Document 5Lm83ZLjEODZVVo4j8kJJa0x8

STATER U.S. ENVIRONMENTAL PROTECTION AGENCY ENVIRONNELIGENCE SPCC FIELD ITNISERP EI CQTUIALOINFI EADN FDA CPILLIATINE SR EVIEW CHECKLIST 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 Tier I Qualified Facilities that meet the eligibility criteria set forth in 112.3 (g) (1). Separate and standalone checklists address the requirements for: Onshore facilities including Tier II Qualified Facilities (excluding oil drilling, production and workover facilities); Onshore oil drilling, production and workover facilities including Tier II Qualified Facilities as defined in 112.3 (g) (2); and Offshore drilling, production and workover facilities Tier I Qualified Facilities must meet the rule requirements in 112.6 and other applicable sections specified in 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 Tier I qualified facilities. Section 112.7 includes general requirements that apply to all facilities (unless otherwise excluded). Attachments Attachment A is a checklist for Sections 112.8 and 112.12. This checklist specifies requirements for spill prevention, control, and countermeasures for onshore facilities (excluding oil production facilities). Attachment B is a checklist that specifies requirements for spill prevention, control, and countermeasures for onshore oil production facilities (112.9 provisions) and onshore drilling and workover facilities (112.10 provisions) Attachment C is for recording information about containers and other locations at the facility that require. secondary containment. Attachment D is a checklist for documenting the tests and inspections the facility operator is required to keep with the SPCC Plan. Attachment E 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 the owner or operator of a facility with qualified oil - filled operational equipment chooses to implement alternative requirements instead of general secondary containment requirements as provided in 40 CFR 112.7 (k). Attachment F is for recording additional comments or notes. Attachment G is for recording information about photos. The inspector needs to evaluate whether the requirements in the checklist are 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 F at the end of the checklist. Comments should remain factual and support the evaluation of compliance. Tier I Qualified FacilitiesPage 1 of 8June 2014 ED_019088A_00004858-00001 FACILITY INFORMATION FACILITY NAME: Attleboro WPCF LATITUDE:LONGITUDE:GPS DATUM: Section / Township / Range:FRS # / OIL DATABASE ID:ICIS #: ADDRESS: 27 Pond Street North CITY: AttleboroSTATE: MAZIP: 02703COUNTY: MAILING ADDRESS (IF DIFFERENT FROM FACILITY ADDRESS - IF NOT, PRINT " SAME "): CITY:STATE:ZIP:COUNTY: TELEPHONE:FACILITY CONTACT NAME / TITLE: OWNER NAME: OWNER ADDRESS: CITY:STATE:ZIP:COUNTY: TELEPHONE: FAX: EMAIL: FACILITY OPERATOR NAME (IF DIFFERENT FROM OWNER - IF NOT, PRINT " SAME "): Same OPERATOR ADDRESS: CITY:STATE:ZIP:COUNTY: TELEPHONE:OPERATOR CONTACT NAME / TITLE: FACILITY TYPE:NAICS CODE: HOURS PER DAY FACILITY ATTENDED:TOTAL FACILITY CAPACITY: TYPE(S) OF OIL STORED: LOCATED IN INDIAN COUNTRY? YES NO RESERVATION NAME: INSPECTION / PLAN REVIEW INFORMATION PLAN REVIEW DATE: 10/3/23REVIEWER NAME: David Turin INSPECTION DATE: 9/27/23TIME:ACTIVITY ID NO: SPCC - MA - 2023-00010 LEAD INSPECTOR: David Turin OTHER INSPECTOR(S): INSPECTION ACKNOWLEDGMENT I performed an SPCC inspection at the facility specified above. INSPECTOR SIGNATURE: DAVID TURIN Digitally signDeatde: 2b02y3. 1D1.A20V 1I6:D55 :4T6 U-0R5'I00N ' DATE: SUPERVISOR REVIEW / SIGNATURE:DATE: Tier / Qualified FacilitiesPage 2 of 8June 2014 ED_019088A_00004858-00002 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 AFFECTED WATERWAY(S): Ten Mile River FLOW PATH TO WATERWAY: Overland, MS4 outfalls and NPDES outfall DISTANCE: 600 yards Yes No 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) Completely buried tanks subject to all the technical requirements of 40 CFR part 280 or a state program approved under 40 CFR part 281; 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; 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? SPCC TIER I QUALIFIED FACILITY APPLICABILITY-40 CFR 112.3 (g) (1), (2) Yes No The aggregate aboveground oil storage capacity is 10,000 U.S. gallons or less AND The capacity of each individual aboveground oil storage container is 5,000 