Document Rb4g0avgjKM8LXEeedYa097X

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 6 Enforcement Division INSPECTION REPORT 05/06/2024 09:00 AM (CT) 05/06/2024 11:45 AM (CT) RCRA Focused Compliance Inspection (FCI) Announced: No Access: Granted Facility or Site Name Facility/Site Identifier Facility/Site Physical Address City, State, Zip Code County/Borough Generator Status NAICS Type of Operation Geographic Coordinates Nature Environmental and Marine Services, LLC (Nature Environmental) TXR000084819 18511 Beaumont Hwy Houston, TX 77049 Harris Very Small Quantity Generator (VSQG) 423930, 484110, 484230 Nature Environmental receives domestic and foreign trash and liquid wastes. Most of their operation involves separating used oil from solids and water. 29.87449, -95.106947 Additional Persons Participating in Inspection: Name Title Organization Dedriel Gardner Inspector EPA REGION 6 John Penland Inspector EPA REGION 6 Anshul Paripati Contractor Eastern Research Group (ERG) Email Gardner.Dedriel@epa.gov Penland.John@epa.gov Anshul.Paripati@erg.com Phone (281) 983-2133 (214) 665-9717 (571) 535-1503 Lead Inspector: Cameron Tanaka Cameron Tanaka Date: 2024.07.25 23:35:57 -04'00' Digitally signed by Cameron Tanaka ERG Cameron.Tanaka@erg.com 07/25/2024 (703) 633-1632 ext. 11632 Page 1 of 9 Nature Environmental and Marine Services, LLC Inspection Date(s): 05/06/2024 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: Focused Compliance Inspection (FCI) The Port of Houston and surrounding facilities were selected for inspection based on an Environmental Justice and Regional initiative to evaluate facilities at ports receiving or transporting Resource Conservation and Recovery Act (RCRA)-regulated hazardous wastes, and/or have an International Convention for the Prevention of Pollution from Ships (MARPOL) Annex V Certificate of Adequacy (COA) issued by the U.S. Coast Guard (USCG). This report is based on information supplied by the facility representatives, inspector observations, port related facilities, and records including photographs taken (see Appendix 1), verbal or written statements made during or after the on-site inspection, and/or materials shown, demonstrated, or submitted to the EPA during or after the on-site inspection. In addition, information gathered prior to or after the inspection from a review of EPA, State, and public records may be included in this report. Attendees Title/Organization Lead Inspector/ Contractor/ERG RCRA Inspector/ Contractor/ERG Inspector/Enforcement Officer/EPA Region 6 Inspector/Enforcement Officer/EPA Region 6 Name Phone Email Opening Closing Conf. Conf. Cameron Tanaka (703) 633-1632 Cameron.Tanaka@erg.com N/A N/A ext. 11632 Anshul Paripati (571) 535-1503 Anshul.Paripati@erg.com N/A N/A Dedriel Gardner (281) 983-2133 Gardner.Dedriel@epa.gov N/A N/A John Penland (214) 665-9717 Penland.John@epa.gov N/A N/A Page 2 of 9 Nature Environmental and Marine Services, LLC Inspection Date(s): 05/06/2024 Facility General Description Tenant/Area Nature Environmental and Marine Services, LLC Inspection Date 05/06/24 Process Description Nature Environmental and Marine Services, LLC (Nature Environmental) receives waste streams in the form of domestic and foreign trash and liquid waste. The liquid wastes include wash water and used oil from ships. Nature Environmental also receives various universal wastes but does not accept hazardous waste. Everything the facility receives is sampled before being unloaded off ships and transported to its site. Most of Nature Environmental's operations involves separating used oil from solids and water in frac tanks and recycling the separated materials. Oily water is sent off to wastewater treatment plants. The facility does not maintain a MARPOL COA. Area of Concern Yes Page 3 of 9 Nature Environmental and Marine Services, LLC Inspection Date(s): 05/06/2024 SECTION II - OBSERVATIONS Tenant: Nature Environmental and Marine Services, LLC Section: 2.1 Date: 05/06/24, 9:00 AM Contains AOC: Yes Contains CBI: No Lead Inspector: Cameron Tanaka Attendees: Vivian Irlas Jr. (General Manager) and Alejandro Escobar (Dispatcher) Nature Environmental receives waste streams in the form of domestic and foreign trash and liquid waste. Domestic trash is generally sent to dumpsters and landfills while foreign trash is sent to an autoclave system in Corpus Christi to be steam sterilized. The liquid wastes include wash water and used oil from ships. The facility does not accept any hazardous waste. Most of its operation involves physically separating used oil from solids and water in frac tanks and recycling the separated materials. Nature Environmental essentially decants used oil by transferring the materials between frac tanks to get the lowest Basic Sediment & Water (BS&W) percentage possible in the final waste oil tank. The used oil that is separated out during this process is generally sold to refineries. A lower BS&W percentage means there is a higher oil content in the used oil, resulting in Nature Environmental receiving higher pay for the recycled material from companies such as Select Oil and Interstate. These companies re-refine the recycled used oil and receive about 10,000 gallons of the material per week from Nature Environmental. The oily water from this process is sent off to wastewater treatment plants for disposal and the solids remain in the frac tanks to be mixed with more water. This is done to pull out more oily content from the solids or sediments. The facility holds wastewater in three poly tanks. These are sent to a wastewater treatment plant (WWTP). If the wastewater is too acidic, the facility will add base, or vice versa, to meet the specifications of the WWTP. For foreign trash, the material is sealed in supersacks. These wastes will stay on-site for a day at most before they are sent to Corpus Christi for steam sterilization. Nature Environmental also removes and stores old printers and universal wastes from ships, such as fluorescent lamps. These wastes generally stay on-site for two weeks. Nature Environmental also stores paint waste which is sent for disposal within a day after being received on site. The facility also operates a parts washer. The solvent and spent solvent for this equipment is handled by Safety Kleen, a thirdparty vendor. A third party also performs any maintenance generating used oil for Nature Environmental. The facility also stated that they generate and transfer used oil. Nature Environmental is registered as a transporter, a used oil handler, and a VSQG of hazardous waste with EPA ID TXR000084819. Although it has not registered with the State of Texas or EPA as a used oil processor, Nature Environmental is acting in that capacity when it processes used oil [AOC #1 - Nature Environmental did not notify as a used oil processor - 40 CFR 279.51, TAC 324.12(2)]. The company transports waste from docks in Houston, primarily City Docks, and occasionally Galveston docks among others. Nature Environmental services vessels and docks exclusively by road using its own fleet of vacuum trucks. Everything Nature Environmental receives is sampled before being unloaded off ships and transported to its facility. The facility uses A&B Lab, Precision Labs, or its own in-house sampling. Nature Environmental generally perform solids and water testing, pH testing, and viscosity testing for any materials received. Occasionally the facility receives waste that does not match the description provided by the customer prior to pick up. Nature Environmental personnel stated that even in those cases, they have never received hazardous waste. Used oil is stored in various storage tanks during the physical separation process, generally for a total of 10 days. They send their processed used oil off on Bills of Lading (BOLs). The inspection team viewed several (BOLs) and noted no issues. Nature Environmental does not have a MARPOL COA. The inspection team then conducted a visual inspection of the facility. Observations and Areas of Concern (AOCs) are organized by section below along with facility responses where relevant. Page 4 of 9 Nature Environmental and Marine Services, LLC Inspection Date(s): 05/06/2024 Universal Waste Area The inspection team noted that many of the facility's universal wastes did not have universal waste labelling (see Appendix 1 - Photo 1) [AOC #2 - Nature Environmental did not label or mark the universal waste to identify the type of universal waste - 40 CFR 273.14]. On May 17, 2024, Nona Walker followed up on this issue via email , stating that the walls of the universal waste area had been labeled (see Appendix 2 and Appendix 3 - Photos 2 and 3). Also, some universal waste lamp boxes were open (see Appendix 1 - Photo 2) [AOC #3 - Nature Environmental did not keep containers holding universal waste lamps closed. - 40 CFR 273.13(d)(1)]. Used Oil Storage Area (see Appendix 1 - Photos 3 and 7) In Nature Environmental's pre-processing used oil storage area, the inspection team noted that multiple containers full of used oil were in rusted or in poor condition (see Appendix 1 - Photos 3, 4, and 7) [AOC #4 - Nature Environmental was storing used oil in containers that were rusted and/or in poor condition - 40 CFR 279.45(c)(1)]. Free liquid was also observed in an oil contaminated solid waste container adjacent to this area (see Appendix 1 - Photos 8 and 9). In her May 17 follow-up email, Ms. Walker indicated that the free liquid had been sucked out of the used oil dumpster (see Appendix 2). Chemical Storage Area 1 Adjacent to Nature Environmental's used oil storage area and across from the oil contaminated solid waste container, the inspection team viewed a tote and three drums in the facility's chemical storage area 1 (see Appendix 1 - Photos 5 and 6). According to facility representatives, the tote contained cooking oil. They could not identify the contents of the three drums during the inspection. In her May 17 follow-up email, Ms. Walker indicated that the drums contained cooking grease/oil which had been emptied into the cooking oil tote (see Appendix 2). Oil Waste Separation Frac Tank Area The inspection team observed about 21 frac tanks used for the facility's used oil separation process. The inspection team viewed Nature Environmental's final storage area for processed oil (see Appendix 1 - Photo 10). In this area, the facility had a white frac tank that did not have a label describing its contents (see Appendix 1 - Photo 11). The tank was not empty, but it did not have a visible gauge to help determine how full it was. The facility representatives believed that the frac tank only contained used oil [AOC #5 - Nature Environmental did not label aboveground tanks used to store used oil - 40 CFR 279.54(f)(1)]. The inspection team also observed six unlabeled white frac tanks for used oil storage in the oil waste separation frac tank area (see Appendix 1 - Photos 12 and 13) [see AOC #5]. These frac tanks were all either full or mostly full. Pictures of two of these white frac tanks with appropriate used oil labels were included in Ms. Walker's May 17 follow-up email (see Appendix 2 and Appendix 3 - Photos 4 and 7). The team also observed that the secondary containment for the six unlabeled white frac tanks had been folded over for an unknown amount of time, making the system incapable of preventing a release of used oil into the environment (see Appendix 1 - Photos 14). [AOC #6 - Nature Environmental's used oil aboveground tank secondary containment system was not sufficiently impervious to used oil to prevent any used oil released into the containment system from migrating out of the system to the soil, groundwater, or surface water - 40 CFR 279.54(c)(2)]. In her May 17 follow-up email, Ms. Walker explained that the secondary containment wall had been fixed (see Appendix 2 and Appendix 3 - Photos 5 and 6). The inspection team observed the heavier solids frac tank storage area (see Appendix 1 - Photos 15). A tote without a label containing a bluish green material was viewed in this area (see Appendix 1 - Photos 16). Facility personnel could not identify the contents of this tote during the inspection. In her May 17 follow-up email, Ms. Walker stated that the bluish green liquid was detergent/soap and that the tote had been properly labeled (see Appendix 2 and Appendix 3 - Photos 1). The inspection team concluded the visual inspection and began a document review process and closeout at Page 5 of 9 Nature Environmental and Marine Services, LLC Inspection Date(s): 05/06/2024 11:26 AM. The inspection team noted that Nature Environmental's Spill Prevention, Control, and Countermeasure (SPCC) plan was not up to date as it indicated there were only ten frac tanks on site rather than the 21 that the inspection team observed [AOC #7 - Nature Environmental's SPCC plan, which has been amended to cover used oil requirements according to their Contingency Plan, was not reviewed and immediately amended to reflect the facility's changes - 40 CFR 279.52(b)(4)(iii)]. Also, Nature Environmental personnel could not locate a physical copy of their Contingency Plan during the inspection [AOC #8 - Nature Environmental did not maintain a copy of their contingency plan at the facility - 279.52(b)(3)(i)]. During the closeout conference, the inspection team requested the following documents and clarifications: Manifests (if available) for any RCRA totes or material that have been sent off or handled within the last 3 years. The inspection team noted that one of Nature Environmental's non-hazardous waste manifests included a space for "RCRA totes" and requested clarification on what type of material that would