Document 1Q5QBk4bzaqvM0L9zwagrjmyK

U.S. ENVIRONMENTAL PROTECTION AGENCY SPCC FIELD INSPECTION AND PLAN REVIEW CHECKLIST ONSHORE FACILITIES (EXCLUDING OIL DRILLING, PRODUCTION AND WORKOVER) Overview of the Checklist This checklist is designed to assist EPA inspectors in conducting a thorough and nationally consistent inspection of a facility's compliance with the Spill Prevention, Control, and Countermeasure (SPCC) rule at 40 CFR part 112. It is a required tool to help federal inspectors (or their contractors) record observations for the site inspection and review of the SPCC Plan. While the checklist is meant to be comprehensive, the inspector should always refer to the SPCC rule in its entirety, the SPCC Regional Inspector Guidance Document, and other relevant guidance for evaluating compliance. This checklist must be completed in order for an inspection to count toward an agency measure (i.e., OEM inspection measures or GPRA). The completed checklist and supporting documentation (i.e. photo logs or additional notes) serve as the inspection report. This checklist addresses requirements for onshore facilities including Tier II Qualified Facilities (excluding facilities involved in oil drilling, production and workover activities) that meet the eligibility criteria set forth in 112.3(g)(2). Separate standalone checklists address requirements for: Onshore oil drilling, production, and workover facilities including Tier II Qualified Facilities as defined in 112.3(g)(2); Offshore drilling, production and workover facilities; and Tier I Qualified Facilities (for facilities that meet the eligibility criteria defined in 112.3(g)(1)) Qualified facilities must meet the rule requirements in 112.6 and other applicable sections specified in 112.6, except for deviations that provide environmental equivalence and secondary containment impracticability determinations as allowed under 112.6. The checklist is organized according to the SPCC rule. Each item in the checklist identifies the relevant section and paragraph in 40 CFR part 112 where that requirement is stated. Sections 112.1 through 112.5 specify the applicability of the rule and requirements for the preparation, implementation, and amendment of SPCC Plans. For these sections, the checklist includes data fields to be completed, as well as several questions with "yes," "no" or "NA" answers. Section 112.6 includes requirements for qualified facilities. These provisions are addressed in Attachment D. Section 112.7 includes general requirements that apply to all facilities (unless otherwise excluded). Sections 112.8 and 112.12 specify requirements for spill prevention, control, and countermeasures for onshore facilities (excluding production facilities). The inspector needs to evaluate whether the requirement is addressed adequately or inadequately in the SPCC Plan and whether it is implemented adequately in the field (either by field observation or record review). For the SPCC Plan and implementation in the field, if a requirement is addressed adequately, mark the "Yes" box in the appropriate column. If a requirement is not addressed adequately, mark the "No" box. If a requirement does not apply to the particular facility or the question asked is not appropriate for the facility, mark as "NA". Discrepancies or descriptions of inspector interpretation of "No" vs. "NA" may be documented in the comments box subsequent to each section. If a provision of the rule applies only to the SPCC Plan, the "Field" column is shaded. Space is provided throughout the checklist to record comments. Additional space is available as Attachment E at the end of the checklist. Comments should remain factual and support the evaluation of compliance. Attachments Attachment A is for recording information about containers and other locations at the facility that require secondary containment. Attachment B is a checklist for documentation of the tests and inspections the facility operator is required to keep with the SPCC Plan. Attachment C is a checklist for oil spill contingency plans following 40 CFR 109. Unless a facility has submitted a Facility Response Plan (FRP) under 40 CFR 112.20, a contingency plan following 40 CFR 109 is required if a facility determines that secondary containment is impracticable as provided in 40 CFR 112.7(d). The same requirement for an oil spill contingency plan applies to the owner or operator of a facility with qualified oil-filled operational equipment that chooses to implement alternative requirements instead of general secondary containment requirements as provided in 40 CFR 112.7(k). Attachment D is a checklist for Tier II Qualified Facilities. Attachment E is for recording additional comments or notes. Attachment F is for recording information about photos. Onshore Facilities (Excluding Oil Production) Page 1 of 14 June 2014 FACILITY INFORMATION FACILITY NAME: Pointe Oasis LATITUDE: 38.168951 LONGITUDE: -92.707479 GPS DATUM: WGS84 Section/Township/Range: 05/39N/16W FRS#/OIL DATABASE ID: R7-MO-00244 ICIS#: ADDRESS: 90 Oasis Circle CITY: Sunrise Beach STATE: Missouri ZIP: 65079 COUNTY: Camden MAILING ADDRESS (IF DIFFERENT FROM FACILITY ADDRESS - IF NOT, PRINT "SAME"): Same CITY: STATE: ZIP: COUNTY: TELEPHONE: 573-374-1400 FACILITY CONTACT NAME/TITLE: Scott Michel / Manager OWNER NAME: Pointe Oasis, Inc. OWNER ADDRESS: 442 Highly Drive CITY: Sunrise Beach STATE: Missouri ZIP: 65079 COUNTY: Camden TELEPHONE: FAX: EMAIL: pointeoasisbiz@gmail.com FACILITY OPERATOR NAME (IF DIFFERENT FROM OWNER - IF NOT, PRINT "SAME"): Pointe Oasis OPERATOR ADDRESS: 90 Oasis Circle CITY: Sunrise Beach STATE: Missouri ZIP: 65079 COUNTY: Camden TELEPHONE: 573-374-1400 OPERATOR CONTACT NAME/TITLE: Scott Michel / Manager FACILITY TYPE: Marina NAICS CODE: 713930 HOURS PER DAY FACILITY ATTENDED: 12 hours TOTAL FACILITY CAPACITY: 32,500 gallons TYPE(S) OF OIL STORED: Unleaded Fuel, Premium Fuel, Red Dye Diesel LOCATED IN INDIAN COUNTRY? YES NO RESERVATION NAME: INSPECTION/PLAN REVIEW INFORMATION PLAN REVIEW DATE: REVIEWER NAME: Facility does not have an SPCC Plan INSPECTION DATE: 05/14/2024 TIME: 13:00 ACTIVITY ID NO: SPCC-MO-2024-00003 LEAD INSPECTOR: Mark Aaron / Abigail Widiker OTHER INSPECTOR(S): Abigail Sroufe INSPECTION ACKNOWLEDGMENT I performed an SPCC inspection at the facility specified above. INSPECTOR SIGNATURE: MARK AARON Date: 2024.06.05 15:24:33 -05'00' Digitally signed by MARK AARON DATE: Digitally signed by CANDACE SUPERVISOR REVIEW/SIGNATURE: CANDACE BEDNAR BEDNAR DATE: 06/25/2024 Date: 2024.06.25 13:37:21 -05'00' Onshore Facilities (Excluding Oil Production) Page 2 of 14 June 2014 SPCC GENERAL APPLICABILITY--40 CFR 112.1 IS THE FACILITY REGULATED UNDER 40 CFR part 112? The completely buried oil storage capacity is over 42,000 U.S. gallons, OR the aggregate aboveground oil storage capacity is over 1,320 U.S. gallons AND The facility is a non-transportation-related facility engaged in drilling, producing, gathering, storing, processing, refining, transferring, distributing, using, or consuming oil and oil products, which due to its location could reasonably be expected to discharge oil into or upon the navigable waters of the United States Yes No Yes No AFFECTED WATERWAY(S): Lake of the Ozarks DISTANCE: 0 feet FLOW PATH TO