U.S. gallons or less AND 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: Yes No Yes::: _: _: A single discharge as described in 112.1 (b) exceeding 1,000 U.S. gallons, OR * Twpeor idodisc harges as described in 112.1 (b) each exceeding 42 U.S. gallons within any twelve - month Yes No Yes No IF YES TO ALL OF THE ABOVE, THEN THE FACILITY IS CONSIDERED A TIER I QUALIFIED FACILITY. Comments: 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 I SPCC Plan may not include any environmentally equivalent alternatives or secondary containment impracticability determinations in the SPCC Plan Tier I Qualified Facilities Page 3 of 8 June 2014 ED_019088A_00004858-00003 REQUIREMENTS FOR PREPARATION AND IMPLEMENTATION OF A SPCC PLAN-40 CFR 112.3 Date facility began operations: 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 fullyYes implemented by November 10, 2011 Facilities beginning operation after November 10, 2011: Oil production facilities - Plan prepared and fully implemented within six monthsYes NoNA after beginning operations; or All other facilities - Plan prepared and fully implemented before operations beginYes NoNA For farms (as defined in 112.2): In operation on or prior to August 16, 2002: Plan maintained, amended andYes NoNA implemented by May 10, 2013 Beginning operations after August 16, 2002 through May 10, 2013: Plan prepared andNA fully implemented by May 10, 2013 Beginning operations after May 10, 2013: Plan prepared and fully implemented beforeYes No NA beginning operations 112.3 (e) (1) Plan is available onsite if attended at least 4 hours per day. If facility is unattended, Plan isYesNoNA available at the nearest field office. (Please note nearest field office contact information in comments section below.) Comments: 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 reportableYes No discharge or more than 42 U.S. gallons in each of two reportable discharges in any 12-month period? If YES* Was information submitted to the RA as required in 112.4 (a)? 4YesNoNA * 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) Yes HK Ko NA Date(s) and volume(s) of reportable discharges(s) under this section: * Were the discharges reported to the NRC?Yes No 112.4 (d), (e) Have changes required by the RA been implemented in the Plan and / or facility?YesNos, Comments: No information regarding previous spills is included in the SPCC plan. This inspector is not aware of any spills. 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 Tier I Qualified FacilitiesPage 4 of 8June 2014 ED_019088A_00004858-00004 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 dischargeYes No described in $ 112.1 (b)? If YES * Was the Plan amended within six months of the change?YesNo Were amendments implemented within six months of any Plan amendment?YesNo 112.5 (b) Review and evaluation of the Plan completed at least once every 5 years?Yes 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 O Yes ONO No ONA g likelihood of a discharge described in 112.1 (b)? Amendments implemented within six months of any Plan amendment?Yes K KOK NA Five year Plan review and evaluation documented?YesNos, 112.5 (c) Professional Engineer certification of any technical Plan amendments in accordance with allYesNo:NA applicable requirements of $ 112.3 (d) [Except for self - certified Plans] Name: John HoarLicense No.: 33344State: MADate of certification: Reason for amendment: The 2019 amendments did not comply with the requirement to review and update the plan every 5-years; however, the update did include the 4000 gal fuel tank added at the landfill in 2017. Inspector did not get copy of signed PE page. TIER I QUALIFIED FACILITY PLAN REQUIREMENTS -40 CFR 112.6 (a) 112.6 (a) (1) APplpaenn Cdeirxt iGf itceatmipolna:t eP lan prepared to comply with the requirements of $ 112.6 (a) (3) using the OC Yes D CHECK COCK: C CHECK NA (i) He or she is familiar with the requirements of 40 CFR part 112 YesNoNA (ii) He or she has visited and examined the facilityYesNoNA (iii) stTahned aPrdlsa n has been prepared in accordance with accepted and sound industry practices andYesNoNA (iv) Procedures for required inspections and testing have been establishedYesNoNA (v) He or she will fully implement the PlanYesNoNA (vi) The facility meets the qualification criteria in 112.3 (g) (1)Yes No NA (vii) The Plan does not deviate from any requirements as