Document MMrEDr1q13jvrwY4jxvRe5MqL

U.S. ENVIRONMENTAL PROTECTION AGENCY SPCC FIELD INSPECTION AND PLAN REVIEW CHECKLIST PROT 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 ED_019088A_00004068-00001 FACILITY INFORMATION FACILITY NAME: Beverly Port Marina LATITUDE: 42.541099 NLONGITUDE: -70.883623 WGPS DATUM: N / A Section / Township / Range: N / AFRS # / OIL DATABASE ID: R1-MA-00342ICIS #: 1000000506 ADDRESS: 43 Water Street CITY: BeverlySTATE: MAZIP: 01915COUNTY: Essex MAILING ADDRESS (IF DIFFERENT FROM FACILITY ADDRESS - IF NOT, PRINT " SAME "): Same CITY: SameSTATE: SameZIP: SameCOUNTY: Same TELEPHONE: (978) 232-3300FACILITY CONTACT NAME / TITLE: Frank Kinzie III, Owner / Manager OWNER NAME: Frank and Suzanne Kinzie OWNER ADDRESS: Same CITY: SameSTATE: SameZIP: SameCOUNTY: Same TELEPHONE: (978) 232-3300FAX: (978) 232-3329EMAIL: frank@beverlyportmarina.com FACILITY OPERATOR NAME (IF DIFFERENT FROM OWNER - IF NOT, PRINT " SAME "): Same OPERATOR ADDRESS: Same CITY: SameSTATE: SameZIP: SameCOUNTY: Same TELEPHONE: (978) 232-3300OPERATOR CONTACT NAME / TITLE: frank@beverlyportmarina.com FACILITY TYPE: MarinaNAICS CODE: 713930 HOURS PER DAY FACILITY ATTENDED: 8-10TOTAL FACILITY CAPACITY: - 15,000 TYPE(S) OF OIL STORED: Diesel, Gasoline, Motor Oils, Lubrication Oils LOCATED IN INDIAN COUNTRY? YES NO RESERVATION NAME: INSPECTION / PLAN REVIEW INFORMATION PLAN REVIEW DATE: 9/2/2024REVIEWER NAME: Damian Bednarz INSPECTION DATE: 8/20/2024TIME: 0900-1630ACTIVITY ID NO: N / A LEAD INSPECTOR: Damian Bednarz OTHER INSPECTOR(S): Newton Tedder, Margarita Chatterton, Joseph Canzano INSPECTION ACKNOWLEDGMENT I performed an SPCC inspection at the facility specified above. DAMIAN Digitally signed by DAMIAN BEDNARZ INSPECTOR SIGNATURED: ate: 2 024.1D 0.15 1A 5:59:T 19 E: 10/9/2024 BEDNARZ -04'00 ' Digitally signed by JOSEPH SUPERVISOR REVIEW / SIGNATURE: JOSEPH CANZANO CANZANODATE: 10/15/2024 Date: 2024.10.15 14:00:24 -04'00 ' Onshore Facilities (Excluding Oil Production)Page 2 of 14June 2014 ED_019088A_00004068-00002 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 Yes No Yes No AFFECTED WATERWAY(S): Beverly Harbor FLOW PATH TO WATERWAY: DISTANCE: 10 feet From source to storm water drain which discharges to surface waters. Facility owns 6 storm water outfalls to Beverly Harbor. Additionally, multiple fuel lines from the Facility's largest bulk storage containers operate near and over the harbor for the purpose of boat refueling by dispenser pump. 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: Onshore Facilities (Excluding Oil Production) Page 3 of 14 June 2014 ED_019088A_00004068-00003 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 ANDYesNo 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, ORYesNo * Two discharges as described in 112.1 (b) each exceeding 42 U.S. gallons within any twelve - month periodYesNo IF YES TO ALL OF THE ABOVE, THEN THE FACILITY IS A TIER II QUALIFIED FACILITY 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: Unknown, but prior to November 10. 2011 Date of initial SPCC Plan preparation: UnknownCurrent Plan version (date / number): January 2019 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 No NA implemented by November 10, 2011 Beginning operations after November 10, 2011, Plan prepared and fully implementedYes No NA before beginning operations For farms (as defined in 112.2): In operation on or prior to August 16, 2002: Plan maintained, amended andYes No NA implemented by May 10, 2013 * Beginning operations after August 16, 2002 through May 10, 2013: Plan prepared andYes No NA fully implemented by May 10, 2013 * Beginning operations after May 10, 2013: Plan prepared and fully implemented beforeYes No NA beginning operations 112.3 (d) Plan is certified by a registered Professional Engineer (PE) and includes statements that theYes No NA PE attests: * PE is familiar with the requirements of 40 CFR part 112YesNoNA * PE or agent has visited and examined the facilityYesNoNA Plan is prepared in accordance with good engineering practice including considerationYes No NA of applicable industry standards and the requirements of 40 CFR part 112 * Procedures for required inspections and testing have been establishedYesNoNA * Plan is adequate for the facilityYes No NA PE Name: Robert H. GriffinLicense No.: 36686State: MADate of certification: January 7. 2019 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: 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 14June 2014 ED_019088A_00004068-00004 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 dischargeYes No 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)? 