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Documentation of Corrective Actions aNorthwest Pipe San Joaquin County—Environmental Health Department Company Aboveground Petroleum Storage Act Inspection Report(03/31/2020) Pending corrections as per Cesar Ruvalcaba/Lydia Baker Amendmentof by Owners or Operators 301 CFR 112.5(a) Failed to amend Plan as necessary The SPCC plan does not address all APSA qualified tanks. The SPCC plan failed to address an emergency generator with a belly tank containing diesel and capacity which appears to be over 55 gallons. Operational equipment in the Bell Expander and Hydrotest areas were not addressed in the SPCC plan. The operational equipment consists of two hydraulic fluid reservoirs of 300 gallons and another that may be between 400 and 500 gallons. The area referred to as the Hazardous Waste consolidation area was observed with several 55 gallon drums, some of which were described as containing oily water and is not addressed in the plan. The Spill Prevention, Control,and Countermeasure(SPCC)Plan must be amended when there is a change in the facility design, construction, operation, or maintenance that materially affects its potential for a discharge, within 6 months of the change, and implemented as soon as possible, not later than 6 months following preparation of the amendment. Corrective Action: Immediately make all necessary amendments to the SPCC Plan to accurately represent the procedures and policies currently in place at the facility. Include all aboveground petroleum storage tanks with a capacity of 55 gallons or more. The facility's SPCC Plan was amended to represent accurately the procedures and policies in place currently at this facility. The following aboveground petroleum storage tanks / containers with a capacity of 55 gallons or more were added to the facility's inventory(See SPCC Plan) - 55-Gal. Drum (Used oil accumulation) - 80-Gal. Emergency Generator belly(Diesel) The following qualified oil-filled operational equipment were added to facility's inventory(see SPCC plan) - 120-Gal. Helical weld oil tank(Lube oil recirculating tank) - 114-Gal. Byard weld oil tank(Hydraulic oil) - 200-Gal. Bell expander west side (Hydraulic oil) - 350-Gal. Bell expander east side(Hydraulic oil) - 200-Gal. Hydrotest oil tank(Hydraulic oil) - 110-Gal. Butt welder oil tank (Hydraulic oil) - 114-Gal. Skimmer oil tank(Hydraulic oil) - 96-Gal. Small expander(Hydraulic oil) - 80-Gal. Offset rolls oil tank(Hydraulic oil) - 134-Gal. Large expander(Hydraulic oil) - 170-Gal. D-load machine (Hydraulic oil) The most recent revision of SPCC plan includes an Oil-filled Operational Equipment representation in Figure 4.5. Additionally, table 5.2 on SPCC plan summarizes how we meet general secondary containment requirements for OFOE. RequirementsGeneral 602 CFR 112.7(a)(2) Plan failed to discuss equivalent environmental protection, if applicable. The Spill Prevention, Control, and Countermeasure (SPCC) failed to discuss alternative environmental protection requirements. The SPCC Plan states that the 300 and 500 gallon tanks along with some 55 gallon drums do not have overfill protection as required by CFR 112.8(c)(8). The SPCC plan does not give the reasons for nonconformance and a detailed description of the alternate method is not discussed. Table 6.1 of the SPCC plan states that the 300 and 500 gallon tanks do not require inspections, given the use of environmental equivalent measures described in section 5.4 of the SPCC plan. Section 5.4 of the SPCC plan does not discuss the reasons for nonconformance and fails to describe a detailed alternative method. If the SPCC Plan does not conform to the applicable requirements, the reasons for nonconformance must [be] stated and the alternate methods to achieve equivalent environmental protection must be described in detail in the Plan Page 1 of 4