allowed by 112.7 (a) (2) and 112.7 (d), or include measures pursuant to 112.9 (c) (6) for produced water containers and anyCTEK KYK: _:: _:: C CHECK COCKER NA associated piping (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 toYes CK COCK CHECK NA fully implement the Plan. 112.6 (a) (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 Yes No NA for a $ 112.1 (b) discharge If YES* Certification of technical amendments is in accordance with the self - certification provisions of $ 112.6 (a) (1). TECHECK KYK: _:: _ KCHECKCHECK COKE: NA An individual oil storage container capacity exceeds 5,000 U.S. gallons or the aggregate aboveground oil storage capacity increased to more than 10,000 U.S. gallons as a result ofYK:::: No: NA the change If YESThe facility no longer meets the Tier I qualifying criteria in 112.3 (g) (1) because an individual oil storage container capacity exceeds 5,000 U.S. gallons or the facility aboveground storage capacity exceeds 10,000 U.S. gallons The following has been or will be completed within six months following the amendment: * Plan prepared and implemented in accordance with the requirements for a Tier II: Yes NoNA (i)Qualified Facility (112.6 (b)) if the facility meets the eligibility criteria OR (ii)* Plan prepared and implemented in accordance with the general Plan requirements in 112.7 and applicable requirements in subparts B and C and certified by a PE asYes No NA required under $ 112.3 (d) 6 Note that only the person certifying the Plan can make the site visit Tier I Qualified FacilitiesPage 5 of 8June 2014 ED_019088A_00004858-00005 112.6 (a) (3) (i) Plan includes a prediction of the direction and total quantity of oil which could be discharged from the facility as a result of each type of major equipment failure if there is a reasonable potential for equipment failure (such as loading or unloading equipment, tank overflow, rupture, or leakage, or any other equipment known to be a source of discharge) (ii) Bulk storage container installations (except mobile refuelers and other non - transportation- related tank trucks), including mobile or portable oil storage containers, are constructed to provide secondary containment for the entire capacity of the largest single container plus additional capacity to contain precipitation, and Yes No NA dMiosbcihlareg eo r portable oil storage containers positioned or located to prevent a 112.1 (b)KESK: NC:::: NA (iii) Plan describes a system or documented procedure to prevent overfills for each container and is regularly tested to ensure proper operation or efficacy Yes No NA Comments: The PE signature page does not include the statements referenced in 112.6 (a) 1) GENERAL SPCC REQUIREMENTS-40 CFR 112.7PLANFIELD fMualnlay giemmpleenmte nta ptphre oPvlaaln 'a t a level of authority to commit the necessary resources toYes No Plan follows sequence of the rule or is an equivalent Plan meeting all applicableYes No NA rule requirements and includes a cross - reference of provisions R: F 1F F - - - - - - - - - - - - F F F F If Plan calls for facilities, procedures, methods, or equipment not yet fully operational, details of their installation and start - up are discussed (Note: RelevantYes @)No ONA for inspection evaluation and testing baselines.) 112.7 (a) (3) Plan addresses each of the following: (i) For each fixed container, type of oil and storage capacity (seeYes No> Yes No Attachment C 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 (iv) Countermeasures for discharge discovery, response, and cleanupYes NoYes No (both facility's and contractor's resources) (vi) Contact list and phone numbers for the facility responseYes No 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) 112.7 (a) (4) Plan includes information and procedures that enable a personYes No NA reporting an oil discharge as described in 112.1 (b) to relate information on the: Exact address or location and phone* A description of all affected media; number of the facility;* Cause of the discharge; Date and time of the discharge;* Damages or injuries caused by the * Type of material discharged;discharge; Estimates of the total quantity discharged;* Actions being used to stop, remove, and * Estimates of the quantity discharged asmitigate the effects of the discharge; described in 112.1 (b);* Whether an evacuation may be needed; * Source of the discharge;* Names of individuals and / or organizations who have also been contacted * 112.7 (a) (5) Plan organized so that portions describing procedures to be usedYes No NA when a discharge occurs will be readily usable in an emergency Comments: Plan is substantially complete but does not seem to contain every element contained in the rule, such as a statement regarding spill history. 