4Yes No NA * Was information submitted to the appropriate agency or agencies in charge of oilYesNoNA 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?Yes No 112.4 (d), (e) Have changes required by the RA been implemented in the Plan and / or facility?Yes No NA Comments: 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 dischargeYesNo 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?YesNoNA Following Plan review, was Plan amended within six months to include more effectiveYesNoNA 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?YesNoNA Five year Plan review and evaluation documented?YesNoNA 112.5 (c) Professional Engineer certification of any technical Plan amendments in accordance with allYesNoNA applicable requirements of $ 112.3 (d) [Except for self - certified Plans] Name:License No.:State:Date of certification: Reason for amendment: Comments: SPCC Plan Coordinator Jonathan Silver is no longer working at the Beverly Port Marina Facility. This change may affect the facility's operation or maintenance that materially affects the facility's potential for a discharge as described in 112.1 (b), the SPCC Plan must be amended within six months and any technical amendments must be certified by a PE (40 CFR 112.5). In addition, last plan implementation was January 2019, meaning a review and evaluation of the Plan was due January 2024. No review of the Plan was conducted until at least August of 2024. The Facility intends to remove a 300 gal heating oil container but has not done so since at least the date of the inspection. This will require an amendment to the Plan. The waste oil storage container was not Permanently Closed as defined in 112.2, and as such, is still included in the total storage capacity of the site in its 2019 Plan. The removal of this tank requires amendment to the Plan. 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 14June 2014 ED_019088A_00004068-00005 GENERAL SPCC REQUIREMENTS-40 CFR 112.7PLANFIELD Management approval at a level of authority to commit the necessary resources toYesNo fully implement the Plan 6 Plan follows sequence of the rule or is an equivalent Plan meeting all applicable ruleYesNoNA requirements and includes a cross - reference of provisions If Plan calls for facilities, procedures, methods, or equipment not yet fully operational,Yes No NASo we do to details of their installation and start - up are discussed (Note: Relevant for inspection evaluation and testing baselines.) 112.7 (a) (2) The Plan includes deviations from the requirements of 112.7 (g),Yes No NA (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) If YES* The Plan states reasons for nonconformanceYesNoNA * Alternative measures described in detail and provide equivalent Yes No NA Yes No NA environmental protection (Note: Inspector should document if the environmental equivalence is implemented in the field, in accordance with the Plan's description) Describe each deviation and reasons for nonconformance: The Plan does not have the full approval of management at a level of authority to commit the necessary resources to fully implement the Plan, as described in 112.7. The Plan is not signed by management. 6 May be part of the Plan or demonstrated elsewhere. Onshore Facilities (Excluding Oil Production)Page 6 of 14June 2014 ED_019088A_00004068-00006 PLAN FIELD 7 112.7 (a) (3) Plan describes physical layout of facility and includes a diagramYesNoYesNo 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: (i) For each fixed container, type of oil and storage capacity (seeYes NoYesNo 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 (ii) Discharge prevention measures, including procedures for routineYesNoYesNo handling of products (loading, unloading, and facility transfers, etc.) (iii) Discharge or drainage controls, such as secondary containmentYesNoYesNo around containers, and other structures, equipment, and procedures for the control of a discharge (iv) Countermeasures for discharge discovery, response, and cleanupYesNoYesNo (both facility's and contractor's resources) (v) Methods of disposal of recovered materials in accordance withYesNo applicable legal requirements (vi) Contact list and phone numbers for the facility response coordinator,Yes No 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) Does not apply if the facility has submitted an FRP under $ 112.20:YesNoNA 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* 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 discharge; * Type of material discharged;Actions being used to stop, remove, and * Estimates of the total quantity discharged;mitigate the effects of the discharge; Estimates of the quantity discharged asWhether an evacuation may be needed; and described in 112.1 (b);* Names of individuals and / or organizations who Source of the discharge;have also been contacted. 