WATERWAY: The three fuel lines are located directly over Lake of the Ozarks. The fuel lines run approximately 195 feet over Lake of the Ozarks. The facility has nine fueling stations and seventeen fuel hoses located on Lake of the Ozarks. Note: The following storage capacity is not considered in determining applicability of SPCC requirements: Equipment subject to the authority of the U.S. Department of Transportation, U.S. Department of the Interior, or Minerals Management Service, as defined in Memoranda of Understanding dated November 24, 1971, and November 8, 1993; Tank trucks that return to an otherwise regulated facility that contain only residual amounts of oil (EPA Policy letter) Containers smaller than 55 U.S. gallons; Permanently closed containers (as defined in 112.2); Motive power containers(as defined in 112.2); Hot-mix asphalt or any hot-mix asphalt containers; Completely buried tanks subject to all the technical requirements of 40 CFR part 280 or a state program approved under 40 CFR part 281; Heating oil containers used solely at a single-family residence; Underground oil storage tanks deferred under 40 CFR part 280 that supply emergency diesel generators at a nuclear power generation facility licensed by the Nuclear Regulatory Commission (NRC) and subject to any NRC provision regarding design and quality criteria, including but not limited to CFR part 50; Any facility or part thereof used exclusively for wastewater treatment (production, recovery or recycling of oil is not considered wastewater treatment); (This does not include other oil containers located at a wastewater treatment facility, such as generator tanks or transformers) Pesticide application equipment and related mix containers; Any milk and milk product container and associated piping and appurtenances; and Intra-facility gathering lines subject to the regulatory requirements of 49 CFR part 192 or 195. Does the facility have an SPCC Plan? Yes No FACILITY RESPONSE PLAN (FRP) APPLICABILITY--40 CFR 112.20(f) A non-transportation related onshore facility is required to prepare and implement an FRP as outlined in 40 CFR 112.20 if: The facility transfers oil over water to or from vessels and has a total oil storage capacity greater than or equal to 42,000 U.S. gallons, OR The facility has a total oil storage capacity of at least 1 million U.S. gallons, AND at least one of the following is true: The facility does not have secondary containment sufficiently large to contain the capacity of the largest aboveground tank plus sufficient freeboard for precipitation. The facility is located at a distance such that a discharge could cause injury to fish and wildlife and sensitive environments. The facility is located such that a discharge would shut down a public drinking water intake. The facility has had a reportable discharge greater than or equal to 10,000 U.S. gallons in the past 5 years. Facility has FRP: Yes No NA FRP Number: Facility has a completed and signed copy of Appendix C, Attachment C-II, "Certification of the Applicability of the Substantial Harm Criteria." Yes No Comments: Mr. Michel stated that the facility does not have an SPCC Plan. He was unfamiliar with the requirement to have an SPCC Plan. A Certification of the Applicability of the Substantial Harm Criteria is not signed and dated by the owner or operator. Onshore Facilities (Excluding Oil Production) Page 3 of 14 June 2014 SPCC TIER II QUALIFIED FACILITY APPLICABILITY--40 CFR 112.3(g)(2) The aggregate aboveground oil storage capacity is 10,000 U.S. gallons or less AND Yes In the three years prior to the SPCC Plan self-certification date, or since becoming subject to the rule (if the facility has been in operation for less than three years), the facility has NOT had: A single discharge as described in 112.1(b) exceeding 1,000 U.S. gallons, OR Yes Two discharges as described in 112.1(b) each exceeding 42 U.S. gallons within any twelve-month period1 Yes IF YES TO ALL OF THE ABOVE, THEN THE FACILITY IS A TIER II QUALIFIED FACILITY2 SEE ATTACHMENT D FOR TIER II QUALIFIED FACILITY CHECKLIST REQUIREMENTS FOR PREPARATION AND IMPLEMENTATION OF A SPCC PLAN--40 CFR 112.3 Date facility began operations: 8/28/97 Date of initial SPCC Plan preparation: Current Plan version (date/number): 112.3(a) For facilities (except farms), including mobile or portable facilities: In operation on or prior to November 10, 2011: Plan prepared and/or amended and fully Yes implemented by November 10, 2011 Beginning operations after November 10, 2011, Plan prepared and fully implemented Yes before beginning operations For farms (as defined in 112.2): In operation on or prior to August 16, 2002: Plan maintained, amended and Yes implemented by May 10, 2013 Beginning operations after August 16, 2002 through May 10, 2013: Plan prepared and Yes fully implemented by May 10, 2013 Beginning operations after May 10, 2013: Plan prepared and fully implemented before Yes beginning operations 112.3(d) Plan is certified by a registered Professional Engineer (PE) and includes statements that the Yes PE attests: PE is familiar with the requirements of 40 CFR part 112 Yes PE or agent has visited and examined the facility Yes Plan is prepared in accordance with good engineering practice including consideration Yes of applicable industry standards and the requirements of 40 CFR part 112 Procedures for required inspections and testing have been established Yes Plan is adequate for the facility Yes PE Name: License No.: State: Date of certification: 112.3(e)(1) Plan is available onsite if attended at least 4 hours per day. If facility is unattended, Plan is Yes available at the nearest field office. (Please note nearest field office contact information in comments section below.) Comments: The facility does not have an SPCC Plan No No No No NA No NA No NA No NA No NA No NA No NA No NA No NA No NA No NA No NA 1 Oil discharges that result from natural disasters, acts of war, or terrorism are not included in this determination. The gallon amount(s) specified (either 1,000 or 42) refers to the amount of oil that actually reaches navigable waters or adjoining shorelines not the total amount of oil spilled. The entire volume of the discharge is oil for this determination. 2 An owner/operator who self-certifies a Tier II SPCC Plan may include environmentally equivalent alternatives and/or secondary containment impracticability determinations when reviewed and certified by a PE. Onshore Facilities (Excluding Oil Production) Page 4 of 14 June 2014 AMENDMENT OF SPCC PLAN BY REGIONAL ADMINISTRATOR (RA)--40 CFR 112.4 112.4(a),(c) Has the facility discharged more than 1,000 U.S. gallons of oil in a single reportable discharge or more than 42 U.S. gallons in each of two reportable discharges in any 12-month period?3 If YES Was information submitted to the RA as required in 112.4(a)?4 Was information submitted to the appropriate agency or agencies in charge of oil pollution control activities in the State in which the facility is located112.4(c) Date(s) and volume(s) of reportable discharges(s) under this section: _____________________________________________________________ Were the discharges reported to the NRC5? 