be and how it is handled. A copy of the current SPCC plan A copy of the current Contingency Plan A copy of the current Used Oil Handler Analysis Plan Records of analyses performed for used oil for April 2024 In Ms. Walker's May 17 follow-up email (see Appendix 2), she responded to these requests in order as follows: Ms. Walker explained that Nature Environmental has not sent any RCRA totes or material offsite to date and has removed that wording from its non-hazardous waste manifest (see Appendix 2). The current SPCC plan is included as Appendix 4. Ms. Walker explained that the SPCC plan was updated to include all the frac tanks on site (see Appendix 2). The current Contingency Plan is included as Appendix 5. In section (b)(3)(i) of this plan, it is indicated that a "copy of the General Facility Standards plan and the SPCC Plan with contingency information is located in the operations supervisor office." Ms. Walker explained that the facility has placed a copy of the Contingency Plan in its SPCC binder (see Appendix 2). The current Used Oil Handler Analysis Plan is included as Appendix 6. No issues were noted in this plan. Records of analyses performed for used oil in April 2024 are included as Appendix 7. No issues were noted in these records. Page 6 of 9 Nature Environmental and Marine Services, LLC Inspection Date(s): 05/06/2024 SECTION III - RECORDS REVIEW No RCRA regulated records were reviewed during this focused onsite inspection. SECTION IV - APPARENT AREAS OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Tenant: Nature Environmental and Marine Services, LLC AOC #1 - Nature Environmental did not notify as a used oil processor. Citation: 40 CFR 279.51, TAC 324.12(2) Section: 2.1 AOC #2 - Nature Environmental did not label or mark Citation: 40 CFR 273.14 the universal waste to identify the type of universal waste. Section: 2.1 AOC #3 - Nature Environmental did not keep containers holding universal waste lamps closed. Citation: 40 CFR 273.13(d)(1) Section: 2.1 AOC #4 - Nature Environmental was storing used oil in Citation: 40 CFR 279.22(b)(1) containers that were rusted and/or in poor condition. Section: 2.1 AOC #5 - Nature Environmental did not label aboveground tanks used to store used oil. Citation: 40 CFR 279.45(g)(1) Section: 2.1 AOC #6 - Nature Environmental's used oil Citation: 40 CFR 279.45(e)(2) aboveground tank secondary containment system was not sufficiently impervious to used oil to prevent any used oil released into the containment system from migrating out of the system to the soil, groundwater, or surface water. Section: 2.1 AOC #7 - Nature Environmental's SPCC plan, which Citation: 40 CFR 279.52(b)(4)(iii) has been amended to cover used oil requirements according to their Contingency Plan, was not reviewed and immediately amended to reflect the facility's changes. Section: 2.1 AOC #8 - Nature Environmental did not maintain a copy of their contingency plan at the facility. Citation: 279.52(b)(3)(i)] Section: 2.1 Page 7 of 9 Nature Environmental and Marine Services, LLC SECTION V - FOLLOW UP Inspection Date(s): 05/06/2024 Follow-Up Any facility follow-up items are as discussed in each facility's observations in Section II. Documents or files provided by the facilities were transmitted via email and included responses to AOCs or provision of documents requested. Communication Log During and after the inspection, additional information was emailed to EPA including: 1. 05/17/24 Nature Environmental email - Nona Walker sent an email providing clarifications on observations noted during the inspection, photographs and explanations of corrective actions implemented, and documents requested during the inspection. Page 8 of 9 Nature Environmental and Marine Services, LLC SECTION VI - LIST OF APPENDICES Appendix 1. Photograph Log Appendix 2. Follow-Up Email from Nature Environmental Appendix 3. Follow-Up Photographs from Nature Environmental Appendix 4. Nature Environmental SPCC Plan Appendix 5. Nature Environmental Contingency Plan Appendix 6. Nature Environmental Oil Handler Analysis Plan Appendix 7. Nature Environmental Oil Testing from April 2024 Inspection Date(s): 05/06/2024 Page 9 of 9 APPENDIX 1. PHOTOGRAPH LOG UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: Nature Environmental LLC City: Houston County/Parish: Harris State: Texas Photo Name: DSC04132 Date of Photo: 05.06.2024 Time of Photo: 10:16 hrs Photographer: Anshul Paripati Description: View of general waste area which includes the Universal Waste Area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: Nature Environmental LLC City: Houston County/Parish: Harris State: Texas Photo Name: DSC04134 Date of Photo: 05.06.2024 Time of Photo: 10:16 hrs Photographer: Anshul Paripati Description: View of open fluorescent lamp boxes in general waste area (photo 1). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: Nature Environmental LLC City: Houston County/Parish: Harris State: Texas Photo Name: DSC04135 Date of Photo: 05.06.2024 Time of Photo: 10:21 hrs Photographer: Anshul Paripati Description: View of used oil storage area before processing begins. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: Nature Environmental LLC City: Houston County/Parish: Harris State: Texas Photo Name: DSC04136 Date of Photo: 05.06.2024 Time of Photo: 10:21 hrs Photographer: Anshul Paripati Description: View of severely rusted drum in oil storage area (photo 3). Inspector Penland stated the drum should be in overpack given the condition. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: Nature Environmental LLC City: Houston County/Parish: Harris State: Texas Photo Name: DSC04137 Date of Photo: 05.06.2024 Time of Photo: 10:30 hrs Photographer: Anshul Paripati Description: View of tote and three drums in chemical storage area 1, located adjacent to the used oil storage area. The tote contains cooking oil; however, the facility representatives were unsure about the three drums. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 6 Location: Nature Environmental LLC City: Houston County/Parish: Harris State: Texas Photo Name: DSC04138 Date of Photo: 05.06.2024 Time of Photo: 10:30 hrs Photographer: Anshul Paripati Description: Close up view of drums with no labels and with unknown liquids. The inspection team requested clarification on the contents of these drums in the follow-up email. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 7 Location: Nature Environmental LLC City: Houston County/Parish: Harris State: Texas Photo Name: DSC04139 Date of Photo: 05.06.2024 Time of Photo: 10:31 hrs Photographer: Anshul Paripati Description: Wide view of used oil storage area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 8 Location: Nature Environmental LLC City: Houston County/Parish: Harris State: Texas Photo Name: DSC04140 Date of Photo: 05.06.2024 Time of Photo: 10:40 hrs Photographer: Anshul Paripati Description: View of used oil contaminated garbage container. Located adjacent to the used oil storage area, across from chemical storage area 1. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 9 Location: Nature Environmental LLC City: Houston County/Parish: Harris State: Texas Photo Name: DSC04141 Date of Photo: 05.06.2024 Time of Photo: 10:40 hrs Photographer: Anshul Paripati Description: View of free liquid in oil contaminated garbage container (photo 9). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 10 Location: Nature Environmental LLC City: Houston County/Parish: Harris State: Texas Photo Name: DSC04142 Date of Photo: 05.06.2024 Time of Photo: 10:45 hrs Photographer: Anshul Paripati Description: View of final storage area of processed oil in the oil waste separation frac tank area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 11 Location: Nature Environmental LLC City: Houston County/Parish: Harris State: Texas Photo Name: DSC04143 Date of Photo: 05.06.2024 Time of Photo: 10:45 hrs Photographer: Anshul Paripati Description: View of white storage frac tank from photo 10 that did not have a label describing contents in the oil waste separation frac tank area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 12 Location: Nature Environmental LLC City: Houston County/Parish: Harris State: Texas Photo Name: DSC04144 Date of Photo: 05.06.2024 Time of Photo: 11:07 hrs Photographer: Anshul Paripati Description: View of six unlabeled white frac tanks for used oil storage in the oil waste separation frac tank area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 13 Location: Nature Environmental LLC City: Houston County/Parish: Harris State: Texas Photo Name: DSC04145 Date of Photo: 05.06.2024 Time of Photo: 11:07 hrs Photographer: Anshul Paripati Description: Close up view of one of the six white frac tanks without labels (photo 12) in the oil waste separation frac tank area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 14 Location: Nature Environmental LLC City: Houston County/Parish: Harris State: Texas Photo Name: DSC04147 Date of Photo: 05.06.2024 Time of Photo: 11:08 hrs Photographer: Anshul Paripati Description: Close up view of secondary containment of the six white frac tanks in photo 12 in the oil waste separation frac tank area. The secondary containment had been folded over for an unknown amount of time. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 15 Location: Nature Environmental LLC City: Houston County/Parish: Harris State: Texas Photo Name: DSC04148 Date of Photo: 05.06.2024 Time of Photo: 11:13 hrs Photographer: Anshul Paripati Description: View of heavier solids frac tank storage area in the oil waste separation frac tank area. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 16 Location: Nature Environmental LLC City: Houston County/Parish: Harris State: Texas Photo Name: DSC04149 Date of Photo: 05.06.2024 Time of Photo: 11:13 hrs Photographer: Anshul Paripati Description: View of tote in heavier solids frac tank storage area (photo 15) without a label. APPENDIX 2. FOLLOW-UP EMAIL FROM NATURE ENVIRONMENTAL Appendix 2 Page 1 of 2 Appendix 2 Page 2 of 2 APPENDIX 3. FOLLOW-UP PHOTOGRAPHS FROM NATURE ENVIRONMENTAL Appendix 3 Page 1 of 7 Appendix 3 Page 2 of 7 Appendix 3 Page 3 of 7 Appendix 3 Page 4 of 7 Appendix 3 Page 5 of 7 Appendix 3 Page 6 of 7 Appendix 3 Page 7 of 7 APPENDIX 4. NATURE ENVIRONMENTAL SPCC PLAN SPILL PREVENTION, CONTROL, AND COUNTERMEASURE PLAN NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC 18511 Beaumont Hwy, Houston, TX 77049 June 05, 2018 ) AARC Environmental, Inc. Two Riverway, Suite 1780 Houston, TX 77056 (713) 974-2272 (833) 493-2272 AARC Project # 1-E-7120-80 Appendix 4 Page 1 of 202 SPILL PREVENTION, CONTROL, AND COUNTERMEASURE PLAN NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC 18511 Beaumont Hwy, Houston, TX 77049 June 05, 2018 Prepared by Edwin C. Centeno AARC Environmental, Inc. Firm# F-8525 AARC Environmental, Inc. Two Riverway, Suite 1780 Houston, TX 77056 (713) 974-2272 (833) 493-2272 AARC Project# 1-E-7120-80 Copyright 1994-2018 by AARC Environmental, Inc. All rights reserved. This document contains proprietary information. No part thereof may be reproduced or transmitted in any form or by any means, electronic or mechanical, including photocopy, recording, or any information storage retrieval system, without prior permission in writing from AARC Environmental, Inc. Appendix 4 Page 2 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 TABLE OF CONTENTS INTRODUCTION .................................................................................................................................. 1 MANAGEMENT APPROVAL AND DESIGNATED PERSON ..............................................................5 PROFESSIONAL ENGINEER CERTIFICATION..................................................................................6 LOCATION OF SPCC PLAN ................................................................................................................7 PLAN REVIEW .....................................................................................................................................8 RECORD OF PLAN REVIEW AND AMENDMENTS ........................................................................ 10 FACILITIES, PROCEDURES, METHODS, OR EQUIPMENT NOT YET FULLY OPERATIONAL ... 12 CROSS REFERENCE WITH SPCC PROVISIONS .......................................................................... 13 ) PART I - GENERAL FACILITY INFORMATION ................................................................................ 15 1.1 Facility Owner and Operator ............................................................................... 15 1.2 Contact Information ............................................................................................. 15 1.3 Facility Location and Operations ......................................................................... 16 1.4 Facility Oil Storage and Handling ........................................................................ 16 1.5 Distance to Navigable Waters and Adjoining Shorelines and Flow Paths .......... 17 1.6 Discharge History .........................................................................................,........ 17 PART II - DISCHARGE PREVENTION-GENERAL PROVISIONS ................................................ 18 2.1 Compliance with Applicable Requirements (40 CFR 112.7(a)(2))....................... 18 2.2 Facility Layout Diagram (40 CFR 112.7(a)(3)) .................................................... 18 2.3 Spill Reporting (40 CFR 112.7(a)(4))................................................................... 18 2.4 Potential Discharge Volumes and Direction of Flow (40 CFR 112.7(b)) ............. 