112.7 (a) (5) Does not apply if the facility has submitted a FRP under 112.20:Yes No NA Plan organized so that portions describing procedures to be used www when a discharge occurs will be readily usable in an emergency 112.7 (b) Plan includes a prediction of the direction, rate of flow, and totalYes No NA quantity of oil that could be discharged for each type of major equipment failure where experience indicates a reasonable potential for equipment failure Comments: 112.7 (a) - physical layout and facility diagram missing from Plan. 112.7 (a) (3) (iii) - EPA observed an out of use 300 gallon waste oil container without secondary containment in a room with a floor drain. EPA observed oil drums positioned in locations without secondary containment. Drums and tanks are to be located in secondary containment area(s). 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 14June 2014 ED_019088A_00004068-00007 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 sufficientlyWeirs, booms or other barriers, impervious to contain oil;* Spill diversion pond; 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 containersYes No NA Yes No NA Mobile / portable containersYes No NAYes No NA Oil - filled operational equipment (as defined in 112.2)Yes No NAYes No NA Other oil - filled equipment (i.e., manufacturing equipment)Yes No NAYes No NA Piping and related appurtenancesYes No NA Yes No NA Mobile refuelers or non - transportation - related tank carsYes No NAYes No NA Transfer areas, equipment and activitiesYes No NAYes No NA | Identify any other equipment or activities that are not listedYes No NAYes No NA above: 112.7 (d) Secondary containment for one (or more) of the following provisionsYes No is determined to be impracticable: General secondary containmentBulk storage containers 112.7 (c)112.8 (c) (2) /112.12 (c) (2) Loading / unloading rackMobile / portable 112.7 (h) (1)containers112.8 (c) (11) / 112.12 (c) (11) If YES * Tdehmeon sitrmapterda acntdi dceascbriibleid tiyn tohfe Pslaenc ondary containment is clearlyYes No NAYes No NA 8 * For bulk storage containers, periodic integrity testing ofYes No NAYes No NA containers and integrity and leak testing of the associated valves and piping is conducted Comments: (Does not apply if the facility has submitted a FRP under 112.20):YesNoNA 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 materialsYes No NAYes No NA required to expeditiously control and remove any quantity of oil discharged that may be harmful 112.7 (c) - EPA observes 55 gallon drum and 300 gallon waste oil tank in locations without sized secondary containment. 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 14June 2014 ED_019088A_00004068-00008 PLAN FIELD 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 Kept with Plan for at least 3 years (see Attachment B of this checklist)Yes NoYes No 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 theYes No NAYes No NA facility and reports to facility management (3) Discharge prevention briefings conducted at least once a year for oilYes No NA Yes No NA 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 112.7 (g) Plan describes how to:Yes No NAYes NoNA 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. 112.7 (h) Tank car and tank truck loading / unloading rack 10 is present at the facilityYes 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 orYes No NAYes No NA treatment facility designed to handle discharges or use a quick drainage system? Containment system holds at least the maximum capacity of theYes No NAYes NoNA largest single compartment of a tank car / truck loaded / unloaded at the facility (2) An interlocked warning light or physical barriers, warning signs,Yes No NAYes No NA 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 (3) Lower - most drains and all outlets on tank cars / trucks inspected prior Yes No NA Yes No NA to filling / departure, and, if necessary ensure that they are tightened, adjusted, or replaced to prevent liquid discharge while in transit Comments: 112.7 (e) There is no documentation in Plan for tank inspections, Appendix D 112.7 (f) - There is no documentation in Plan for annual employee training, Appendix C 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 14June 2014 ED_019088A_00004068-00009 PLAN FIELD 112.7 (i) Brittle fracture evaluation of field - constructed abovegroundYes No NAYes No NA 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 field- constructed aboveground containers) 112.7 (j) Discussion of conformance with applicable more stringent StateYes No NA rules, regulations, and guidelines and other effective discharge prevention and containment procedures listed in 40 CFR part 112 112.7 (k) Qualified oil - filled operational equipment is present at the facility 11Yes 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. 