112.4(d),(e) Have changes required by the RA been implemented in the Plan and/or facility? Comments: Yes No Yes No NA Yes No NA Yes No Yes No NA AMENDMENT OF SPCC PLAN BY THE OWNER OR OPERATOR--40 CFR 112.5 112.5(a) Has there been a change at the facility that materially affects the potential for a discharge described in 112.1(b)? If YES Was the Plan amended within six months of the change? Were amendments implemented within six months of any Plan amendment? 112.5(b) Review and evaluation of the Plan completed at least once every 5 years? Following Plan review, was Plan amended within six months to include more effective prevention and control technology that has been field-proven to significantly reduce the likelihood of a discharge described in 112.1(b)? Amendments implemented within six months of any Plan amendment? Five year Plan review and evaluation documented? 112.5(c) Professional Engineer certification of any technical Plan amendments in accordance with all applicable requirements of 112.3(d) [Except for self-certified Plans] Name: License No.: State: Date of certification: Reason for amendment: Yes No Yes No Yes No Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Comments: The facility does not have an SPCC Plan, so the amendment requirements cannot be evaluated. 3 A reportable discharge is a discharge as described in 112.1(b)(see 40 CFR part 110). The gallon amount(s) specified (either 1,000 or 42) refers to the amount of oil that actually reaches navigable waters or adjoining shorelines not the total amount of oil spilled. The entire volume of the discharge is oil for this determination. 4 Triggering this threshold may disqualify the facility from meeting the Qualified Facility criteria if it occurred in the three years prior to self certification 5 Inspector Note-Confirm any spills identified above were reported to NRC Onshore Facilities (Excluding Oil Production) Page 5 of 14 June 2014 GENERAL SPCC REQUIREMENTS--40 CFR 112.7 Management approval at a level of authority to commit the necessary resources to fully implement the Plan6 PLAN Yes No Plan follows sequence of the rule or is an equivalent Plan meeting all applicable rule requirements and includes a cross-reference of provisions Yes No NA If Plan calls for facilities, procedures, methods, or equipment not yet fully operational, details of their installation and start-up are discussed (Note: Relevant for inspection evaluation and testing baselines.) Yes No NA 112.7(a)(2) If YES The Plan includes deviations from the requirements of 112.7(g), (h)(2) and (3), and (i) and applicable subparts B and C of the rule, except the secondary containment requirements in 112.7(c) and (h)(1), 112.8(c)(2),112.8(c)(11), 112.12(c)(2), and 112.12(c)(11) The Plan states reasons for nonconformance Alternative measures described in detail and provide equivalent environmental protection (Note: Inspector should document if the environmental equivalence is implemented in the field, in accordance with the Plan's description) Yes No NA Yes No NA Yes No NA Describe each deviation and reasons for nonconformance: The facility does not have an SPCC Plan, so these general requirements cannot be evaluated. FIELD Yes No NA 6 May be part of the Plan or demonstrated elsewhere. Onshore Facilities (Excluding Oil Production) Page 6 of 14 June 2014 112.7(a)(3) (i) (ii) (iii) (iv) (v) (vi) 112.7(a)(4) 112.7(a)(5) 112.7(b) Comments: Plan describes physical layout of facility and includes a diagram7 that identifies: Location and contents of all regulated fixed oil storage containers Storage areas where mobile or portable containers are located Completely buried tanks otherwise exempt from the SPCC requirements (marked as "exempt") Transfer stations Connecting pipes, including intra-facility gathering lines that are otherwise exempt from the requirements of this part under 112.1(d)(11) Plan addresses each of the following: For each fixed container, type of oil and storage capacity (see Attachment A of this checklist). For mobile or portable containers, type of oil and storage capacity for each container or an estimate of the potential number of mobile or portable containers, the types of oil, and anticipated storage capacities Discharge prevention measures, including procedures for routine handling of products (loading, unloading, and facility transfers, etc.) Discharge or drainage controls, such as secondary containment around containers, and other structures, equipment, and procedures for the control of a discharge Countermeasures for discharge discovery, response, and cleanup (both facility's and contractor's resources) Methods of disposal of recovered materials in accordance with applicable legal requirements Contact list and phone numbers for the facility response coordinator, National Response Center, cleanup contractors with an agreement for response, and all Federal, State, and local agencies who must be contacted in the case of a discharge as described in 112.1(b) PLAN Yes No Yes No Yes No Yes No Yes No Yes No Yes No Does not apply if the facility has submitted an FRP under 112.20: Yes No NA Plan includes information and procedures that enable a person reporting an oil discharge as described in 112.1(b) to relate information on the: Exact address or location and phone number of the facility; Date and time of the discharge; Type of material discharged; Estimates of the total quantity discharged; Description of all affected media; Cause of the discharge; Damages or injuries caused by the discharge; Actions being used to stop, remove, and mitigate the effects of the discharge; Estimates of the quantity discharged as described in 112.1(b); Source of the discharge; Whether an evacuation may be needed; and Names of individuals and/or organizations who have also been contacted. Does not apply if the facility has submitted a FRP under 112.20: Plan organized so that portions describing procedures to be used when a discharge occurs will be readily usable in an emergency Yes No NA Plan includes a prediction of the direction, rate of flow, and total quantity of oil that could be discharged for each type of major equipment failure where experience indicates a reasonable potential for equipment failure Yes No NA FIELD Yes No Yes No Yes No Yes No Yes No 7 Note in comments any discrepancies between the facility diagram, the description of the physical layout of facility, and what is observed in the field Onshore Facilities (Excluding Oil Production) Page 7 of 14 June 2014 PLAN FIELD 112.7(c) Appropriate containment and/or diversionary structures or equipment are provided to prevent a discharge as described in 112.1(b), except as provided in 112.7(k) of this section for certain qualified operational equipment. The entire containment system, including walls and floors, are capable of containing oil and are constructed to prevent escape of a discharge from the containment system before cleanup occurs. The method, design, and capacity for secondary containment address the typical failure mode and the most likely quantity of oil that would be discharged. See Attachment A of this checklist. For onshore facilities, one of the following or its equivalent: Dikes, berms, or retaining walls sufficiently impervious to contain oil; Curbing or drip pans; Sumps and collection systems; Culverting, gutters or other drainage