19 Two Riverway Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page i Appendix 4 Page 3 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 2.5 2.6 2.7 2.8 2.9 2.10 2.11 2.12 Containment and Diversionary Structures ............................................................. 20 Practicability of Secondary Containment ............................................................... 22 Inspections, Test, and Records .............................................................................. 22 2.7.1 Daily Inspection ...................................................................................... 26 2.7.2 Monthly Inspection.................................................................................. 26 2.7.3 Annual lnspection ................................................................................... 27 2.7.4 Periodic Integrity Testing........................................................................ 27 Personnel, Training, and Discharge Prevention Procedures ................................ 29 Security..................................................................................................................... 30 Tank Truck Loading/Unloading Rack Requirements ............................................. 31 Brittle Fracture Evaluation ....................................................................................... 31 Conformance with State and Local Applicable Requirements .............................. 31 PART Ill - DISCHARGE PREVENTION - ONSHORE FACILITIES (EXCLUDING PRODUCTION FACILITIES)........................................................................................................................... 33 3.1 Facility Drainage Controls ....................................................................................... 33 3.2 Bulk Storage Containers .......................................................................................... 33 3.2.1 Construction ............................................................................................ 33 3.2.2 Secondary Containment. ........................................................................ 33 3.2.3 Drainage of Containment Areas............................................................. 34 3.2.4 Corrosion Protection ............................................................................... 34 3.2.5 Partially Buried and Bunkered Storage Containers .............................. 34 3.2.6 Inspections and Tests............................................................................ ,34 3.2.7 Heating Coils .......................................................................................... ,35 3.2.8 Overfill Prevention Systems ................................................................... 35 3.2.9 Effluent Treatment Facilities................................................................... 36 3.2.10 Visible Discharges................................................................................... 36 MR En"Jlronmr:nt1l l.alllit&Wf'!'f Inc .......... Two Riverway Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page ii Appendix 4 Page 4 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 3.2.11 Mobile and Portable Containers ............................................................. 36 3.3 Transfer Operations, Pumping, and In-Plant Processes ........................................ 36 PART IV- DISCHARGE RESPONSE .................................................................................................... 37 4.1 Response to a Minor Discharge ............................................................................... 37 4.2 Response to a Major Discharge ............................................................................... 38 4.3 Waste Disposal ......................................................................................................... 39 4.4 Discharge Notification ...............................................................................................40 APPENDIX A: Site Plan and Facility Diagram......................................................................................... 42 APPENDIX B: Certification of Substantial Harm Criteria........................................................................ 46 APPENDIX C: Facility Inspection Checklists .......................................................................................... 47 STI/SPFA SP001 Annual Inspection Checklist...................................................................... 48 ) STI/SPFA SP001 Monthly Inspection Checklist. ................................................................... 49 STI/SPFA SP001 Portable Container Monthly Inspection Checklist.....................................50 APPENDIX D: Record of Containment Drainage ....................................................................................51 APPENDIX E: Record of Annual Discharge Prevention Briefings and Training ...................................52 APPENDIX F: Volume Required of Secondary Containment .................................................................53 APPENDIX G: Records of Tank Integrity and Pressure Tests...............................................................58 APPENDIX H: Emergency Contacts ........................................................................................................59 APPENDIX I: Discharge Notification Form ..............................................................................................60 APPENDIX J: Discharge Response Equipment lnventory......................................................................62 APPENDIX K: SOS ...................................................................................................................................63 MR Envronmental Inc ,OorupaloNJHealrh&Saf..rySoluooru Two Riverway Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page iii Appendix 4 Page 5 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 APPENDIX L: Oil Transfer Guidance .......................................................................................................64 APPENDIX M: Definitions......................................................................................................................... 66 MR Envlronmentai Inc .O<rupa!IDnllHIYl!h&!iifavSoluoont Two Riverway Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page iv Appendix 4 Page 6 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 List of Acronyms and Abbreviations ANSI American National Standards Institute API American Petroleum Institute ASME American Society of Mechanical Engineers AST Aboveground storage tank ASTM American Society for Testing and Materials BMP Best Management Practices CFR Code of Federal Regulations CERCLA Comprehensive Environmental Response, Compensation, and Liability Act EPA U.S. Environmental Protection Agency LEPC Local Emergency Planning Commission NAICS North American Industrial Classification System NPDES National Pollutant Discharge Elimination System NRC National Response Center OSHA Occupational Safety and Health Association PE Professional Engineer ) PEI Petroleum Equipment Institute POTW Publicly Owned Treatment Works RQ sos Reportable quantity Safety Data Sheet SIC Standard Industrial Classification SPCC Spill Prevention, Control, and Countermeasure STI/SPFA Steel Tank Institute/Steel Plate Fabricators of America SWPPP Storm Water Pollution Prevention Plan TCEQ Texas Commission on Environmental Quality TRRC Texas Railroad Commission USEPA United States Environmental Protection Agency USGS United States Geological Survey UST Underground storage tank MR Environmental Inc Enwonmerul, Ottupm,na,1H..al!h & Sd Sdulions Two Riverway Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page vi Appendix 4 Page 7 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC - 18511 Beaumont Hwy, Houston, TX 77049 INTRODUCTION The purpose of this Spill Prevention, Control, and Countermeasure (SPCC) Plan is to describe measures implemented by Nature Environmental and Marine Services, LLC to prevent oil discharges from occurring, and to prepare Nature Environmental and Marine Services, LLC to respond in safe, effective, and timely manner to mitigate the impacts of a discharge. This Plan has been prepared to meet the requirements of Title 40, Code of Federal Regulations, Part 112 (40 CFR part 112), and supersedes any earlier Plan developed to meet provisions in effect since 1974. In addition to fulfilling requirements of 40 CFR Part 112, this SPCC Plan is used as a reference for oil storage information and testing records; as a tool to communicate practices on preventing and responding to discharges with Nature Environmental and Marine Services, LLC employees and contractors; as a guide on facility inspections; and as a resource during emergency response. A facility is subject to SPCC regulations if the total aboveground storage capacity of oil and oil products exceeds 1,320 gallons; or if the underground storage capacity exceeds 42,000 gallons; and if, because of its location, the facility could reasonably be expected to discharge oil into navigable waters of the United States. Containers with a capacity of less than 55 gallons of oil or oil products are exempted from the requirements under the Oil Pollution Prevention regulations. "Oil" is defined in 40 CFR 112.2 as "oil of any kind or in any form, including, but not limited to: fats, oils, or greases from animals, fish, or marine mammal origin; vegetable oils, including oils from seeds, nuts, fruits, or kernels; and, other oils and greases, including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with wastes MR EnvHonrntnl:tl Inc Emilronmwn.,l,Ocai.PilNIHMl!h&Sifet'o'Salu!lon Two Riverway Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 1 Appendix 4 Page 8 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 other than dredge spoil." This definition includes many transformer oils, hydraulic oils, and other oils. This SPCC Plan addresses two basic issues: (1) design, operation, and maintenance procedures to prevent and control oil spills; and (2) discharge response procedures for facility personnel. More specifically, the first basic issue encompasses measures designed for the prevention of operational error and equipment failure, which are the causes of most spills; and the control and recovery of any oil spill by containment structures to prevent a spill from entering navigable waters. The second basic issue specifically encompasses countermeasures (contingency plan) to contain, clean up, and mitigate the effects of an oil spill at or from the facility. This Plan is not intended to address materials classified as hazardous wastes covered by 40 CFR 265 or Texas Waste Regulations that are stored in Nature Environmental and Marine Services, LLC However, used oils stored in different areas located in the general facility that are not covered by 40 CFR 265 or Texas Waste Regulations are therefore addressed in this SPCC Plan. Nature Environmental and Marine Services, LLC management has determined that this facility does not pose a risk of substantial harm under 40 CFR 112, as recorded in the "Substantial Harm Determination" included in Appendix B of this Plan. This Plan provides guidance on key actions that Nature Environmental and Marine Services, LLC must perform to comply with the SPCC rule: Complete monthly and annual site inspections as outlined in the Inspection, Tests and Records section of this Plan (Section 2.7) using the inspection checklists included in Appendix C. MR Envlro11mental lr,c HYhh&SmtvSlllU!lon, Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 2 Appendix 4 Page 9 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 Perform preventive maintenance of equipment, secondary containment systems, and discharge prevention systems described in this Plan as needed to keep them in proper operating conditions. Conduct annual employee training as outlined in the Personnel, Training, and Prevention Procedures section of this Plan (Section 2.8) and document them on the log included in Appendix E. If either of the following occurs, submit the SPCC Plan to the EPA Region 6 Regional Administrator (RA) and the Texas Commission on Environmental Quality (TCEQ), along with other information available as detailed in Section 4.4 of this Plan: - The facility discharges more than 1,000 gallons of oil into or upon the navigable waters of the U.S. or adjoining shorelines in a single spill event, or - The facility discharges oil in quantity greater than 42 gallons in each of two spill events within any 12 month period. Review the SPCC Plan at least once every five (5) years and amend it to include more effective prevention and control technology, if such technology will significantly reduce the likelihood of a spill event and has been proven effective in the field at the time of the review. Plan amendments, other than administrative changes discussed above, must be recertified by a Professional Engineer (PE) on the certification page of this Plan. Amend the SPCC Plan within six (6) months whenever there is a change in facility design, construction, operation, or maintenance that materially affects the facility's spill potential. The revised plan must be certified by a PE. Review the Plan on an annual basis. Update the Plan to reflect any "administrative changes" that are applicable, such as personnel changes or revisions to contact information and phone numbers. Administrative changes will be documented in the Plan review log of this Plan, but do not have to be certified by a PE. MR Environmental Inc Envlr .OttuPfik>n,l!Htial!h&Saf.r, s Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 