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 No NA 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 - filledYes No NA operational equipment each exceeding 42 U.S. gallons occur1r2 ed within any 12-month period within the three years prior to Plan certification date? " Comments: If YES for either, secondary containment in accordance with $ 112.7 (c) is required Facility procedure for inspections or monitoring program toYes No NAYes No 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 CYes No NA 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 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 14June 2014 ED_019088A_00004068-00010 ONSHORE FACILITIES (EXCLUDING PRODUCTION)PLANFIELD 40 CFR 112.8 / 112.12 112.8 (b) / 112.12 (b) Facility Drainage Diked Areas Drainage from diked storage areas is:Yes No NAYes 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 (2) Diked storage area drain valves are manual, open - and - closedYes No NAYesNoNA design (not flapper - type drain valves) If drainage is released directly to a watercourse and not into anYes No NAYes No NA 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). Undiked Areas Drainage from undiked areas with a potential for discharge designed Yes No NA Yes No NA (3) to flow into ponds, lagoons, or catchment basins to retain oil or return it to facility. Catchment basin located away from flood areas. 13 (4) If facility drainage not engineered as in (b) (3) (i.e., drainage flowsYes No NAYes No NA 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 (5) Are facility drainage waters continuously treated in more than oneYes No NAYes No NA treatment unit and pump transfer is needed? If YESTwo " lift " pumps available and at least one permanently installedYes No NAYes No NA * Facility drainage systems engineered to prevent a discharge asYes No NAYes No NA described in 112.1 (b) in the case of equipment failure or human error Comments: 112.8 (b) (3) Part 1.6 in the Plan discusses drainage from the undiked area where truck transfer operations occur (east side of Facility) to stormceptor units before discharging to the ocean, but doesn't include discussion for drainage at other parts of the facility. Piping and fueling occurs in other places at the facility in addition to the largest gas and diesel receptacles. 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 A of this checklist. (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 for mobile refuelers and other non - transportation - related tank Yes No NA Yes No NA 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 ORYes No NAYes No NA Alternatively, any discharge to a drainage trench system will beYes No NAYes No NA safely confined in a facility catchment basin or holding pond 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 14June 2014 ED_019088A_00004068-00011 PLAN FIELD (3) Is there drainage of uncontaminated rainwater from diked areas intoYes No NA Yes No NA a storm drain or open watercourse? If YESBypass valve normally sealed closedYesNoNAYesNoNA Retained rainwater is inspected to ensure that its presence willYes No NAYes No NA not cause a discharge as described in 112.1 (b) Bypass valve opened and resealed under responsibleYes No NAYes No NA supervision Adequate records of drainage are kept; for example, recordsYes NoNAYesNoNA 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 No NA protection compatible with local soil conditions * Regular leak testing conductedYes No NA Yes No NA (5) The buried section of partially buried or bunkered metallic tanksYes No NAYes No NA protected from corrosion with coatings or cathodic protection compatible with local soil conditions (6)Test or inspect each aboveground container for integrity on aYes No NAYesNo 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 No NA 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 integrity testingYes No NA Yes No NA are maintained * Container supports and foundations regularly inspectedYes No NAYes No NA 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 15Yes No NAYes No NA Integrity Testing Standard identified in the Plan: 112.8 (c) (6) - The plan fails to include container inspection records. 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 to Subject to 21 CFR part 110;* Have no external insulation; and AFVO Facilities | Elevated;Shop - fabricated. only) * Constructed of austenitic stainless steel; In addition, you must frequently inspect the outside of the containerYes No NAYes No NA for signs of deterioration, discharges, or accumulation of oil inside diked areas. You must determine and document in the Pl1a6 n the appropriateYesNoNAYesNoNA qualifications for personnel performing tests and inspections. 