /> Northwest Pipe San Joaquin County—Environmental Health Department <br /> Company Aboveground Petroleum Storage Act Inspection Report(03/31/2020) <br /> Pending corrections as per Cesar Ruvalcaba/Lydia Baker <br /> RequirementsGeneral <br /> Corrective Action: <br /> Immediately amend the SPCC Plan to include a discussion of equivalent environmental protection. <br /> NWP will retract the Environmental Equivalence claim for meeting Overfill Protection System (OPS) <br /> requirements,because we currently meet 112.8(c)(8)(iii)and 112.8(c)(8)(iv) by using a measuring stick <br /> and following procedures that prevent overfill. The applicable procedure has been included in the <br /> SPCC Plan revision. <br /> 604 Plan failed to include oil type and storage capacity for each container. <br /> No remarks found in "Summary of Violations". <br /> The SPCC plan now includes the oil type and storage capacity for all aboveground petroleum storage <br /> tanks/containers with a capacity of 55 gallons or more. <br /> SPCC plan now includes the oil type and storage capacity for all qualified oil-filled operational <br /> equipment with a capacity of 55 gallons or more. <br /> Refer to Table 5.2 from SPCC Plan <br /> SPCC Plan Requirements for Onshore Facilities (excluding production facilities) <br /> 706 CFR 112.8(c)(2) Failed to provide and maintain adequate secondary containment <br /> The emergency generator was observed with insufficient secondary containment. There was no evident <br /> secondary containment for the belly tank of the generator. All bulk storage tanks must be provided with a <br /> secondary means of containment for the entire capacity of the tank and sufficient freeboard to contain <br /> precipitation. <br /> Corrective Action: <br /> Immediately provide sufficient secondary containment for this and all other tanks at this facility. <br /> A proper containment method for the emergency generator fuel (belly) tank has been identified, and <br /> is described the discharge or drainage control section;the new containment system is also mentioned <br /> in SPCC plan. <br /> Northwest Pipe Company hereby commits to custom fabricate containment with a capacity of —248 <br /> gallons, enough to contain the entire capacity of the 80 gallon belly tank plus sufficient freeboard to <br /> contain precipitation. <br /> NWP has fabricated secondary containment as described above. <br /> Page 2of4 <br />