3 Appendix 4 Page 10 of 202 I \ I NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 Amend the SPCC Plan if required by the EPA Regional Administrator. Nature Environmental and Marine Services, LLC must amend the Plan as required within 30 days after such notice, unless the Regional Administrator, for good cause, specifies another effective date. Nature Environmental and Marine Services, LLC must implement the amended Plan as soon as possible, but not later than six months after the amendment, unless the Regional Administrator specifies another date. Regional Administrator required amendments can be administrative or technical or both. MR Envlro,.mr:ntal Inc La!,Om,fWlo!l&lliwlh&WflYSolution, Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 4 Appendix 4 Page 11 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC - 18511 Beaumont Hwy, Houston, ) TX 77049 MANAGEMENT APPROVAL AND DESIGNATED PERSON 40 CFR 112.7 Nature Environmental and Marine Services, LLC is committed to preventing discharges of oil to navigable waters and the environment, and to maintaining the highest standards for spill prevention, Control, and Countermeasure through the implementation and regular review and amendment to this plan. This SPCC Plan has the full approval of Nature Environmental and Marine Services, LLC management. Nature Environmental and Marine Services, LLC has committed the necessary resources (including manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful) to implement the measures described in this Plan. The following is the Designated Person Accountable for Oil Spill Prevention at the facility and has the authority to commit the necessary resources to implement this Plan. Authorized Facility Representative: Mr . Title: Signature: Date: 5-17-2024 MR Environmental Inc &Mroomenul,Ocw & Sdution, Two Riverway Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 5 Appendix 4 Page 12 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 PROFESSIONAL ENGINEER CERTIFICATION 40 CFR 112.3(d) The undersigned Registered Professional Engineer is familiar with the requirements of Part 112 of Title 40 of the Code of Federal Regulations (40 CFR Part 112) and has visited and examined the facility, or has supervised examination of the facility by appropriately qualified personnel. The undersigned Registered Professional Engineer attests that this Spill Prevention, Control, and Countermeasure Plan has been prepared in accordance with good engineering practice, including consideration of applicable industry standards and the requirements of 40 CFR Part 112; that procedures for required inspections and testing have been established; and that this Plan is adequate for Nature Environmental and Marine Services, LLC located at 18511 Beaumont Hwy, Houston, TX 77049. This certification in no way relieves the owner or operator of the facility of his/her duty to prepare and fully implement this SPCC Plan in accordance with the requirements of 40 a e1- _-ag CFR Part 112. This Plan is valid only to the extent that the facility owner or operator maintains, tests, and inspects equipment, containment, and other devices as prescribed in this Plan. 06/05/2018 Signature Date Edwin C. Centeno - Jimenez Name of Professional Engineer 101780 Registration Number TX Issuing State MR Environmental Inc &,y;,nn,.,..t.,J,QupadonoJliYl:l,&S&reiySclut,Qn, Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 6 Appendix 4 Page 13 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC -18511 Beaumont Hwy, Houston, TX 77049 LOCATION OF SPCC PLAN 40 CFR 112.3(e) In accordance with 40 CFR 112.3(e), a complete copy of this SPCC is maintained at the facility office located at 18511 Beaumont Hwy, Houston, TX 77049. This Plan must be available to the Regional Administrator for on-site review during normal working hours. MR nv!ronn1itntal tnc Ertwt,onwol.Om,patbnuHe.11.h&SlleiySl!lluoo,, Two Riverway Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 7 Appendix 4 Page 14 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 PLAN REVIEW 40 CFR 112.3 and 112.5 Changes in Facility Configuration In accordance with 40 CFR 112.5(a), Nature Environmental and Marine Services, LLC periodically reviews and evaluates this SPCC Plan for any change in the facility design, construction, operation, or maintenance that materially affects the facility's potential for an oil discharge, including, but not limited to: Commissioning or decommissioning of containers; Reconstruction, replacement, or installation of piping systems; Construction or demolition that might alter secondary containment structures; or Changes of product or service, revisions to standard operation, modification of testing/inspection procedures, and use of new or modified industry standards or maintenance procedures. Amendments to the Plan made to address changes of this nature are referred to as technical amendments, and must be certified by a PE. Non-technical amendments can be done (and must be documented in this section) by the facility owner and/or operator. Nontechnical amendments include the following: Change in the name or contact information (i.e., telephone numbers) of individuals responsible for the implementation of this Plan; or Change in the name or contact information of spill response or cleanup contractors. Nature Environmental and Marine Services, LLC must make the needed revisions to the SPCC Plan as soon as possible, but no later than six (6) months after the change occurs, The Plan must be implemented as soon as possible following any technical amendment, but no later than six months from the date of the amendment. The facility manager is responsible for initiating and coordinating revisions to the SPCC Plan. MR Envlronmental Inc I.O;:a, l-wllh&/1Soluoont Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 8 Appendix 4 Page 15 of 202 l NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 Scheduled Plan Reviews In accordance with 40 CFR 112.5(b), Nature Environmental and Marine Services, LLC reviews this SPCC Plan at least once every five years. Revisions to the Plan, if needed, are made within six months of the five-year review. A registered Professional Engineer certifies any technical amendment to the Plan, as described above, in accordance with 40 CFR 112.3(d). The Plan is dated June 05, 2018. The next plan review is therefore scheduled to take place on or prior to June 04, 2023. Record of Plan Reviews Scheduled reviews and Plan amendments are recorded in this Plan. This log will be completed even if no amendment is made to the Plan as a result of the review. Unless a technical or administrative change prompts an earlier review of the Plan, the next scheduled review of this Plan will occur by June 04, 2023. MR& Environmental Inc ErN!roome,,l.il,OcwpaloNl &Si.fl!tVSolution1 Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 9 Appendix 4 Page 16 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 RECORD OF PLAN REVIEW AND AMENDMENTS MR fnvlronme-rnAl lnc Envlronmw>IM, OmlpzioNI li-,h &SifRYSdlftlont Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 10 Appendix 4 Page 17 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 RECORD OF PLAN REVIEW AND AMENDMENTS Non-Technical Amendments Non-technical amendments are not certified by a Professional Engineer Examples of changes include, but are not limited to: phone numbers, name changes, or any non-technical text change(s). Technical Amendments Technical amendments are certified by a Professional Engineer Examples of changes include, but are not limited to: commissioning or decommissioning containers; replacement, reconstruction, or movement of containers; reconstruction, replacements, or installation of piping systems; construction or demolition that might alter secondary containment structures; changes in product or service; revision of standard operation or maintenance procedures at a facility; or changes in facility design, construction operation, or maintenance that materially affects the potential for discharges. An amendment made under this section will be prepared within six months of the change and implemented as soon as possible but not later than six months following preparation of the amendment. Documentation of SPCC Plan reviews and evaluations shall be recorded in the table below and according to the following statement: I have completed a review and evaluation of the SPCC Plan for Nature Environmental and Marine Services, LLC As a result, I (will)/(will not) amend the Plan, as indicated below. Review/Eva!. Date Amend Plan? \ )-ili. <is)1 No - ---- Yes / No Yes / No Yes / No Yes/ No Yes I No Yes I No Yes I No Yes / No Yes / No Yes / No Yes / No Technical Amendment? W1 No Yes / No Yes / No Yes / No Yes I No Yes I No Yes I No Yes I No Yes / No Yes I No Yes / No Yes / No Signature , . Next Review/Eva!. Not Later Than Jr. A..t-. - MR EnV"lrontntn11I inc. 1 ()' - &'W Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 11 Appendix 4 Page 18 of 202 -AAA Environmental Inc l.nvl1onmenlal, Oc:cup,atlon,111 leallll &Sar11tv SoJuU011s 12/3/2018 Technical Amendment for Nature Environmental and Marine Services, LLC SPCC Plan 1. Tank 4 to T-10 (7 Frac tanks) were added. All tanks have a capacity of 500 bbl (21,000 gallons). Quantity of tanks can vary from 2 to 12 tanks or from 42,000 gallons to 252,000 gallons of oily water). 2. Frac-tanks used to store oily water from ships. Frac-tank is a single walled " steel walls and floor. 3. Each tank has an individual secondary containment and is sited near T-1 and T-2 (See Attached Drawing). 4. Secondary containment calculations for individual these tanks are available on SPCC Appendix F (All secondary containments are the same). None of the individual secondary containments are complying with the SPCC regulation 112.8(c)(2) Bulk storage containers: Construct all bulk storage tank installations (except mobile refuelers and other non- transportation-related tank trucks) so that you provide a secondary means of containment for the entire capacity of the largest single container and sufficient freeboard to contain recipitation. You must ensure that diked areas are sufficiently impervious to contain discharaed oil. Dikes, containment curbs, and pits are commonly employed for this purpose. You may also use an alternative system consisting of a drainage trench enclosure that must be arranged so that any discharge will terminate and be safely confined in a facility catchment basin or holding pond. Within three months of this technical amendment the owner or operator must modify or construct new tank installations (secondary containment) that comply with the conditions stated in this amendment and 40 CFR 112.8(c)(2). 1 Appendix 4 Page 19 of 202 RECORD OF PLAN REVIEW AND AMENDMENTS Nature Environmental and Marine Services, LLC Review/Eval. Date - -- Amend Plan? Technical Amendment? Yes I No Yes I No Yes I No Yes I No Yes I No Yes -I- No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No - --- -- Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No ,_ Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No -- Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Signature -- Next Review/Eval. Not Later Than - - ------ Appendix 4 Page 20 of 202 RECORD OF PLAN REVIEW AND AMENDMENTS Nature Environmental and Marine Services, LLC Review/Eval. Date - --- ---- Amend Plan? Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Y es I No - Yes I No Yes / No Yes / No Yes / No Yes / No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes / No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Technical Amendment? Yes I No Signature Yes I No Yes I No Yes I No Yes I No Yes I No - Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No - -- - -- -- Yes I N o -- Yes / No Yes / No Yes / No Yes I No Yes / No Yes / No Yes I No Yes / No Yes I No Yes I No Yes I No -- Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Next Review/Eval. Not Later Than - - Appendix 4 Page 21 of 202 RECORD OF PLAN REVIEW AND AMENDMENTS Nature Environmental and Marine Services, LLC Review/Eva!. Date Amend Plan? Technical Amendment? Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Ye s / No -- -- --- - --- - - Yes / No Yes / No Yes / No Yes / No --Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No - Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Signature Next Review/Eva!. Not Later Than -- -- -- - Appendix 4 Page 22 of 202  RECORD OF PLAN REVIEW AND AMENDMENTS Nature Environmental and Marine Services, LLC Review/Eval. Date Amend Plan? Yes / No Yes / No Yes / N-o Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes/ No - Yes / No - Yes / No Yes / No Yes / No - Yes / No Yes / No Yes / No Yes Yes / / NNoo Yes / No Yes / No Yes / No Yes / No Yes/ Yes / NNoo Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Technical Amendment? Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes/ No Yes / No Yes / No Yes / No Yes / No -- Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No ' Yes / No Yes / No Yes/ No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Yes / No Signature Next Review/Eval. Not Later Than - -- -- - - Appendix 4 Page 23 of 202  RECORD OF PLAN REVIEW AND AMENDMENTS Nature Environmental and Marine Services, LLC Review/Eval. Date ----- -- Amend Plan? Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Ye s I No - Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Technical Amendment? Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No -- Yes I No Yes I No Yes I No - Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Yes I No Signature Next Review/Eval. Not Later Than --- -- -- Appendix 4 Page 24 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC - 18511 Beaumont Hwy, Houston, TX 77049 FACILITIES, PROCEDURES, METHODS, OR EQUIPMENT NOT YET FULLY OPERATIONAL 40 CFR 112.7 Section 3.2.6 of this Plan describes the inspection program to be implemented by the facility following a regular schedule, including the dates by which each of the bulk storage containers will be tested. MR E11vlronn,entof Inc Envlrotllnll'lt1i,Oa:11pllloNIHallh&SdvSoluaoM Two Riverway Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 12 Appendix 4 Page 25 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 CROSS REFERENCE WITH SPCC PROVISIONS 40 CFR 112.7 The SPCC Plan does not follow the exact order presented in 40 CFR part 112. Section headings identify, where appropriate, the relevant sections of the SPCC rule. Table 1-1 presents a cross-reference of Plan sections relative to applicable parts of 40 CFR part 112. Table 1-1 - Cross-Reference with SPCC provisions Provision* 112.3(d) Plan Section Professional Engineer Certification Page 6 112.3(e) Location of SPCC Plan 7 112.5 Plan Review 8 112.7 Management Approval 5 112.7 Cross-Reference with SPCC Rule 13 Part I - General Information and Facility Diagram 15 112.7(a)(3) Appendix A: Site Plan and Facility Diagrams 42 Section 4.4: Discharge Notification 40 112.7(a)(4) Appendix I: Discharae Notification 60 Part IV - Discharge Response 37 112.7(a)(5) Aooendix J: Discharae Response Equipment Inventory 62 112.7(b) Section 2.4: Potential Discharge Volume and Direction of Flow 19 112.7(c) 112.7(d) 112.7(e) 112.7(f) MR Envfronn,e.nt:a.1 Inc [nyj ,()miparbn,alHM!h&Saf"'VSolutlont Section 2.5: Containment and Diversionary Structures 20 Section 2.6: Practicability of Secondary Containment 22 Appendix F: Volume Required for Secondary Containment 53 Section 2.7: Inspections, Tests, and Records 22 Appendix C: Facility Inspection Checklists 47 Section 2.8: Personnel, Training, and Discharge Prevention Procedures 28 Appendix E: Record of Annual Discharge Prevention Briefing and 52 Training Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 13 Appendix 4 Page 26 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 Provision* 112.?(g) Plan Section Section 2.9: Security 112.?(h) Section 2.10: Loading/Unloading Rack 112.?(i) 112.70) 112.8(b) Section 2.11: Brittle Fracture Evaluation Section 2.12: Conformance with Applicable State and Local Requirements Section 3.1: Facility Drainage 112.8(c)(1) 112.8(C)(2) 112.8(c)(3) 112.8(c)(4) Section 3.2.1 : Construction Section 3.2.2: Secondary Containment Aooendix F: Volume Required for Secondary Containment Section 3.2.3: Drainage of Diked Areas Aooendix D: Record of Secondary Containment DrainaQe Section 3.2.4: Corrosion Protection 112.8(c)(5) Section 3.2.5: Partially Buried and Bunkered Storage Containers 112.8(c)(6) Section 3.2.6: Inspections and Tests 112.8(c)(8) Section 3.2.8: Overfill Prevention System 112.8(c)(9) Section 3.2.9: Effluent Treatment Facilities 112.8(c)(10) Section 3.2.10: Visible Discharges 112.8(c)(11) Section 3.2.11: Mobile and Portable Containers 112.8(d) Section 3.3: Transfer Operations, Pumping and In-Plant Processes 112.20(e) Appendix B: Certification of Substantial Harm Determination Page 30 31 31 31 33 33 33 53 33 51 34 34 34 35 36 36 36 36 46 * Only relevant rule provisions are indicated. For a complete list of SPCC requirements, refer to the full text of 40 CFR 112. MR 1Er.,.v,l,ro,.n_,n.ll!,.!.n..t.a"W l ftIln,..,..... Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 14 Appendix 4 Page 27 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 PART I - GENERAL FACILITY INFORMATION 40 CFR 112.7(a)(3) 1.1 Facility Owner and Operator Facility Name Nature Environmental and Marine Services, LLC Owner Address of Owner Nature Environmental and Marine Services, LLC Phone: Name of Operator Address of Operator Mr. 18511 Beaumont Hwy, Houston, TX 77049 Phone: SIC Code NAICS Code 4213 - Trucking, Except Local and 5093 - Scrap and Waste Materials 484121 - General Freight Trucking, Long-Distance, Truckload and 425110 - Business to Business Electronic Markets 1.2 Contact Information The designated person accountable for overall oil spill prevention and response at the facility, also referred to as the facility's "Response Coordinator" (RC), is the CEO of the facility. 24-hour contact information is provided in Table 1-2. Name Table 1-2: Facility contact information Title Telephone Address 18511 Beaumont Hwy, Houston, TX 77049 18511 Beaumont Hwy, Houston, TX 77049 18511 Beaumont Hwy, Houston, TX 77049 MR Environmental Inc ErrvironrraiUl,OccupZloni!HYlthS.Slf SoM!ons Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 15 Appendix 4 Page 28 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC - 18511 Beaumont Hwy, Houston, TX 77049 1.3 Facility Location and Operations Nature Environmental and Marine Services, LLC operates this facility located at 18511 Beaumont Hwy, Houston, TX 77049 (see Figure A-1 in Appendix A). The facility is located in Harris County. 1.4 Facility Oil Storage and Handling A list of bulk oil storage containers at the facility with capacity of 55 gallons or more is provided in the Table 1-3. Only those containers that contain materials classified as "oil" are addressed in this SPCC Plan. Table 1-3: Characteristics of oil storage containers Map ID Tank ID Construction Bulk oil storage containers (ASTs) Horizontal " Corrugated Steel T-1 Rectangular Frac (See dimensions in Appendix Tank A, Fiaure A-3) Horizontal " Corrugated Steel T-2 Rectangular Frac (See dimensions in Appendix Tank A, Figure A-3) Drums/Totes/Other Containers Contents Location Capacity (Gallons) Oily Water Oily Water Southwest of Warehouse/Office Southwest of Warehouse/Office 21,000 21,000 T-3 Portable Containers (8 drums; 55 gallons) Steel (2'-0" 0 X 2'-10" H) Oily Water Adjacent to 440 Warehouse/Office Total 42,440 JIAR Envtronme.naI,nc menl.ll,Oo:a.pil\JonalHNJlh&5.det'f'SalllliM, Two Riverway Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC Appendix 4 Page 29 of 202 1994-2018 Page 16 Appendix 4 Page 30 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 The Site Plan and Facility Diagram included in Appendix A of this Plan show the location and layout of the facility. The Facility Diagram (Figure A-2) shows the location of oil containers. The total aboveground capacity of all bulk oil-containing storage containers at this facility is 197,000 gallons. There are no bunkered tanks or underground tanks at the facility. 1.5 Distance to Navigable Waters and Adjoining Shorelines and Flow Paths The facility is located west of San Jacinto River. The site plan in Figure A-1 in Appendix A shows the location of the facility relative to nearby waterways. The facility diagram included in Figure A-2 in Appendix A indicates the general direction of drainage. In the event of an uncontrolled discharge, oil would follow the natural topography of the site and flow to San Jacinto River. 1.6 Discharge History There have been no discharges of oil from this facility. In the event of an oil discharge, the required information will be recorded in this section. MR (nvlronmenttl tnc iM,a,menu,l,Oa:up11i,m,1JHQl\h&s,/ffYSoluoons Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 17 Appendix 4 Page 31 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC - 18511 Beaumont Hwy, Houston, TX 77049 PART II - DISCHARGE PREVENTION - GENERAL PROVISIONS 40 CFR 112.7 The following measures are implemented to prevent oil discharges during the handling, use, or transfer of oil products at the facility. Oil-handling employees have received training in the proper implementation of these measures. 2.1 Compliance with Applicable Requirements (40 CFR 112.7(a)(2)) When product enters or exits containers at this facility, a trained operator supervises the process, including the opening and closing of the container valves and the opening and closing of fill caps. The above ground storage containers and drums are positioned such that adequate secondary containment is provided for the largest single container in order to prevent a discharge of oil into navigable water. 2.2 Facility Layout Diagram (40 CFR 112.7(a)(3)) Figure A-1 in Appendix A shows the location of the facility. Figure A-2 in Appendix A presents a layout of the facility and the general location of oil-storage containers. The diagram also shows the location of any storm water drain inlets and the direction of surface water runoff. As required under 40 CFR 112.7(a)(3), the facility diagram indicates the location and content of ASTs, USTs, transfer stations, connecting piping and containment. 2.3 Spill Reporting (40 CFR 112.7(a)(4)) The discharge notification form included in Appendix I will be completed upon immediate detection of a discharge an prior to reporting of a spill to the proper notification contacts (see Appendix H). MRG - Env,,onmtHH.t.l Inc Enwcnrrvntal,Ckru Hslth&!ial'O!!YSolUDOns Two Riverway Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 18 Appendix 4 Page 32 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 2.4 Potential Discharge Volumes and Direction of Flow (40 CFR 112.7(b)) Table 2-1 presents expected volume, discharge rate, general direction of flow in the event of equipment failure, and means of secondary containment for each oil container stored at the facility. MR Envlronmental Inc Env+mn,-iUll,(kcupa!lon&IHYl!haSafySdllllon Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 19 Appendix 4 Page 33 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 Table 2-1: Potential discharge volumes and flow direction Map ID Type of Event Maximum Volume {aal) Bulk oil storaae containers (ASTs) Rupture 21,000 T-1 Leakage 21,000 Overfill 1,750 Rupture 21,000 T-2 Leakage 21,000 Overfill 1,750 Drums/Totes/Other Containers Rupture 55 T-3 Leakage 55 Overfill NA Maximum Discharge Rate {gal/min) 10,500 14.58 350 10,500 14.58 350 27.5 0.04 NA Direction of Flow Secondary Containment Description East towards San Jacinto River East towards San Jacinto River East towards San Jacinto River Aluminum Angle Standard Portable Containment Berm Aluminum Angle Standard Portable Containment Berm Concrete Containment NOTE: 1 Rupture and leakage volumes were estimated by assuming complete loss of the entire capacity of the tank 2 Overfill volume was estimated by assuming that the delivery person would take 5 minutes to notice overfill 3 Discharge rate for tank rupture was calculated by assuming full discharge in 2 minutes 4 Discharge rate for leakage was calculated by assuming the container will empty its contents within 24 hrs 5 Delivery rate is estimated to be 350 gpm for T-1 and T-2; NA gpm for T-3. 6 New Drums and totes are not filled on site. Used drums and totes usually are filled on site with used oil or other substances 2.5 Containment and Diversionary Structures As required by 40 CFR 112.7(c), the secondary containment system (shown in Figures A-2) must be capable of containing oil and constructed so that any discharge from a primary containment system must not escape the containment system before cleanup occurs. Tank T-1 (Steel; Oily Water; 21,000 gallons) is sited in an aluminum angle standard portable containment berm C-1 (capacity of 5,745 gallons). The existing secondary containment C-1 volume is insufficient to contain the capacity of the largest single container (T-1) including sufficient freeboard to contain precipitation. Within three months of the implementation of this plan the facility must provide secondary containment sufficient to hold the full capacity of T-1 and sufficient freeboard to contain precipitation. The facility has made a written commitment to have manpower, equipment, and materials MR EnvJronmental Inc nvlmnrnei!M,Ocrup,11ionalHMhh&!.af Soludons Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 20 Appendix 4 Page 34 of 202 Appendix 4 Page 35 of 202 Appendix 4 Page 36 of 202 Appendix 4 Page 37 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 available to the facility to respond to a release. During the time until adequate secondary containment is provided, the facility must deploy active secondary containment. Once provided Nature Environmental and Marine Services, LLC must keep the secondary containment clear of debris. The facility must ensure that the secondary containment system must be free of cracks, holes, or gaps and be sufficiently impervious to contain leaks, spills, and accumulated rainfall until the collected material is detected and removed. T-1 is located outside so the owner or operator needs to provide extra volume for a freeboard of 9.9 inches. See calculations in Appendix F. Tank T-2 (Steel; Oily Water; 21,000 gallons) is sited in an aluminum angle standard portable containment berm C-2 (capacity of 5,745 gallons). The existing secondary containment C-2 volume is insufficient to contain the capacity of the largest single container (T-2) including sufficient freeboard to contain precipitation. Within three months of the implementation of this plan the facility must provide secondary containment sufficient to hold the full capacity of T-2 and sufficient freeboard to contain precipitation. The facility has made a written commitment to have manpower, equipment, and materials available to the facility to respond to a release. During the time until adequate secondary containment is provided, the facility must deploy active secondary containment. Once provided Nature Environmental and Marine Services, LLC must keep the secondary containment clear of debris. The facility must ensure that the secondary containment system must be free of cracks, holes, or gaps and be sufficiently impervious to contain leaks, spills, and accumulated rainfall until the collected material is detected and removed. T-2 is located outside so the owner or operator needs to provide extra volume for a freeboard of 9.9 inches. See calculations in Appendix F. Tank T-3 (Steel; 55 gallons Drums; Oily water) is placed inside a concrete secondary containment C-3 (capacity of 1,148 gallons). The existing secondary containment C-3 volume is sufficient to contain the capacity of the largest containment, T-3. The facility must ensure that the secondary containment system must be free of cracks, holes, or gaps and be sufficiently impervious to contain leaks, spills, and accumulated rainfall until MA Envhonmental Inc ttMl1>11mt!UJ,Qnuj>Hio,Y!Hul!h& SolUttOOS Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 21 Appendix 4 Page 38 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 the collected material is detected and removed. T-3 is located in an area with a shed roof thus eliminating the need to provide extra volume for freeboard. See calculations in Appendix F. Nature Environmental and Marine Services, LLC has commissioned the preparation of this oil spill contingency plan and a written commitment to have manpower, equipment and materials available to the facility to respond to a release as described in 40 CFR 112.7(k)(2) has been made by Nature Environmental and Marine Services, LLC. Nature Environmental and Marine Services, LLC must periodically inspect the tanks (as described in Sections 2.7) and ensure good housekeeping practices (including but not limited to those described in Appendix L) are used during routine maintenance activities. Nature Environmental and Marine Services, LLC must also ensure that oil from any spill is managed and disposed following all regulatory requirements . 