15 Records of inspections and tests kept under usual and customary business practices will suffice Onshore Facilities (Excluding Oil Production)Page 12 of 14June 2014 ED_019088A_00004068-00012 PLAN FIELD (7) Leakage through defective internal heating coils controlled: Steam returns and exhaust lines from internal heating coilsYesNoNAYesNoNA that discharge into an open watercourse are monitored for contamination, OR Steam returns and exhaust lines pass through a settlingYes No NAYes No NA tank, skimmer, or other separation or retention system (8) Each container is equipped with at least one of the following forYes No NAYesNo NA liquid level sensing: High liquid level alarms with an audible or visual* Direct audible or code signal communication between container gauger signal at a constantly attended operation orand pumping station; surveillance station, or audible air vent in smaller* Fast response system for determining liquid level (such as digital facilities;computers, telepulse, or direct vision gauges) and a person present to * High liquid level pump cutoff devices set to stopmonitor gauges and overall filling of bulk containers; or flow at a predetermined container content level;Regularly test liquid level sensing devices to ensure proper operation. (9) Effluent treatment facilities observed frequently enough to detectYes No NAYes No NA possible system upsets that could cause a discharge as described in 112.1 (b) (10) Visible discharges which result in a loss of oil from the container,Yes No NAYes 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 (11) Mobile or portable containers positioned to prevent a discharge asYes No NAYes No NA described in 112.1 (b). Mobile or portable containers (excluding mobile refuelers and otherYes No NAYes No NA 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 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 hasYes No NAYes No NA protective wrapping or coating Buried piping installed or replaced on or after August 16, 2002 isYes NoNAYesNoNA 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;Yes No NAYes NoNA corrosion damage is examined; and corrective action is taken (2) Piping terminal connection at the transfer point is marked as to originYes No NAYes No NA and capped or blank - flanged when not in service or in standby service for an extended time (3) Pipe supports are properly designed to minimize abrasion andYes No NAYes No NA corrosion and allow for expansion and contraction (4) Aboveground valves, piping, and appurtenances such as flangeYes No NAYes 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 NAYes No NA installation, modification, construction, relocation, or replacement (5) Vehicles warned so that no vehicle endangers aboveground pipingYes No NAYes No NA and other oil transfer operations Comments: 112.8 (c) (11) - EPA observes 55 gallon drum and 300 gallon waste oil tank in locations without sized secondary containment. Onshore Facilities (Excluding Oil Production)Page 13 of 14June 2014 ED_019088A_00004068-00013 This page left intentionally blank. Onshore Facilities (Excluding Oil Production) Page 14 of 14 June 2014 ED_019088A_00004068-00014 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 Condition16Storage Capacity and TypeType of Containment /Overfill Protection and of OilDrainage ControlTesting & Inspections Aboveground or Buried Tank AST A 2 compartment shell8,000 gallon (4,000 galDouble wall tankfloat switch high level alarm gasoline, 4,000 gal diesel)& gauge AST B6,000 gallons - gasolineDouble wall tankfloat switch high level alarm & gauge Maintenance building approx 7 waste oil, hydraulic fluid, Spill pallet, (1) drum without visual 55 gallon drumsmotor oilcontainment Waste oil container and heater 250 gallons - waste motor double wall tankgauge oil waste oil container250 gallons wastenone - contained withinvisual motor oilbuilding Heating oil container (to be250 gallons - heating oilnone - contained withinvisual removed)building (3) 2 in diameter fuel lines, 300 approx 50 gallons pernone - single wall pipinglow pressure pipe sensor linear feet ea.,line, 150-200 gallonsand auto valve shut off 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 2June 2014 ED_019088A_00004068-00015 ATTACHMENT A: SPCC FIELD INSPECTION AND PLAN REVIEW TABLE (CONT.) Documentation of Field Observations for Containers and Associated Requirements Container ID / General Condition17Storage Capacity and TypeType of Containment /Overfill Protection and Aboveground or Buried Tank of OilDrainage ControlTesting & 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 2June 2014 ED_019088A_00004068-00016 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 Not Not Applicable Present Present 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 ED_019088A_00004068-00017 This page left intentionally blank. Onshore Facilities (Excluding Oil Production) Page B-2 of 2 June 2014 ED_019088A_00004068-00018 ATTACHMENT C: 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). 