systems; Weirs, booms or other barriers; Spill diversion pond; Retention ponds; or Sorbent materials. Identify which of the following are present at the facility and if appropriate containment and/or diversionary structures or equipment are provided as described above: Bulk storage containers Yes No NA Yes No NA Mobile/portable containers Yes No NA Yes No NA Oil-filled operational equipment (as defined in 112.2) Yes No NA Yes No NA Other oil-filled equipment (i.e., manufacturing equipment) Yes No NA Yes No NA Piping and related appurtenances Yes No NA Yes No NA Mobile refuelers or non-transportation-related tank cars Yes No NA Yes No NA Transfer areas, equipment and activities Yes No NA Yes No NA Identify any other equipment or activities that are not listed above: __________________________________________ Yes No NA Yes No NA 112.7(d) Secondary containment for one (or more) of the following provisions is determined to be impracticable: Yes No General secondary containment 112.7(c) Loading/unloading rack 112.7(h)(1) Bulk storage containers 112.8(c)(2)/112.12(c)(2) Mobile/portable containers112.8(c)(11)/ 112.12(c)(11) If YES The impracticability of secondary containment is clearly demonstrated and described in the Plan For bulk storage containers,8 periodic integrity testing of containers and integrity and leak testing of the associated valves and piping is conducted Yes No NA Yes No NA Yes No NA Yes No NA (Does not apply if the facility has submitted a FRP under 112.20): Contingency Plan following the provisions of 40 CFR part 109 is provided (see Attachment C of this checklist) AND Written commitment of manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful Yes No NA Yes No NA Yes No NA Comments: I observed that both concrete containment dikes have cracks in their foundations. I also observed that rainwater was leaking out of the bottom of the eastern containment dike during the inspection. In June of 2021, the Missouri Department of Natural Resources observed a leak of stormwater in the corner of the eastern most concrete containment dike. Indicating that the structure was not holding water as intended. 8 These additional requirements apply only to bulk storage containers, when an impracticability determination has been made by the PE Onshore Facilities (Excluding Oil Production) Page 8 of 14 June 2014 PLAN FIELD 112.7(e) Inspections and tests conducted in accordance with written procedures Record of inspections or tests signed by supervisor or inspector Kept with Plan for at least 3 years (see Attachment B of this checklist)9 Yes No Yes No Yes No Yes No Yes No Yes No 112.7(f) Personnel, training, and oil discharge prevention procedures (1) Training of oil-handling personnel in operation and maintenance of equipment to prevent discharges; discharge procedure protocols; applicable pollution control laws, rules, and regulations; general facility operations; and contents of SPCC Plan (2) Person designated as accountable for discharge prevention at the facility and reports to facility management (3) Discharge prevention briefings conducted at least once a year for oil handling personnel to assure adequate understanding of the Plan. Briefings highlight and describe known discharges as described in 112.1(b) or failures, malfunctioning components, and any recently developed precautionary measures Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA 112.7(g) Plan describes how to: Secure and control access to the oil handling, processing and storage areas; Secure master flow and drain valves; Prevent unauthorized access to starter controls on oil pumps; Secure out-of-service and loading/unloading connections of oil pipelines; and Address the appropriateness of security lighting to both prevent acts of vandalism and assist in the discovery of oil discharges. Yes No NA Yes No NA 112.7(h) Tank car and tank truck loading/unloading rack10 is present at the facility Yes No Loading/unloading rack means a fixed structure (such as a platform, gangway) necessary for loading or unloading a tank truck or tank car, which is located at a facility subject to the requirements of this part. A loading/unloading rack includes a loading or unloading arm, and may include any combination of the following: piping assemblages, valves, pumps, shut-off devices, overfill sensors, or personnel safety devices. If YES (1) Does loading/unloading rack drainage flow to catchment basin or treatment facility designed to handle discharges or use a quick drainage system? Containment system holds at least the maximum capacity of the largest single compartment of a tank car/truck loaded/unloaded at the facility Yes No NA Yes No NA Yes No NA Yes No NA (2) An interlocked warning light or physical barriers, warning signs, wheel chocks, or vehicle brake interlock system in the area adjacent to the loading or unloading rack to prevent vehicles from departing before complete disconnection of flexible or fixed oil transfer lines Yes No NA Yes No NA (3) Lower-most drains and all outlets on tank cars/trucks inspected prior to filling/departure, and, if necessary ensure that they are tightened, adjusted, or replaced to prevent liquid discharge while in transit Yes No NA Yes No NA Comments: The operator, Mr. Michel, did not provide records of applicable inspections or tests. Mr. Michel stated that the facility does not conduct personnel training on applicable pollution control laws, rules, and regulations. He was unfamiliar with these requirements. 9 Records of inspections and tests kept under usual and customary business practices will suffice 10 Note that a tank car/truck loading/unloading rack must be present for 112.7(h) to apply Onshore Facilities (Excluding Oil Production) Page 9 of 14 June 2014 112.7(i) 112.7(j) 112.7(k) If YES 112.7(k) PLAN FIELD Brittle fracture evaluation of field-constructed aboveground containers is conducted after tank repair, alteration, reconstruction, or change in service that might affect the risk of a discharge or after a discharge/failure due to brittle fracture or other catastrophe, and appropriate action taken as necessary (applies to only fieldconstructed aboveground containers) Yes No NA Yes No NA Discussion of conformance with applicable more stringent State rules, regulations, and guidelines and other effective discharge prevention and containment procedures listed in 40 CFR part 112 Yes No NA Qualified oil-filled operational equipment is present at the facility11 Yes No Oil-filled operational equipment means equipment that includes an oil storage container (or multiple containers) in which the oil is present solely to support the function of the apparatus or the device. Oil-filled operational equipment is not considered a bulk storage container, and does not include oil-filled manufacturing equipment (flow-through process). Examples of oil-filled operational equipment include, but are not limited to, hydraulic systems, lubricating systems (e.g. , those for pumps, compressors and other rotating equipment, including pumpjack lubrication systems), gear boxes, machining coolant systems, heat transfer systems, transformers, circuit breakers, electrical switches, and other systems containing oil solely to enable the operation of the device. Check which apply: Secondary Containment