2.6 Practicability of Secondary Containment As required by 40 CFR 112.?(d), the facility management has determined that secondary containment is practicable. 2.7 Inspections, Test, and Records All bulk storage containers must be inspected on a regular schedule, including the outside of the container for deterioration, discharges, or accumulations of oil inside containment. A walk around inspection is intended for portable bulk storage containers while non-portable bulk storage containers are subject to the inspection requirements as outlines in STI/SPFA SP001 Standard. Inspection of oil filled equipment or mobile equipment tanks are subject to the existing operating, maintenance and inspection procedures for each piece of machinery or equipment. Documentation and record keeping of these inspections are managed through Nature Environmental and Marine Services, LLC's usual and customary business practices. MR Envlronmien111r Inc Envlror,rnmlal,Occu Hsllh& Sulutian, Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 22 Appendix 4 Page 39 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 Non-portable bulk storage containers are subject of routine visual inspections per STI/SPFA SP001 Standard. Monthly inspections will be conducted by AARC Environmental, Inc. Formal internal and external inspections are conducted by certified inspectors per the SP001 Standard. Any tanks subject to a different inspection schedule than the one outlined in the Inspection portion of the SPCC are identified in the appendices. The inspection exceptions are based on good engineering practices, determined by the professional judgment of the Professional Engineer who certified the Plan and has given consideration to industry standards. Nature Environmental and Marine Services, LLC must conduct inspections and tests in accordance with 40 CFR 112.7(e). Based on the criteria developed in SP001, the inspection schedules for the tanks at the Nature Environmental and Marine Services, LLC facility located at 18511 Beaumont Hwy, Houston, TX 77049 have been determined and summarized. MR EnY"lronmenCill Inc: - -fUM!A,W(lff\lJl,MN Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 23 Appendix 4 Page 40 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 Table 2-2: General inspection schedule evaluation for tanks at facility Container T-1 T-2 T-3 AST Type Horizontal Rectangular Frac Tank Horizontal Rectangular Frac Tank Vertical Steel Portable Container (Drums) Volume Spill Caallons) Control 21,000 No 21,000 No 55 Yes CRDM Yes Yes Yes Category 3b 3b 1 *Inspection Schedule [P, E&L (5), 1(10)] or [P. L(1}. E(5}l [P, E&L (5), 1(10)] or [P, L{1}. E(5}l ap This is a suggested inspection schedule. Final schedule to be selected by client in consultation with an STI certified inspector or professional engineer. alf a portable container is taken out of the spill containment pallets then their category changes from Category 1 to Category 3 and the following **notes applies. bFor T-1 and T-2 if additional spill control is added their category will change to 1 and so the inspection schedule. **Notes: P - Periodic AST inspection E - Formal External Inspection by certified inspector I - Formal Internal Inspection by certified inspector L - Leak test by owner or owner's designee ( ) indicates maximum inspection interval in years Category 1 -ASTs with spill control, and with CROM Category 2 - ASTs with spill control and without CROM Category 3 - ASTs without spill control and without CROM P** - Owner shall either discontinue use of portable container for storage as scheduled below or have the portable container DOT (Department of Transportation) tested and recertified per the following schedule if the portable container do not have spill control (i.e., Category 3): Plastic portable container - every 7 years Steel portable container - every 12 years Stainless steel portable container - every 17 years Additional information: Frac tanks are not constructed following any industry standard (UL, API, etc.) meaning that the inspection of these tanks is at the discretion of the owner and the professional engineer. MR Envt,onn\ctnt:;al Inc O'lvlronmenW, Orolpnk!NI HMlth & 'iifll!tV SollJIIO"s Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 24 Appendix 4 Page 41 of 202 Appendix 4 Page 42 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 Table 2-3 summarizes the various types of inspections and tests performed at the facility. Table 2-3: Routine inspection and testing program. Facility Component Aboveground container Container supports and foundation Secondary Containment Lowermost drain and all outlets of tank truck All aboveground valves, piping, and appurtenances Periodic integrity testing Action Visually inspect container integrity and inspect outside of container for signs of deterioration and discharges Inspect container supports and foundations Inspect for signs of deterioration, discharges, or accumulation of oil or water inside diked areas. Visually inspect content for presence of oil Visually inspect Frequency/ Circumstances Continuous, Monthly and Annual Continuous, Monthly and Annual Continuous, Monthly and Annual Prior to draining Prior to filling and departure Assess general condition of items, such as flange joints, expansion joints, valve glands and bodies, catch pans, pipeline supports, locking of valves, and metal surfaces Please refer to STI/SPFA SP001, 6th Ed., January, 2018 Continuous, Monthly and Annual Please refer to STI/SPFA SP001 Table 2-4: Suggested inspection schedule for Formal Inspections Tank ID Construction Date (In service Date) Last External and Internal Inspection Next Inspection (External)* 1 unknown unknown Will depend on the inspection schedule selected 2 unknown unknown Will depend on the inspection schedule selected 3 unknown unknown Not required * A formal inspection is one conducted by a certified inspector. Next Inspection (Internal)* Will depend on the inspection schedule selected Will depend on the inspection schedule selected Not required Note: If information became available about any not known date in the above Table, the owner/operator is responsible to notify a PE to adjust the schedule accordingly. MEnvironmental IJ1c Enwoomental, Ocrupm,n.,1 HMkh & Sm'VSalut101u Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 25 Appendix 4 Page 43 of 202 Appendix 4 Page 44 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 A record of the inspections/tests signed by the supervisor or inspector conducting the inspection/tests will be retained in the SPCC Plan for a period of three years. Records of inspections and tests kept under usual and customary business practices will suffice for purposes of this paragraph. 2.7.1 Daily Inspection The facility employees perform continuous, undocumented inspections of the facility each day. This daily visual inspection involves observing container/piping for damage or leakage, stained or discolored soils, or accumulation of water in the secondary containment areas. 2.7.2 Monthly Inspection The checklist provided in Appendix C is used for monthly inspections by the facility personnel. The monthly inspections cover the following key elements: Observing the exterior of oil-storage containers, pipes, and other equipment for signs of deterioration, leaks, corrosion, and thinning. Observing the exterior of portable containers for signs of deterioration or leaks. Observing container foundations and supports for signs of instability or excessive settlement. Observing the container fill and discharge pipes for signs of poor connection that could cause a discharge, and container vents for obstructions and proper operation. Verifying the proper functioning of overfill prevention systems. Checking the inventory of discharge response equipment and restocking as needed. All problems regarding containers, piping, containment, or response equipment will immediately be reported to the authorized facility representative. Visible oil leaks from container walls, piping, or other components will be repaired as soon as possible to MR Environmental Inc &iworlrrw,u,l,DccuJM[lon,olHe.l!h&Sdft'f'S<lludolu Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 26 Appendix 4 Page 45 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 prevent a larger spill or a discharge to navigable waters. Pooled oil is removed immediately upon discovery. Written monthly inspection records are signed by the authorized facility representative and maintained with this SPCC Plan for a period of three years. 2.7.3 Annual Inspection Facility personnel perform a more thorough inspection of facility equipment on an annual basis. This annual inspection complements the monthly inspection described above and the checklist is provided in Appendix C of this Plan. Written annual inspection records are signed by the authorized facility representative and maintained with this SPCC Plan for a period of three years. 2.7.4 Periodic Integrity Testing All non-portable/non-mobile bulk storage containers must be tested on a regular schedule and whenever material repairs are made unless: there is an environmental equivalency identified that has given consideration to good engineering practices and verified by the Professional Engineer who certified the Plan or it is exempt. Steel Tank Institute STI/SPFA SP001 industry standard is followed unless the tank is 50-feet or taller, or 30-feet or greater in diameter; then refer to API 653 Standard. Records of integrity testing are maintained according to Nature Environmental and Marine Services, LLC usual and customary business practices. The following table shows the integrity testing schedule and required frequency in years per STI/SPFA SP001- Standard for the Inspection of Aboveground Storage Containers, 6th Edition Issued January 2018: MR Envlronmental Inc [!9,ljn:,nmll'IUI, Om,parlonalHe.llh&s.t 'iduti<r, Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 27 Appendix 4 Page 46 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 Table 2-5: SP001 inspection schedule for shop-fabricated AST's, Field-erected AST's and Portable Containers AST Type and Size (US gallons) Category 1 Category 2 Category 3 0 - 1,100 p p P, E&L (10) Shop-Fabricated AST's 1,101 - 5,000 p 5,001 - 30,000 P, E(20) P, E&L (10) [P, E(10), 1(20)] or [P,E(5), L(10)] [P, E&L (5), 1(10)] or [ P, L(2), E(5)] [P, E&L (5), 1(10)] or [P, L{1), E(5)] 30,001 - 75,000 P, E(20) P, E&L (5), 1(15) P, E&L (5), 1(10) Field-erected AST Portable Containers P, E(5), 1(10) p P, E&L(5), 1(10) p P, E&L(5), 1(10) P** Notes: P - Periodic AST inspection E - Formal External Inspection by certified inspector I - Formal Internal Inspection by certified inspector L - Leak test by owner or owner's designee ( ) indicates maximum inspection interval in years Category 1 - ASTs with spill control, and with CRDM Category 2 - ASTs with spill control and without CRDM Category 3 - ASTs without spill control and without CRDM P** - Owner shall either discontinue use of portable container for storage as scheduled below or have the portable container DOT (Department of Transportation) tested and recertified per the following schedule if the portable container do not have spill control (i.e., Category 3): Plastic portable container - every 7 years Steel portable container - every 12 years Stainless steel portable container - every 17 years Nature Environmental and Marine Services, LLC shall select with the inspector which of the following integrity test will perform in their tanks (the list is not all inclusive): MR Envlronmibntal Inc. .OcwpmoNJHslth&Snry'i<Hlbml Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 28 Appendix 4 Page 47 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 Ultrasonic thickness (UT) testing UT scanning readings Magnetic particle testing (MT) Radiographic testing (RT) Magnetic flux testing (MFL) Penetrant testing (PT) As for the leaking testing methods for shop-fabricated ASTs, the standard references the Steel Tank Institute Recommended Practice R912, "Installation Instructions for Shop Fabricated Stationary Aboveground Storage Tanks for Flammable, Combustible Liquids." There also exist some types of Leaking Testing Methods like: Gas pressure decay Gas pressure soap bubble testing Gas tracers Soil tracers Mass measurement Level measurement Hydrostatic testing 2.8 Personnel, Training, and Discharge Prevention Procedures The authorized facility representative is the designated person responsible for oil discharge prevention, control, and response preparedness activities at this facility. In accordance with 40 CFR 112.7(f), the facility has trained oil-handling facility personnel in the operation and maintenance of oil pollution prevention equipment, discharge procedure protocols, applicable pollution control laws, rules and regulations, general facility operations, and the content of this SPCC Plan. Any new facility personnel with oil-handling responsibilities are provided with this same training prior to being involved in any oil operation. MR En'lltonmrnlal Jnc liMrc..morul,Octupalc)nilHMl!h& l Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 29 Appendix 4 Page 48 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 Annual discharge prevention briefings are held by the authorized facility representative for all facility personnel involved in oil operations. The briefings are aimed at ensuring continued understanding and adherence to the discharge prevention procedures presented in the SPCC Plan. The briefings also highlight and describe known discharge events or failures, malfunctioning components, and recently implemented precautionary measures and best practices. Facility operators and other personnel will have the opportunity during the briefings to share recommendations concerning health, safety, and environmental issues encountered during facility operations. Records of the briefings and discharge prevention training are kept on the form shown in Appendix E and maintained with this SPCC Plan for a period of three years. 