7 May be part of the Plan or demonstrated elsewhere. Tier I Qualified FacilitiesPage 6 of 8June 2014 ED_019088A_00004858-00006 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 and 112.9 (d) (3) for certain flowlines and intra - facility gathering lines at an oil production facility. 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 C of this checklist. For onshore facilities, one of the following or its equivalent: * Dikes, berms, or retaining walls sufficientlyWeirs, booms or other barriers, impervious to contain oil,Spill diversion ponds, * Curbing or drip pans,* Retention ponds, or * Sumps and collection systems,Sorbent materials * Culverting, gutters or other drainage systems, 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 Mobile / portable containersYes No NA Yes No NA Oil - filled operational equipment (as defined in 112.2) Yes:::::::: TECTED NA HTC KYK: _: _:: CHECK KNO: NA Otheroil - 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 activitiesYes No NA Yes: No CHECK NEKA Identify any other equipment or activities that are not listedYes No NA H KYK:::::::: No CHECK _: _ _: _ above: 112.7 (e) Inspections and tests conducted in accordance with writtenYes NoYes No procedures Record of inspections or tests signed by supervisor or inspectorYes NoYes No cKheecpkltis t)w 8i th Plan for at least 3 years (see Attachment D of thisYesNoYesNo 112.7 (f) Personnel, training, and oil discharge prevention procedures (1) Training of oil - handling personnel in operation and maintenance ofYes No NAYes No NA 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 Y::: No: NA HTC Y::::: CHECK: No NA facility and reports to facility management (3) Discharge prevention briefings conducted at least once a year forYes No NAYes No NA 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 Comments: A portable pump without required secondary containment was observed adjacent to a storm water inlet; its removal was documented with photos shortly after the inspection. 8 Records of inspections and tests kept under usual and customary business practices will suffice Tier I Qualified FacilitiesPage 7 of 8June 2014 ED_019088A_00004858-00007 PLAN FIELD 112.7 (g) Plan describes how to:Yes TDNOTNA::::: D: D: D D: D:: D DNA: Secure and control access to the oil handling, processing and storage areas;For Oil Production Facilities: Secure master flow and drain valves;Select NA 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 112.7 (k) Qualified oil - filled operational equipment is present at the facility 9YesNo 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. If YES Check which apply: Secondary Containment provided in accordance with 112.7 (c) Alternative measure described below (confirm eligibility) 112.7 (k) Qualified Oil - Filled Operational Equipment Has a single reportable discharge as described in 112.1 (b) from any oil - filledYes NoNA 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 operationalYes NoNA equipment each exceeding 42 U.S. gallons occurred within any 12-month period within the three years prior to Plan certification date? 10 If YES for either, secondary containment in accordance with $ 112.7 (c) is required Comments: Facility procedure for inspections or monitoring program toYes NO NA CHECKYKKES: CHECKEDNO NA 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 Yes No NA E of this checklist) is provided in Plan AND Written commitment of manpower, equipment, and materialsYes No NA required to expeditiously control and remove any quantity of oil discharged that may be harmful is provided in Plan This Inspector is not aware of reported spills; the SPCC plan does not appear to contain a statement regarding its spill history. Inspector Note- Complete, as applicable, either Attachment A or B which include additional requirements based on the type of facility. 