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. (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 2June 2014 ED_019088A_00004068-00019 This page left intentionally blank. Onshore Facilities (Excluding Oil Production) Page C-2 of 2 June 2014 ED_019088A_00004068-00020 ATTACHMENT D: TIER II QUALIFIED FACILITY CHECKLISTNA TIER II QUALIFIED FACILITY PLAN REQUIREMENTS -40 CFR 112.6 (b) 112.6 (b) (1) Plan Certification: Owner / operator certified in the Plan that:Yes No (i) He or she is familiar with the requirements of 40 CFR part 112YesNoNA (ii) He or she has visited and examined the facility 19 'Yes No NA (iii) The Plan has been prepared in accordance with accepted and sound industry practices andYesNoNA standards and with the requirements of this part (iv) Procedures for required inspections and testing have been establishedYes No NA (v) He or she will fully implement the PlanYesNo NA (vi) The facility meets the qualification criteria set forth under $ 112.3 (g) (2)Yes No NA (vii) The Plan does not deviate from any requirements as allowed by 112.7 (a) (2) and 112.7 (d),Yes No NA 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 ofYes No NA management and the facility owner or operator has committed the necessary resources to fully implement the Plan. 112.6 (b) (2) Technical Amendments: The owner / operator self - certified the Plan's technical amendments Yes No NA for a change in facility design, construction, operation, or maintenance that affected potential for a $ 112.1 (b) discharge If YES* Certification of technical amendments is in accordance with the self - certificationYesNoNA provisions of $ 112.6 (b) (1). (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 theYesNoNA Plan as required under 112.6 (b) (4) (ii) (ii) The aggregate aboveground oil storage capacity increased to more than 10,000 U.S. gallonsYes No NA as a result of the change If YESThe 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 changeYes No NA and had it certified by a PE under $ 112.3 (d) 112.6 (b) (3) Plan Deviations: Does the Plan include environmentally equivalent alternative methods orYes No NA impracticability determinations for secondary containment? If YES Identify the alternatives in the hybrid Plan: Environmental equivalent alternative method(s) allowed under $ 112.7 (a) (2);Yes No NA * Impracticability determination under $ 112.7 (d)Yes No NA 112.6 (b) (4)For each environmentally equivalent measure, the Plan is accompanied by a writtenYes No NA 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 theYes No NA reason for the impracticability determination and provides the alternative measures to secondary containment required in 112.7 (d) AND (i) PE certifies in the Plan that: (A) He / she is familiar with the requirements of 40 CFR Part 112Yes No NA (B) He / she or a representative agent has visited and examined the facilityYes No NA (C) The alternative method of environmental equivalence in accordance with $ 112.7 (a) (2) or theYes No NA 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. Comments: 19 Note that only the person certifying the Plan can make the site visit Onshore Facilities (Excluding Oil Production)Page D-1 of 2June 2014 ED_019088A_00004068-00021 This page left intentionally blank. Onshore Facilities (Excluding Oil Production) Page D-2 of 2 June 2014 ED_019088A_00004068-00022 ATTACHMENT E: ADDITIONAL COMMENTS EPA Comments provided to Facility: 1) Update SWPPP, last update made May 1, 2014. (((( 2) Update SPCC Plan, plan not revised / updated for 5+ years, requires P.E. stamp signature 3) Include documentation of SPCC training in the Plan 4) Include STI tank inspection records in SPCC Plan (5) All oil filled containers require sized secondary containment. (1) 55 gallon drum without containment, (1) single wall 250 gallon tank (black, to be removed) without containment, (1) single wall 250 gallon waste oil container (blue) without containment (6) (1) 55 gallon gasoline drum needs to be grounded while in storage (7) label all outfalls and catch basins (8) repair berming around pressure wash station and bolster such that stormwater does not co - mingle with wash waters before discharging process wastewaters via stormdrain (9) Cover dumpsters and trash so that waste does not co - mingle with stormwater Onshore Facilities (Excluding Oil Production) Page E-1 of 2 June 2014 ED_019088A_00004068-00023 ATTACHMENT E: ADDITIONAL COMMENTS (CONT.) Onshore Facilities (Excluding Oil Production) Page E-2 of 2 June 2014 ED_019088A_00004068-00024 ATTACHMENT F: PHOTO DOCUMENTATION NOTES Photo # Photographer Time of Compass Description Name Photo Taken Direction See attachment Onshore Facilities (Excluding Oil Production) Page F-1 of 2 June 2014 ED_019088A_00004068-00025 ATTACHMENT F: PHOTO DOCUMENTATION NOTES (CONT.) Photo # Photographer Time of Compass Description Name Photo Taken Direction Onshore Facilities (Excluding Oil Production) Page F-2 of 2 June 2014 ED_019088A_00004068-00026