2.9 Security Nature Environmental and Marine Services, LLC entrance gates are locked when the facility is unattended. All valves permitting direct outward flow of the container's contents to the surface have adequate security measures so that they remain in the closed position when in non-operating status or non-standby status. The starter control on each oil pump is locked in the "off" position and located at a site accessible only to authorized personnel when the pump is in a non-operating or nonstandby status. The loading/unloading connections of oil pipelines or facility piping are securely capped or blank-flanged when not in service or when in standby service for an extended time. The facility has adequate lighting commensurate with the type and location of the facility that will assist in the: Discovery of discharges occurring during hours of darkness, both by operating personnel, if present, and by non-operating personnel (the general public, local police, etc.); and MR Envlronmental Inc Emrimn ,OcrupatlonllH&llh&SafeiySdutian, Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 30 Appendix 4 Page 49 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 Prevention of discharges occurring through acts of vandalism. 2.10 Tank Truck Loading/Unloading Rack Requirements This facility does not utilize a tank car or tank truck loading rack for transferring oil. General guidelines for transferring oil are contained in Appendix L. 2.11 Brittle Fracture Evaluation Nature Environmental and Marine Services, LLC does not have any field-constructed aboveground container, then in accordance with 40 CFR 112.?(i), and under STI/SPFA SP001, 6th Ed., January, 2018, brittle fracture evaluation is not required for any tank in this facility because the tank shells are under inch thick and the risk of brittle fracture is minimal. Brittle fracture assessments and documentation are not required for tanks that fall within the scope of this Standard. Nonetheless, in the event that a field constructed aboveground container undergoes a repair, alteration, reconstruction, or change in service that might affect the risk of a discharge or failure, the container will be evaluated for risk of discharge or failure, following APl-653 or STI/SPFA SP001 or an equivalent approach, and corrective action will be taken as necessary. 2.12 Conformance with State and Local Applicable Requirements In addition to the requirements under 40 CFR 112, the Texas Commission on Environmental Quality (TCEQ) further regulates certain oil storage containers under Texas Administrative Code, Title 30, Chapter 334- Underground and Aboveground Storage Containers and oil spills under 30 TAC Chapter 327 - Spill Prevention and Control. State and local oil spill related requirements have been incorporated into this SPCC Plan where applicable. MR Envlronmental Inc IM, ....... ..-al,0,f !l6Ml- wa,,. Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 31 Appendix 4 Page 50 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 Applicable Spill Reporting Requirements for Spills to Water* US EPA (Region VI)/ NRC TCEQ Reportable Quantity (RQ) for: Vegetable Oils (i.e. Palm Oil, Soy Oil, etc) Lubricating Oil Used Oil Petroleum Oils Sheen Sheen Sheen Sheen Sheen Sheen Sheen Sheen Initial Reporting Time Immediately upon discovery of a release Follow up Report Time Within 60 Calendar Days if spill exceeds 1,000 gallons or second spill of 42 aallons in 12 months *Spills to water includes spills or releases to stormwater As soon as possible but no later than 24 hours after discovery of a release 30 Calendar Days US EPA (Region VI)/ TCEQ Applicable Spill Reporting ReNqRuCirements for Spills to Land** Reportable Quantity (RQ) for: Vegetable Oils (i.e. Palm N/A Oil, Soy Oil, etc) Lubricating Oil N/A Used Oil N/A Petroleum Oils NA 210 gallons 25 gallons 25 gallons 25 gallons Initial Reporting Time Follow uo Reoort Time As soon as possible but N/A no later than 24 hours after discover of a release N/A 30 davs **Spills to land include spills or releases that occur on soil, concrete and/or asphalt on-site or off-site. MEnvlronmen al Inc ErMron ,CktupllbnuHMl!h&SaRtySolut!on1 Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 32 Appendix 4 Page 51 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 PART Ill - DISCHARGE PREVENTION - ONSHORE FACILITIES (EXCLUDING PRODUCTION FACILITIES) 40 CFR 112.8 3.1 Facility Drainage Controls Any potential discharge from oil-storage containers will be restrained by secondary containment structures. The content of the secondary containment areas are inspected by the facility personnel for the presence of oil or sheen. A facility employee or contractor will remove any oil accumulated within the secondary containment area to a tank, tank truck, or other appropriate container for disposal in accordance with applicable legal requirements. 3.2 Bulk Storage Containers All oil storage containers at the facility are constructed of welded steel or plastic compatible with the contents at the specified operating conditions (pressure and temperature). 3.2.1 Construction All oil containers used at this facility are constructed of welded steel or plastic. The design and construction of all bulk storage containers are compatible with the oil they contain under the specified conditions. 3.2.2 Secondary Containment Aboveground Storage Tanks The ASTs on-site include two (21,000 gal) oily water AST. All AST's are inside secondary containments made of PVC (aluminum angle standard portable containment berms). MR Environmental Inc ErMron!nenw,Occupamn.ill-wl!h& Solutloni Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 33 Appendix 4 Page 52 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 Drums/Totes/Containers Inside the facility there is various (55 gallons) oily water drums. All portable containers are inside a secondary containment made of concrete. Please see Appendix F for detailed secondary containment calculations. 3.2.3 Drainage of Containment Areas Secondary containment areas are drained under direct supervision of facility personnel. The accumulated water is observed for signs of oil prior to draining. The content of the secondary containment areas are inspected by the facility personnel for the presence of oil or sheen. Containment drainage events are recorded on the form included in Appendix D of this Plan. Records are maintained at the facility for at least three years. 3.2.4 Corrosion Protection This section is not applicable to Nature Environmental and Marine Services, LLC, since there are no partially buried or underground metallic storage tanks at the facility. 3.2.5 Partially Buried and Bunkered Storage Containers This section is not applicable to Nature Environmental and Marine Services, LLC, since there are no partially buried or bunkered metallic storage tanks. 3.2.6 Inspections and Tests Visual inspections of aboveground storage containers by facility personnel are performed according to the procedure described in this SPCC Plan. Leaks from container seams, gaskets, rivets, and bolts are promptly corrected. Records of inspections and tests are signed by the inspector and kept at the facility for at least three years. MR Envlronmental Inc m.rrtal,OU\Jpatlon,,J &Sil'"VSlllutian Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 34 Appendix 4 Page 53 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 3.2.7 Heating Coils Section 40 CFR 112.8(c)(7) does not apply because the facility does not have any heating coils. 3.2.8 Overfill Prevention Systems All non-portable/non-mobile bulk storage containers must be equipped with overfill protection with one of the following devices is required: High liquid level alarms with an audible or visual signal at a constantly attended operation; High liquid level pump cutoff device set to stop flow at a predetermined container content level; Direct audible or code signal communication between the tank gauge and pumping station; Fast response system for determining the liquid level of each bulk storage container such as digital computers, telepulse, or direct vision gauges. With this alternative a person (driver) must be present to monitor gauges and the overfilling of bulk storage containers during delivery. Exceptions to the aforementioned requirements will apply under this condition: An environmental equivalency identified based on good engineering practices that is based on the professional judgment of the Professional Engineer who certified the Plan and has given consideration to industry standards. All liquid level sensing devices undergo tests to ensure proper operation. All movements/transfers of oil are manually controlled in the physical presence of a trained employee. All storage containers are situated such that they are in close proximity and view of daily operations conducted by facility employees. MR Environmental Inc Env1r<lrlmflfll.ll,OmJpalk>rwHMth& 'iolutioru Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 35 Appendix 4 Page 54 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC - 18511 Beaumont Hwy, Houston, TX 77049 3.2.9 Effluent Treatment Facilities There are no effluent treatment facilities in operation at the facility. 3.2.10 Visible Discharges Visible discharges from any container or appurtenance - including seams, gaskets, piping, pumps, valves, rivets, and bolts - are quickly corrected upon discovery. Any accumulation of oil is promptly removed from the secondary containment area. 3.2.11 Mobile and Portable Containers Any mobile or portable oil storage containers utilized at the facility are positioned so as to prevent spilled oil from reaching navigable waters. Mobile refueling containers do not require sized secondary containment. However, the general secondary containment requirements of 40 CFR 112.?(c), still apply. 3.3 Transfer Operations, Pumping, and In-Plant Processes Oil-containing piping that is placed out of service or is in standby service for an extended period of time is evacuated of oil and the terminal connection capped or blank flanged and marked as to origin. Oil containing pipe supports are maintained so as to minimize abrasion and corrosion and allow for expansion and contraction. All oil-service valves and piping are subjected to regular examinations by operating personnel at which time the general conditions of items, such as flange joints, expansion joints, valve glands and bodies, catch pans, pipeline supports, locking of valves and metal surfaces are addressed. A".R [l'l'ldronmantol Inc c,..,tn,nnwn , Oto,p,ati;, & Safl!II/ Solutlonl Two Riverway Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 36 Appendix 4 Page 55 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 PART IV - DISCHARGE RESPONSE This section describes the response and cleanup procedures in the event of an oil discharge. The uncontrolled discharge of oil to groundwater, surface water, or soil is prohibited. Immediate action will be taken to control, contain, and recover discharged oil. In general, the following steps are taken: Eliminate potential spark sources; If possible and safe to do so, identify and shut down source of the discharge to stop the flow; Contain the discharge with sorbents, berms, trenches, sandbags, or other material; Contact the authorized facility representative or his/her alternate; Contact regulatory authorities and the clean-up organization; and Collect and dispose of recovered products according to applicable regulations. For the purpose of establishing appropriate response procedures, this SPCC Plan classifies discharges as either "minor'' or "major," depending on the volume and characteristics of the material released. A list of emergency contacts is provided in Appendix H and posted at prominent locations throughout the facility. A discharge notification form is provided in Appendix I. A list of discharge response material kept at the facility is included in Appendix J. 4.1 Response to a Minor Discharge A "minor" discharge is defined as one that poses no significant harm (or threat) to human health and safety or to the environment. Minor discharges are generally those where: The quantity of product discharged is small (e.g., less than 10 gallons of oil); Discharged material is easily stopped and controlled at the time of the discharge; Discharge is localized near the source; MR& Envlronmental Inc nvlr .Oc l-wl!h&SofnySnlL'lffl1 Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 37 Appendix 4 Page 56 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 Discharged oil is not likely to reach water; There is minimal risk to human health or safety; and There is minimal risk of fire or explosion. Minor discharges can usually be cleaned up by facility personnel. The following guidelines apply: Immediately notify the authorized facility representative. Under the direction of the authorized facility representative, contain the discharge with discharge response materials and equipment. Place discharge debris in properly labeled waste containers. The authorized facility representative will complete the discharge notification form (Appendix I) and attach a copy to this SPCC Plan. If the discharge involves more than 25 gallons of oil spill on the ground, the authorized facility representative will contact the Texas Commission on Environmental Quality, Region 10, Beaumont (409-898-3838). 