9 This provision does not apply to oil - filled manufacturing equipment (flow - through process) 10 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. Tier I Qualified FacilitiesPage 8 of 8June 2014 ED_019088A_00004858-00008 ATTACHMENT ANA PLAN FIELD ONSHORE FACILITIES (EXCLUDING PRODUCTION) 40 CFR 112.8 / 112.12 112.8 (b) / 112.12 (b) Facility Drainage Diked Areas Drainage from diked storage areas is:Yes No INAYes No NA (1)* 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 Comments: 112.8 (c) /112.12 (c) Bulk Storage ContainersNA 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 C of this checklist. (1) Containers materials and construction are compatible withYes No NA CK YES: CHECKCENCE: KM: CHCEC NA material stored and conditions of storage such as pressure and temperature (3) Isi nttoh ear es tdorrami dnraagien oofr uonpecno nwtaatmeirncaoturesde ?r ainwater from diked areasO Yes No NA Yes D: D: D: D: D:: D:: DICE_A_A_A If YES Bypass valve normally sealed closed1 Yes No NA Yes No NA Retained rainwater is inspected to ensure that its presenceYes NoNAYesNoNA will not cause a discharge as described in $ 112.1 (b) Bypass valve opened and resealed under responsibleYes NO NA H KYK::::: CHECK NO: NA supervision Adequate records of drainage are kept; for example, records Yes TCHECK: KEKECOCKCHECK CACHECKCHECK YES:: D: D: D: D D:: D DIN_A_A required under permits issued in accordance with 40 CFR 122.41 (j) (2) and (m) (3) (4) 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 cathodicYes No NAYes NoNA protection compatible with local soil conditions Regular leak testing conductedYes NoYes (5) The buried section of partially buried or bunkered metallic tanksYes No NAYes NoNA s, protected from corrosion with coatings or cathodic protection compatible with local soil conditions Comments: Tier I Qualified FacilitiesPage A-1 of 2June 2014 ED_019088A_00004858-00009 ATTACHMENT APLAN FIELD (6)Test or inspect each aboveground container for integrity on aYes No NA:::: CHECHECKCOM: CHEC NA 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 andYes No NAYes NoNA inspections are identified in the Plan and have been assessed in accordance with industry standards * The frequency and type of testing and inspections areYes No NAYes No NA documented, are in accordance with industry standards and take into account the container size, configuration and design * Comparison records of aboveground container integrityYes No NA TECKY:::: CHECHECK NO: NA testing are maintained * Container supports and foundations regularly inspectedYes No NAYes NoNA * Outside of containers frequently inspected for signs ofYes No NAYes No NA deterioration, discharges, or accumulation of oil inside diked areas * Records of all inspections and tests maintained 11Yes No NA KYK:::::: No NA Integrity Testing Standard identified in the Plan: 112.12 Conduct formal visual inspection on a regular schedule for bulkYesNoNAYesNoNA (c) (6) (ii) storage containers that meet all of the following conditions: (Applies toSubject to 21 CFR part 110;* Have no external insulation; and AFVO Facilities only) Elevated;* Shop - fabricated. Constructed of austenitic stainless steel; In addition, you must frequently inspect the outside of the containerYesNoNAYesNo NA for signs of deterioration, discharges, or accumulation of oil inside. diked areas. You must determine and document in the Pl1a1 n the appropriateYes NoNAYesNoNA qualifications for personnel performing tests and inspections. (10) Visible discharges which result in a loss of oil from the container,T K KECK THE COCKE NAY::::::: No NA including but not limited to seams, gaskets, piping, pumps, valves, rivets, and bolts are promptly corrected and oil in diked areas is promptly removed 112.8 (d) /112.12 (d) Facility transfer operations, pumping, and facility process (4) Aboveground valves, piping, and appurtenances such as flangeYes No NA Yes:: No NA 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 ofYes No NA Yes No NA installation, modification, construction, relocation, or replacement Comments: 11 Records of inspections and tests kept under usual and customary business practices will suffice Tier I Qualified FacilitiesPage A-2 of 2June 2014 ED_019088A_00004858-00010 ATTACHMENT BNA PLAN FIELD ONSHORE OIL PRODUCTION FACILITIES-40 CFR 112.9 (Drilling and workover facilities are excluded from the requirements of 112.9) Production facility means all structures (including but not limited to wells, platforms, or storage facilities), piping (including but not limited