provided in accordance with 112.7(c) Alternative measure described below (confirm eligibility) Qualified Oil-Filled Operational Equipment Has a single reportable discharge as described in 112.1(b) from any oil-filled operational equipment exceeding 1,000 U.S. gallons occurred within the three years prior to Plan certification date? Have two reportable discharges as described in 112.1(b) from any oil-filled operational equipment each exceeding 42 U.S. gallons occurred within any 12-month period within the three years prior to Plan certification date?12 Yes No NA Yes No NA Comments: If YES for either, secondary containment in accordance with 112.7(c) is required Facility procedure for inspections or monitoring program to detect equipment failure and/or a discharge is established and documented Does not apply if the facility has submitted a FRP under 112.20: Contingency plan following 40 CFR part 109 (see Attachment C of this checklist) is provided in Plan AND Written commitment of manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful is provided in Plan Yes No NA Yes No NA Yes No NA Yes No NA 11 This provision does not apply to oil-filled manufacturing equipment (flow-through process) 12 Oil discharges that result from natural disasters, acts of war, or terrorism are not included in this determination. The gallon amount(s) specified (either 1,000 or 42) refers to the amount of oil that actually reaches navigable waters or adjoining shorelines not the total amount of oil spilled. The entire volume of the discharge is oil for this determination. Onshore Facilities (Excluding Oil Production) Page 10 of 14 June 2014 ONSHORE FACILITIES (EXCLUDING PRODUCTION) 40 CFR 112.8/112.12 PLAN 112.8(b)/ 112.12(b) Facility Drainage Diked Areas (1) (2) Undiked Areas (3) (4) (5) If YES Drainage from diked storage areas is: Restrained by valves, except where facility systems are designed to control such discharge, OR Manually activated pumps or ejectors are used and the condition of the accumulation is inspected prior to draining dike to ensure no oil will be discharged Diked storage area drain valves are manual, open-and-closed design (not flapper-type drain valves) If drainage is released directly to a watercourse and not into an onsite wastewater treatment plant, retained storm water is inspected and discharged per 112.8(c)(3)(ii), (iii), and (iv) or 112.12(c)(3)(ii), (iii), and (iv). Drainage from undiked areas with a potential for discharge designed to flow into ponds, lagoons, or catchment basins to retain oil or return it to facility. Catchment basin located away from flood areas.13 If facility drainage not engineered as in (b)(3) (i.e., drainage flows into ponds, lagoons, or catchment basins) then the facility is equipped with a diversion system to retain oil in the facility in the event of an uncontrolled discharge.14 Are facility drainage waters continuously treated in more than one treatment unit and pump transfer is needed? Two "lift" pumps available and at least one permanently installed Facility drainage systems engineered to prevent a discharge as described in 112.1(b) in the case of equipment failure or human error Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Comments: The facility does not keep any records of drainage from the two concrete containment dikes. FIELD Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA 112.8(c)/112.12(c) Bulk Storage Containers NA Bulk storage container means any container used to store oil. These containers are used for purposes including, but not limited to, the storage of oil prior to use, while being used, or prior to further distribution in commerce. Oil-filled electrical, operating, or manufacturing equipment is not a bulk storage container. If bulk storage containers are not present, mark this section Not Applicable (NA). If present, complete this section and Attachment A of this checklist. (1) Containers materials and construction are compatible with material stored and conditions of storage such as pressure and temperature Yes No NA Yes No NA (2) Except for mobile refuelers and other non-transportation-related tank trucks, construct all bulk storage tank installations with secondary containment to hold capacity of largest container and sufficient freeboard for precipitation Diked areas sufficiently impervious to contain discharged oil OR Alternatively, any discharge to a drainage trench system will be safely confined in a facility catchment basin or holding pond Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA 13 Oil discharges that result from natural disasters, acts of war, or terrorism are not included in this determination. The gallon amount(s) specified (either 1,000 or 42) refers to the amount of oil that actually reaches navigable waters or adjoining shorelines not the total amount of oil spilled. The entire volume of the discharge is oil for this determination. 14 These provisions apply only when a facility drainage system is used for containment; otherwise mark NA Onshore Facilities (Excluding Oil Production) Page 11 of 14 June 2014 (3) If YES (4) (5) (6) Is there drainage of uncontaminated rainwater from diked areas into a storm drain or open watercourse? Bypass valve normally sealed closed Retained rainwater is inspected to ensure that its presence will not cause a discharge as described in 112.1(b) Bypass valve opened and resealed under responsible supervision Adequate records of drainage are kept; for example, records required under permits issued in accordance with 40 CFR 122.41(j)(2) and (m)(3) For completely buried metallic tanks installed on or after January 10, 1974 (if not exempt from SPCC regulation because subject to all of the technical requirements of 40 CFR part 280 or 281): Provide corrosion protection with coatings or cathodic protection compatible with local soil conditions Regular leak testing conducted The buried section of partially buried or bunkered metallic tanks protected from corrosion with coatings or cathodic protection compatible with local soil conditions Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs. Techniques include, but are not limited to: visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other system of non-destructive testing Appropriate qualifications for personnel performing tests and inspections are identified in the Plan and have been assessed in accordance with industry standards The frequency and type of testing and inspections are documented, are in accordance with industry standards and take into account the container size, configuration and design Comparison records of aboveground container integrity testing are maintained Container supports and foundations regularly inspected Outside of containers frequently inspected for signs of deterioration, discharges, or accumulation of oil inside diked areas Records of all inspections and tests maintained15 PLAN Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Integrity Testing Standard identified in the Plan: The facility does not have an SPCC Plan and no integrity testing standard was mentioned. FIELD Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA 112.12 (c)(6)(ii) (Applies to AFVO Facilities only) Conduct formal visual inspection on a regular schedule for bulk storage containers