to flowlines or intra - facility gathering lines), or equipment (including but not limited to workover equipment, separation equipment, or auxiliary non - transportation- related equipment) used in the production, extraction, recovery, lifting, stabilization, separation or treating of oil (including condensate), or associated storage or measurement, and is located in an oil or gas field, at a facility. This definition governs whether such structures, piping, or equipment are subject to a specific section of this part. 112.9 (b) Oil Production Facility Drainage (1) At tank batteries, separation and treating areas where there is aYes: No: NAYes No NA reasonable possibility of a discharge as described in 112.1 (b), drains for dikes or equivalent measures are closed and sealed except when draining uncontaminated rainwater. Accumulated oil on the rainwater is removed and then returned to storage or disposed of in accordance with legally approved methods Prior to drainage, diked area inspected and action taken as provided below: 112.8 (c) (3) (ii) - Retained rainwater is inspected to ensure thatYes No NA Yes No NA its presence will not cause a discharge as described in 112.1 (b) 112.8 (c) (3) (iii) - Bypass valve opened and resealed underTTC YES: THE COCK: TEDNA Y:::::::::: NA responsible supervision 112.8 (c) (3) (iv) - Adequate records of drainage are kept; forYes No NAYesNoNA example, records required under permits issued in accordance with $ 122.41 (j) (2) and (m) (3) (2) Field drainage systems (e.g., drainage ditches or road ditches) and Yes No NA Yes No NA oil traps, sumps, or skimmers inspected at regularly scheduled intervals for oil, and accumulations of oil promptly removed 112.9 (c) Oil Production Facility Bulk Storage Containers 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. (1) Containers materials and construction are compatible with materialYes No: NAYes No NA stored and conditions of storage such as pressure and temperature (2) Except as allowed for flow - through process vessels in 112.9 (c) (5)Yes T CHECK COCKCHECKCK_KAT NA Y Yes::::: CHECHERCHECK No: D: D: D DNA: and produced water containers in 112.9 (c) (6), secondary containment provided for all tank battery, separation and treating facilities sized to hold the capacity of largest single container and sufficient freeboard for precipitation. Drainage from undiked area safely confined in a catchment basinYesNoYesNoNA or holding pond. (3) Except as allowed for flow - through process vessels in 112.9 (c) (5)Yes: NC::: NAYes No NA and produced water containers in 112.9 (c) (6), periodically and upon a regular schedule, visually inspect containers for deterioration and maintenance needs, including foundation and supports of each container on or above the surface of the ground (4) New and old tank batteries engineered / updated in accordance withYesNoNA good engineering practices to prevent discharges including at least one of the following: * Adequate container capacity to prevent overfill if a* Adequate vacuum protection to prevent container collapse; or pumper / gauger is delayed in making regularly scheduled* High level sensors to generate and transmit an alarm to the rounds; computer where the facility is subject to a computer production * Overflow equalizing lines between containers so that acontrol system full container can overflow to an adjacent container; Comments: Tier I Qualified FacilitiesPage B-1 of 4June 2014 ED_019088A_00004858-00011 ATTACHMENT BPLAN FIELD (5) Flow - through Process Vessels. Alternate requirements in lieu of sized secondary containment required in (c) (2) and requirements in (c) (3) above for facilities with flow - through process vessels: (i) Flow - through process vessels and associated components (e.g.Yes No NAYes No NA dump valves) are periodically and on a regular schedule visually inspected and / or tested for leaks, corrosion, or other conditions that could lead to a discharge as described in 112.1 (b) (ii) Corrective actions or repairs have been made to flow - throughYes No NAYes NoNA process vessels and any associated components as indicated by regularly scheduled visual inspections, tests, or evidence of an oil discharge (iii) Oil removed or other actions initiated to promptly stabilize andYes No NAYes No NA remediate any accumulation of oil discharges associated with the produced water container (iv) All flow - through process vessels comply with 112.9 (c) (2) andYes No NAYes NoNA (c) (3) within six months of any flow - through process vessel discharge of more than 1,000 U.S. gallons of oil in a single discharge as described in $ 112.1 (b) or discharges of more than 42 U.S. gallons of oil in each of two discharges as described in $ 112.1 (b) within any twelve month period. 