that meet all of the following conditions: Subject to 21 CFR part 110; Elevated; Constructed of austenitic stainless steel; Have no external insulation; and Shop-fabricated. In addition, you must frequently inspect the outside of the container for signs of deterioration, discharges, or accumulation of oil inside diked areas. You must determine and document in the Plan the appropriate qualifications for personnel performing tests and inspections.16 Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA 15 Records of inspections and tests kept under usual and customary business practices will suffice Onshore Facilities (Excluding Oil Production) Page 12 of 14 June 2014 PLAN FIELD (7) Leakage through defective internal heating coils controlled: Steam returns and exhaust lines from internal heating coils that discharge into an open watercourse are monitored for contamination, OR Steam returns and exhaust lines pass through a settling tank, skimmer, or other separation or retention system Yes No NA Yes No NA Yes No NA Yes No NA (8) Each container is equipped with at least one of the following for liquid level sensing: Yes No NA Yes No NA High liquid level alarms with an audible or visual signal at a constantly attended operation or surveillance station, or audible air vent in smaller facilities; High liquid level pump cutoff devices set to stop flow at a predetermined container content level; Direct audible or code signal communication between container gauger and pumping station; Fast response system for determining liquid level (such as digital computers, telepulse, or direct vision gauges) and a person present to monitor gauges and overall filling of bulk containers; or Regularly test liquid level sensing devices to ensure proper operation. (9) Effluent treatment facilities observed frequently enough to detect possible system upsets that could cause a discharge as described in 112.1(b) Yes No NA Yes No NA (10) Visible discharges which result in a loss of oil from the container, including but not limited to seams, gaskets, piping, pumps, valves, rivets, and bolts are promptly corrected and oil in diked areas is promptly removed Yes No NA Yes No NA (11) Mobile or portable containers positioned to prevent a discharge as described in 112.1(b). Mobile or portable containers (excluding mobile refuelers and other non-transportation-related tank trucks) have secondary containment with sufficient capacity to contain the largest single compartment or container and sufficient freeboard to contain precipitation Yes No NA Yes No NA Yes No NA Yes No NA 112.8(d)/112.12(d)Facility transfer operations, pumping, and facility process (1) Buried piping installed or replaced on or after August 16, 2002 has protective wrapping or coating Buried piping installed or replaced on or after August 16, 2002 is also cathodically protected or otherwise satisfies corrosion protection standards for piping in 40 CFR part 280 or 281 Buried piping exposed for any reason is inspected for deterioration; corrosion damage is examined; and corrective action is taken Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA (2) Piping terminal connection at the transfer point is marked as to origin and capped or blank-flanged when not in service or in standby service for an extended time Yes No NA Yes No NA (3) Pipe supports are properly designed to minimize abrasion and corrosion and allow for expansion and contraction Yes No NA Yes No NA (4) Aboveground valves, piping, and appurtenances such as flange joints, expansion joints, valve glands and bodies, catch pans, pipeline supports, locking of valves, and metal surfaces are inspected regularly to assess their general condition Integrity and leak testing conducted on buried piping at time of installation, modification, construction, relocation, or replacement Yes No NA Yes No NA Yes No NA Yes No NA (5) Vehicles warned so that no vehicle endangers aboveground piping and other oil transfer operations Yes No NA Yes No NA Comments: During the inspection, I observed that the 15,000-gallon tank was not equipped with a liquid level sensing device. Onshore Facilities (Excluding Oil Production) Page 13 of 14 June 2014 This page left intentionally blank. Onshore Facilities (Excluding Oil Production) Page 14 of 14 June 2014 ATTACHMENT A: SPCC FIELD INSPECTION AND PLAN REVIEW TABLE Documentation of Field Observations for Containers and Associated Requirements Inspectors should use this table to document observations of containers as needed. Containers and Piping Check containers for leaks, specifically looking for: drip marks, discoloration of tanks, puddles containing spilled or leaked material, corrosion, cracks, and localized dead vegetation, and standards/specifications of construction. Check aboveground container foundation for: cracks, discoloration, and puddles containing spilled or leaked material, settling, gaps between container and foundation, and damage caused by vegetation roots. Check all piping for: droplets of stored material, discoloration, corrosion, bowing of pipe between supports, evidence of stored material seepage from valves or seals, evidence of leaks, and localized dead vegetation. For all aboveground piping, include the general condition of flange joints, valve glands and bodies, drip pans, pipe supports, bleeder and gauge valves, and other such items (Document in comments section of 112.8(d) or 112.12(d).) Secondary Containment (Active and Passive) Check secondary containment for: containment system (including walls and floor) ability to contain oil such that oil will not escape the containment system before cleanup occurs, proper sizing, cracks, discoloration, presence of spilled or leaked material (standing liquid), erosion, corrosion, penetrations in the containment system, and valve conditions. Check dike or berm systems for: level of precipitation in dike/available capacity, operational status of drainage valves (closed), dike or berm impermeability, debris, erosion, impermeability of the earthen floor/walls of diked area, and location/status of pipes, inlets, drainage around and beneath containers, presence of oil discharges within diked areas. Check drainage systems for: an accumulation of oil that may have resulted from any small discharge, including field drainage systems (such as drainage ditches or road ditches), and oil traps, sumps, or skimmers. Ensure any accumulations of oil have been promptly removed. Check retention and drainage ponds for: erosion, available capacity, presence of spilled or leaked material, debris, and stressed vegetation. Check active measures (countermeasures) for: amount indicated in plan is available and appropriate; deployment procedures are realistic; material is located so that they are readily available; efficacy of discharge detection; availability of personnel and training, appropriateness of measures to prevent a discharge as described in 112.1(b). Container ID/ General Condition16 Aboveground or Buried Tank Storage Capacity and Type of Oil Type of Containment/ Drainage Control Overfill Protection and Testing & Inspections Tank 1 / Aboveground 5,500 gallons - red dye diesel Concrete Containment Dike / Drain Valve Overfill Alarm / No Testing / Visual Inspections Tank 2 / Aboveground 12,000 gallons - unleaded Concrete Containment premium gasoline Dike / Drain Valve Overfill Alarm / No Testing / Visual Inspections Tank 3 / Aboveground 15,000 gallons - unleaded Concrete Containment regular gasoline Dike / Drain Valve No Overfill Protection / No Testing / Visual Inspections 16 Identify each tank with either an A to indicate aboveground or B for completely buried Onshore Facilities (Excluding Oil Production) Page A-1 of 2 June 2014 ATTACHMENT A: SPCC FIELD INSPECTION AND PLAN REVIEW TABLE (CONT.) Documentation of Field Observations for Containers and Associated Requirements Container ID/ General Condition17 Aboveground or Buried Tank Storage Capacity and Type of Oil Type of Containment/ Drainage Control Overfill Protection and Testing & Inspections 17 Identify each tank with either an A to indicate aboveground or B for completely buried Onshore Facilities (Excluding Oil Production) Page A-2 of 2 June 2014 ATTACHMENT B: SPCC INSPECTION AND TESTING CHECKLIST Required Documentation of Tests and Inspections Records of inspections and tests required by 40 CFR part 112 signed by the appropriate supervisor or inspector must be kept by all facilities with the SPCC Plan for a period of three years. Records of inspections and tests conducted under usual and customary business practices will suffice. Documentation of the following inspections and tests should be kept with the SPCC Plan. Inspection or Test Documentation Present Not Present Not Applicable 112.7-General SPCC Requirements (d) Integrity testing for bulk storage containers with no secondary containment system and for which an impracticability determination has been made (d) Integrity and leak testing of valves and piping associated with bulk storage containers with no secondary containment system and for which an impracticability determination has been made (h)(3) Inspection of lowermost drain and all outlets of tank car or tank truck prior to filling and departure from loading/unloading rack (i) Evaluation of field-constructed aboveground containers for potential for brittle fracture or other catastrophic failure when the container undergoes a repair, alteration, reconstruction or change in service or has discharged oil or failed due to brittle fracture failure or other catastrophe k(2)(i) Inspection or monitoring of qualified oil-filled operational equipment when the equipment meets the qualification criteria in 112.7(k)(1) and facility owner/operator chooses to implement the alternative requirements in 112.7(k)(2) that include an inspection or monitoring program to detect oil-filled operational equipment failure and discharges 112.8/112.12-Onshore Facilities (excluding oil production facilities) (b)(1), (b)(2) Inspection of storm water released from diked areas into facility drainage directly to a watercourse (c)(3) Inspection of rainwater released directly from diked containment areas to a storm drain or open watercourse before release, open and release bypass valve under supervision, and records of drainage events (c)(4) Regular leak testing of completely buried metallic storage tanks installed on or after January 10, 1974 and regulated under 40 CFR 112 (c)(6) Regular integrity testing of aboveground containers and integrity testing after material repairs, including comparison records (c)(6), Regular visual inspections of the outsides of aboveground containers, supports (c)(10) and foundations (c)(6) Frequent inspections of diked areas for accumulations of oil (c)(8)(v) Regular testing of liquid level sensing devices to ensure proper operation (c)(9) Frequent observations of effluent treatment facilities to detect possible system upsets that could cause a discharge as described in 112.1(b) (d)(1) Inspection of buried piping for damage when piping is exposed and additional examination of corrosion damage and corrective action, if present (d)(4) Regular inspections of aboveground valves, piping and appurtenances and assessments of the general condition of flange joints, expansion joints, valve glands and bodies, catch pans, pipeline supports, locking of valves, and metal surfaces (d)(4) Integrity and leak testing of buried piping at time of installation, modification, construction, relocation or replacement Onshore Facilities (Excluding Oil Production) Page B-1 of 2 June 2014 This page left intentionally blank. Onshore Facilities (Excluding Oil Production) Page B-2 of 2 June 2014 ATTACHMENT C: SPCC CONTINGENCY PLAN REVIEW CHECKLIST NA 40 CFR Part 109-Criteria for State, Local and Regional Oil Removal Contingency Plans If SPCC Plan includes an impracticability determination for secondary containment in accordance with 112.7(d), the facility owner/operator is required to provide an oil spill contingency plan following 40 CFR part 109, unless he or she has submitted a FRP under 112.20. An oil spill contingency plan may also be developed, unless the facility owner/operator has submitted a FRP under 112.20 as one of the required alternatives to general secondary containment for qualified oil filled operational equipment in accordance with 112.7(k). 109.5-Development and implementation criteria for State, local and regional oil removal contingency plans18 Yes No (a) Definition of the authorities, responsibilities and duties of all persons, organizations or agencies which are to be involved in planning or directing oil removal operations. (b) Establishment of notification procedures for the purpose of early detection and timely notification of an oil discharge including: (1) The identification of critical water use areas to facilitate the reporting of and response to oil discharges. (2) A current list of names, telephone numbers and addresses of the responsible persons (with alternates) and organizations to be notified when an oil discharge is discovered. (3) Provisions for access to a reliable communications system for timely notification of an oil discharge, and the capability of interconnection with the communications systems established under related oil removal contingency plans, particularly State and National plans (e.g., National Contingency Plan (NCP)). (4) An established, prearranged procedure for requesting assistance during a major disaster or when the situation exceeds the response capability of the State, local or regional authority. (c) Provisions to assure that full resource capability is known and can be committed during an oil discharge situation including: (1) The identification and inventory of applicable equipment, materials and supplies which are available locally and regionally. (2) An estimate of the equipment, materials and supplies that would be required to remove the maximum oil discharge to be anticipated. (3) Development of agreements and arrangements in advance of an oil discharge for the acquisition of equipment, materials and supplies to be used in responding to such a discharge. (d) Provisions for well-defined and specific actions to be taken after discovery and notification of an oil discharge including: (1) Specification of an oil discharge response operating team consisting of trained, prepared and available operating personnel. (2) Pre-designation of a properly qualified oil discharge response coordinator who is charged with the responsibility and delegated commensurate authority for directing and coordinating response operations and who knows how to request assistance from Federal authorities operating under existing national and regional contingency plans. (3) A preplanned location for an oil discharge response operations center and a reliable communications system for directing the coordinated overall response operations. (4) Provisions for varying degrees of response effort depending on the severity of the oil discharge. (5) Specification of the order of priority in which the various water uses are to be protected where more than one water use may be adversely affected as a result of an oil discharge and where response operations may not be adequate to protect all uses. (e) Specific and well defined procedures to facilitate recovery of damages and enforcement measures as provided for by State and local statutes and ordinances. 18 The contingency plan should be consistent with all applicable state and local plans, Area Contingency Plans, and the NCP. Onshore Facilities (Excluding Oil Production) Page C-1 of 2 June 2014 This page left intentionally blank. Onshore Facilities (Excluding Oil Production) Page C-2 of 2 June 2014 ATTACHMENT D: TIER II QUALIFIED FACILITY CHECKLIST NA TIER II QUALIFIED FACILITY PLAN REQUIREMENTS --40 CFR 112.6(b) 112.6(b)(1) Plan Certification: Owner/operator certified in the Plan that: (i) He or she is familiar with the requirements of 40 CFR part 112 (ii) He or she has visited and examined the facility19 (iii) The Plan has been prepared in accordance with accepted and sound industry practices and standards and with the requirements of this part (iv) Procedures for required inspections and testing have been established (v) He or she will fully implement the Plan (vi) The facility meets the qualification criteria set forth under 112.3(g)(2) (vii) The Plan does not deviate from any requirements as allowed by 112.7(a)(2) and 112.7(d), except as described under 112.6(b)(3)(i) or (ii) (viii) The Plan and individual(s) responsible for implementing the Plan have the full approval of management and the facility owner or operator has committed the necessary resources to fully implement the Plan. Yes No Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA 112.6(b)(2) Technical Amendments: The owner/operator self-certified the Plan's technical amendments for a change in facility design, construction, operation, or maintenance that affected potential for a 112.1(b) discharge Yes No NA If YES Certification of technical amendments is in accordance with the self-certification provisions of 112.6(b)(1). Yes No NA (i) A PE certified a portion of the Plan (i.e., Plan is informally referred to as a hybrid Plan) Yes No NA If YES The PE also certified technical amendments that affect the PE certified portion of the Plan as required under 112.6(b)(4)(ii) Yes No NA (ii) The aggregate aboveground oil storage capacity increased to more than 10,000 U.S. gallons as a result of the change Yes No NA If YES The facility no longer meets the Tier II qualifying criteria in 112.3(g)(2) because it exceeds 10,000 U.S. gallons in aggregate aboveground storage capacity. The owner/operator prepared and implemented a Plan within 6 months following the change and had it certified by a PE under 112.3(d) Yes No NA 112.6(b)(3) If YES Plan Deviations: Does the Plan include environmentally equivalent alternative methods or impracticability determinations for secondary containment? Identify the alternatives in the hybrid Plan: Environmental equivalent alternative method(s) allowed under 112.7(a)(2); Impracticability determination under 112.7(d) Yes No NA Yes No NA Yes No NA 112.6(b)(4) (i) (A) (B) (C) For each environmentally equivalent measure, the Plan is accompanied by a written statement by the PE that describes: the reason for nonconformance, the alternative measure, and how it offers equivalent environmental protection in accordance with 112.7(a)(2); For each secondary containment impracticability determination, the Plan explains the reason for the impracticability determination and provides the alternative measures to secondary containment required in 112.7(d) AND PE certifies in the Plan that: He/she is familiar with the requirements of 40 CFR Part 112 He/she or a representative agent has visited and examined the facility The alternative method of environmental equivalence in accordance with 112.7(a)(2) or the determination of impracticability and alternative measures in accordance with 112.7(d) is consistent with good engineering practice, including consideration of applicable industry standards, and with the requirements of 40 CFR Part 112. Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Comments: 19 Note that only the person certifying the Plan can make the site visit Onshore Facilities (Excluding Oil Production) Page D-1 of 2 June 2014 This page left intentionally blank. Onshore Facilities (Excluding Oil Production) Page D-2 of 2 June 2014 ATTACHMENT E: ADDITIONAL COMMENTS 112.20(e) - The facility has not completed and signed a copy of the Certification of the Applicability of the Substantial Harm Criteria. 112.3(a) - The facility has not prepared and fully implemented an SPCC Plan. 112.7(e) - Records of applicable inspections and tests were not provided at the time of inspection. 112.8(c)(2) - The bulk storage secondary containment is not sufficiently impervious to contain the capacity of a discharge from the largest single containers. At the time of inspection, cracks near the bottom of both concrete containment dikes were observed. Rainwater was observed leaking out from the eastern containment's bottom during the inspection. In June of 2021, the Missouri Department of Natural Resources had also observed a leak of stormwater in the corner of the eastern most concrete containment. Indicating that the structure was not holding water/functioning as intended. 112.8(c)(3) - The facility does not keep any records of drainage for the two concrete containment dikes. 112.8(c)(6) - Integrity testing, in addition to regular visual inspections, is required in accordance with industry standards; including, the need to address qualifications for personnel performing the tests; a method, frequency, and type of testing; maintenance of comparison records of integrity testing; inspections of container supports and foundations; outsides of containers for accumulation of oil inside diked areas; and, recordkeeping of integrity testing for all tanks. 112.8(c)(8) - There is no liquid level sensing device provided for the 15,000-gallon aboveground storage tank. This inspection was conducted by Abigail Widiker. Mark Aaron, the credentialed SPCC inspector, oversaw the inspection process. Onshore Facilities (Excluding Oil Production) Page E-1 of 2 June 2014 ATTACHMENT E: ADDITIONAL COMMENTS (CONT.) Onshore Facilities (Excluding Oil Production) Page E-2 of 2 June 2014 ATTACHMENT F: PHOTO DOCUMENTATION NOTES Photo# Photographer Name See Attached Photo Log Time of Photo Taken Compass Direction Description Onshore Facilities (Excluding Oil Production) Page F-1 of 2 June 2014 Photo# ATTACHMENT F: PHOTO DOCUMENTATION NOTES (CONT.) Photographer Name Time of Photo Taken Compass Direction Description Onshore Facilities (Excluding Oil Production) Page F-2 of 2 June 2014