12 112.9 (d) Facility transfer operations, pumping, and facility process (1) All aboveground valves and piping associated with transferYes No NAYes NoNA operations are inspected periodically and upon a regular schedule to determine their general condition. Include the general condition of flange joints, valve glands and bodies, drip pans, pipe supports, pumping well polish rod stuffing boxes, bleeder and gauge valves, and other such items (3) If flowlines and intra - facility gathering lines are not provided with secondary containment in accordance with $ 112.7 (c) and the facility is not required to submit an FRP under $ 112.20, then the SPCC Plan includes: (i)An oil spill contingency plan following the provisions of 40 CFR Yes NO NA OCH YES: CHECKERED: D: D: D:: D: DCECHECK NAT part 10913 (ii)A written commitment of manpower, equipment, and materialsYes No NAYes NoNA required to expeditiously control and remove any quantity of oil discharged that might be harmful Comments: 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. 13 Note that the implementation of a 40 CFR part 109 plan does not require a PE impracticability determination for this specific requirement Tier I Qualified FacilitiesPage B-2 of 4June 2014 ED_019088A_00004858-00012 ATTACHMENT BPLAN FIELD (4) A flowline / intra - facility gathering line maintenance program to prevent discharges is prepared and implemented and includes the following procedures: (i) Flowlines and intra - facility gathering lines and associated valvesTTC YK::: CHECK CHECK: NA Yes NoNA and equipment are compatible with the type of production fluids, their potential corrosivity, volume, and pressure, and other conditions expected in the operational environment (ii) Flowlines and intra - facility gathering lines and associatedYes No NA Yes NoNA appurtenances are visually inspected and / or tested on a periodic and regular schedule for leaks, oil discharges, corrosion, or other conditions that could lead to a discharge as described in 112.1 (b). If flowlines and intra - facility gathering lines are not provided withYes No NA Yes NoNA secondary containment in accordance with 112.7 (c), the frequency and type of testing allows for the implementation of a contingency plan as described under 40 CFR 109 or an FRP submitted under $ 112.20 (iii) Repairs or other corrective actions are made to any flowlines andYes No NAYes CC: NoNA intra - facility gathering lines and associated appurtenances as indicated by regularly scheduled visual inspections, tests, or evidence of a discharge (iv) Oil removed or other actions initiated to promptly stabilize andYes No NAYes NoNA remediate any accumulation of oil discharges associated with the produced water containers ATTACHMENT BNA PLAN FIELD ONSHORE OIL DRILLING AND WORKOVER FACILITIES-40 CFR 112.10 112.10 (b) Mobile drilling or workover equipment is positioned or located toYes No NAYes:: NoNA prevent a discharge as described in 112.1 (b) 112.10 (ca)n d Ccaonttcaihnm deisnctha rbgeass oifn fsue lo, rc ruddie voeilr, soir oonil ys dtrrilulicntg ufrlueisds are provided to interceptYes No NANo NA 112.10 (d) Blowout prevention (BOP) assembly and well control systemYes No NA Yes NoNA installed before drilling below any casing string or during workover operations BOP assembly and well control system is capable of controllingYes No NA Yes NoNA any well - head pressure that may be encountered while on the well Comments: Tier I Qualified FacilitiesPage B-3 of 4June 2014 ED_019088A_00004858-00013 This page left intentionally blank. Tier I Qualified Facilities Page B-4 of 4 June 2014 ED_019088A_00004858-00014 ATTACHMENT C: 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). Note that appropriate evaluation and consideration must be given to the any use of active measures at an unmanned production facility. Container ID / General Condition 14 Aboveground or Buried Tank Storage Capacity and Type Type of Containment / Overfill Protection and of Oil Drainage Control Testing & Inspections 14 Identify each tank with either an A to indicate aboveground or B for completely buried Tier I Qualified Facilities Page C-1 of 2 June 2014 ED_019088A_00004858-00015 ATTACHMENT C: SPCC FIELD INSPECTION AND PLAN REVIEW TABLE (CONT.) Documentation of Field Observations for Containers and Associated Requirements Container ID / General Condition 15Storage Capacity and TypeType of Containment /Overfill Protection and Aboveground or Buried Tank of OilDrainage ControlTesting & Inspections 15 Identify each tank with either an A to indicate aboveground or B for completely buried Tier I Qualified FacilitiesPage C-2 of 2June 2014 ED_019088A_00004858-00016 ATTACHMENT D: 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 Not Present Not Applicable Present 112.6-Tier I Qualified Facilities (a) (3) (iii) Regular testing of system or documented procedures used instead of liquid level sensing devices specified in 112.8 (c) (8) and 112.12 (c) (8) to prevent container overfills 112.7-General SPCC Requirements 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)NA (b) (1), Inspection of storm water released from diked areas into facility drainage directly to a (b) (2) 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 January 10, 1974 and regulated under 40 CFR 112 (c) (4) Regular leak testing of completely buried metallic storage tanks installed on or after000 (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 and (c) (10) foundations (d) (4) Regular inspections of aboveground valves, piping and appurtenances and assessments (c) (of6 t)he gFenreeraql ucoendnitti oni onf sflpaengce tjoiinotsn,s e xpoanfsi ond ijokinetsd, vaalrvee galasnd sf aondr b odaiecsc, ucamtcuh lations of oil000 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 112.9-Onshore Oil Production Facilities (excluding drilling and workover facilities)NA (b) (1) Rainwater released directly from diked containment areas inspected following 112.8 (c) (3) (ii), (iii) and (iv), including records of drainage kept (b) (2) Field drainage systems, oil traps, sumps, and skimmers inspected regularly for oil, and accumulations of oil promptly removed (c) (3) Containers, foundations and supports inspected visually for deterioration and maintenance needs (c) (5) (i) In lieu of having sized secondary containment, flow - through process vessels and associated components visually inspected and / or tested periodically and on a regular schedule for conditions that could result in a discharge as described in 112.1 (b) (d) (1) All aboveground valves and piping associated with transfers are regularly inspected (d) (4) (ii) For flowlines and intra - facility gathering lines without secondary containment, in accordance with 112.7 (c), lines are visually inspected and / or tested periodically and on a regular schedule to allow implementing the part 109 contingency plan or the FRP submitted under $ 112.20 Tier I Qualified FacilitiesPage D-1 of 2June 2014 ED_019088A_00004858-00017 This page left intentionally blank. Tier I Qualified Facilities Page D-2 of 2 June 2014 ED_019088A_00004858-00018 ATTACHMENT E: SPCC CONTINGENCY PLAN REVIEW CHECKLISTNA 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). 16 109.5-Development and implementation criteria for State, local and regional oil removal contingency plans '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. OO 000 (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. 16 The contingency plan should be consistent with all applicable state and local plans, Area Contingency Plans, and the NCP. Tier I Qualified FacilitiesPage E-1 of 2June 2014 ED_019088A_00004858-00019 This page left intentionally blank. Tier / Qualified Facilities Page E-2 of 2 June 2014 ED_019088A_00004858-00020 ATTACHMENT F: ADDITIONAL COMMENTS Tier I Qualified Facilities Page F-1 of 2 June 2014 ED_019088A_00004858-00021 ATTACHMENT F: ADDITIONAL COMMENTS (CONT.) Tier I Qualified Facilities Page F-2 of 2 June 2014 ED_019088A_00004858-00022 ATTACHMENT G: PHOTO DOCUMENTATION NOTES Photo # Photographer Time of Compass Description Name Photo Taken Direction Tier I Qualified Facilities Page G-1 of 2 June 2014 ED_019088A_00004858-00023 ATTACHMENT G: PHOTO DOCUMENTATION NOTES (CONT.) Photo # Photographer Time of Compass Description Name Photo Taken Direction Tier I Qualified Facilities Page G-2 of 2 June 2014 ED_019088A_00004858-00024