4.2 Response to a Major Discharge A "major" discharge is defined as one that cannot be safely controlled or cleaned up by facility personnel, such as when: The discharge is large enough to spread beyond the immediate discharge area; The discharged oil enters a storm drain or other water; The discharge requires special equipment or training to clean up; The discharged oil poses a hazard to human health or safety; or There is a danger of fire or explosion. In the event of a major discharge, the following guidelines apply: All workers will immediately evacuate the discharge site via designated exit routes and move to designated staging areas at a safe distance from the discharge. If the authorized facility representative is not present at the facility, the senior onsite person notifies the authorized facility representative of the discharge and has authority to initiate notification and response. MR Env1ronm"nr11.1 Inc (nvlron_.,q!Occupmk>NJHuth&'wfny'ialution, Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 38 Appendix 4 Page 57 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 The authorized facility representative (or senior on-site person) will obtain medical assistance if workers are injured. The authorized facility representative (or senior on-site person) will notify the Fire Department and Police Department. The authorized facility representative (or senior on-site person) will contact spill response and cleanup contractors. The authorized facility representative (or senior on-site person) will immediately contact the Texas Commission on Environmental Quality, Region 10, Beaumont (409-898-3838) and the National Response Center (800-424-8802). The authorized facility representative (or senior on-site person) will record the call on the Discharge Notification form in Appendix I and attach a copy to this SPCC Plan. The authorized facility representative (or senior on-site person) coordinates cleanup and obtains assistance from a cleanup contractor or other response organization as necessary. If the authorized facility representative is not available at the time of the discharge, then the next highest person in seniority assumes responsibility for coordinating response activities. 4.3 Waste Disposal Wastes resulting from an oil discharge response will be containerized in impervious bags, drums, or buckets. The authorized facility representative is responsible for ensuring that all wastes are properly characterized for disposal and that all spill-related waste is removed from the facility by a licensed waste hauler. All wastes recovered will be disposed in accordance with applicable regulations. MR Envlronmental Inc ElMronlTlffll.ll,Ocrupatlon,ll wlth&SifetySolU!ioos Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 39 Appendix 4 Page 58 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 4.4 Discharge Notification Any size discharge of oil that affects or threatens to affect navigable waters or adjoining shorelines will be reported immediately to the National Response Center (1-800424-8802). The NRC is staffed 24 hours a day. A summary sheet is included in Appendix I to facilitate reporting. The person reporting the discharge will provide the following information: Name, location, organization, and telephone number; Name and address of the party responsible for the incident; Date and time of the incident; Location of the incident; Source and cause of the release or discharge; Types of material(s) released or discharged; Quantity of materials released or discharged; Danger or threat posed by the release or discharge; Number and types of injuries (if any); Media affected or threatened by the discharge (i.e., water, land, air); Weather conditions at the incident location; Any other information that may help emergency personnel respond to the incident. Contact information for reporting a discharge to the appropriate authorities is listed in Appendix H and is also posted in prominent locations throughout the facility. In addition to the above reporting, 40 CFR 112.4 requires that information be submitted to the United States Environmental Protection Agency (EPA) Regional Administrator and the appropriate state agency in charge of oil pollution control activities (see contact information in Appendix H) whenever the facility discharges (as defined in 40 CFR 112.1(b)) more than 1,000 gallons of oil in a single event, or discharges (as defined in 40 CFR 112.1(b)) more than 42 gallons of oil in each of two discharge incidents within a MR Envlronmtntal Inc t.ll.OcaJpalon&IHM/l.h&5ah!rvSohnian1 Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 40 Appendix 4 Page 59 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 12-month period. The following information will be submitted to the EPA Regional Administrator and to TCEQ within 60 days: Name of the facility; Name of the owner/operator; Location of the facility; Maximum storage or handling capacity and normal daily throughput; Corrective action and Countermeasure taken, including a description of equipment repairs and replacements; Description of facility, including maps, flow diagrams, and topographical maps; Cause of the discharge(s) to navigable waters and adjoining shorelines, including a failure analysis of the system and subsystem in which the failure occurred; Additional preventive measures taken or contemplated to minimize possibility of recurrence; and Other pertinent information requested by the Regional Administrator. A standard report for submitting the information to the EPA Regional Administrator and to TCEQ is included in Appendix I of this Plan. MR nvlronmental Inc En,,ron ,Cluul>l(IDnllHsfth&'iffl!lySoluoonl Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC Appendix 4 Page 60 of 202 1994-2018 Page 41 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 APPENDIX A: SITE PLAN AND FACILITY DIAGRAM MR Envlronmcntal Inc Enworvnenul,Oca,paJon,IIHaah:h&Sm,tySnlutlons Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 42 Appendix 4 Page 61 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 FIGURE A-1: SITE PLAN. MR Environmental Inc rn...troMltnW,Ow,paioNJ HMl!h& Sdy SaluUai, Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493- RC Fax: (833) 771-AARC 1994-2018 Page 43 Appendix 4 Page 62 of 202 nolia_ (iard --- ... - .. . ...... . - 'in,111"" /_,,k(' 1'' " 11- .--....-, -... - Receiving BodylOf Water: San Jacinto River Tidal each Basin.: San Jacinto River -. t...... ,.,.. LEGEND Local Raad D Papulatian Center O Exit 6 Summit D Majar Connector Stale Roule US Highway Land c Point of lnlernt "I' Geographic F'ealure Woodland Small Town + Hospital City Park/Rnervalian w E lnter tale/Limiled Access Park Mega City t Cemetery Interstate/Unlimited Accns Waler Rh/Canal s Toll Highway -++- RaUroad ... Airport --- AirOeld Nature Environmental & Marine Services 18511 Beaumont Hwy. Houston, TX 77049 Prepared By: MK Envlronrnental. Inc. tn """'o<>l.al Occu a11on l ll.' tM& Sar,:, Sclu k-rs 01994 - 2018 Date: 05/29/2018 Drawn B : Nathan Dosher Visit B : Fidel R. Ru/ Appendix 4 Page 63 of 202 Nature Environmental & Marine Services 18511 Beaumont Hwy. Houston, TX 77049 Prepared By: MIS nvtronmental. Inc. En lro111nental, Occupallanal Health & safety Solullons 1994 - 2018 Appendix 4 Page 64 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 FIGURE A-2: FACILITY DIAGRAM MR Environmental inc Oro, Heillh& Solulb11 Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 44 Appendix 4 Page 65 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 FIGURE A-3: TANK AND CONTAINMENT DETAILS MR Envlr0nmt!nt1I Inc .,..,..._..,,..o.-,. ..... _.c.\.Nt Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 45 Appendix 4 Page 66 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 APPENDIX B: CERTIFICATION OF SUBSTANTIAL HARM CRITERIA FACILITY NAME: Nature Environmental and Marine Services, LLC FACILITY ADDRESS: 18511 Beaumont Hwy, Houston, TX 77049 1. Does the facility transfer oil over water to or from vessels and does the facility have a total oil storage capacity greater than or equal to 42,000 gallons? YES_ NO_x_ 2. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and does the facility lack secondary containment that is sufficiently large to contain the capacity of the largest aboveground oil storage tank plus sufficient freeboard to allow for precipitation within any aboveground oil storage tank area? YES_ NO_x_ 3. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance (as calculated using the formula in Attachment C-I11, Appendix C, 40 CFR 112 or a comparable formula) such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments? For further description of fish and wildlife and sensitive environments, see Appendices I, 11, and Ill to DOC/NOAA's "Guidance for Facility and Vessel Response Environments" (Section 10, Appendix E, 40 CFR 112 for availability) and the applicable Area Contingency Plan. YES_ NO_x_ 4. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance (as calculated using the appropriate formula Attachment C-III, Appendix C, 40 CFR 112 or a comparable formula) such that a discharge from the facility would shut down a public drinking water intake? YES_ NO_x_ 5. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and has the facility experienced a reportable oil spill in an amount greater or equal to 10,000 gallons within the last 5 years? YES_ NO_x_ Certification I certify under penalty of law that I have personally examined and am familiar with the information submitted in this document, and that based on my inquiry of those individuals responsible for obtaining this information, I believe that the submitted information is true, accurate, and complete. Mr. Corneli s Zuyderwijk CEO Name ..,/ Title ====, --= --- Signature Date MR Environmental Inc EnvlronnwuJ,O,JpatkwwHqlth&!iafeiySallltiMs Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 46 Appendix 4 Page 67 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 APPENDIX C: FACILITY INSPECTION CHECKLISTS The following checklists are to be used for monthly and annual facility-conducted inspections. Completed checklists will be signed by the inspector and maintained at the facility, with this SPCC Plan, for at least three years. MR Environmental Inc Ottu &Sill!tYSoluooni Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 47 Appendix 4 Page 68 of 202 --- (1 Environmental Inc Environmental, Occupational Health II, Safety Solutions Re!]i"1rn/ Offices: Austin, T:X (512)236-1110 Date of Inspection: 11/07/2018 Dallas, T>-' (2 I 4) 3 88-2272 El PflSO, T.::x (915) 533-.:2272 McAI len, rx (956) 682-6898 Mr. Cornelis Zuyderwijk CEO Nature Environmental & Marine Services, LLC 18511 Beaumont Hwy. Houston, TX 77049 San Antoni <>, TX (21O) 444-2272 ' RE: Monthly SPCC Inspection Report for November 2018 New Orlear1.s, LA (504) 392-2272 Miami, FL (305) 520-2272 Jacksonville, FL Dear Mr. Cornelis Zuyderwijk: Thank you for your time and cooperation during my recent visit to your facility for the required SPCC inspection. Enclosed is the monthly inspection report (in accordance with the requirements of 40 CFR 112.7 (e)) for the Nature Environmental & Marine Services, LLC facility located at 18511 Beaumont Hwy. for November 2018 conducted by AARC Environmental, Inc. The following report should be signed and inserted into the "Appendix C' of the Spill Prevention Control and Countermeasure (SPCC) Plan. (904) 722-22 72 Tallahassee, FL (850) 297-2272 Comments itemized in the inspection report indicate a non-conformance issue. This indicates that action is required to address a problem. Please review the comments in the monthly inspection checklist and address the issues immediately. Tampa, FL (813) 249-2272 AARC Environmental, Inc. conducts these inspections every month for your facility. If you have any questions, please do not hesitate to call us at (713) 974-2272. Washington,0.C. (202) 584-2272 New York, NY (212) 567-2272 Los Angeles, CA (213) 553-9309 Sincerely Anthony Carlton Environmental Specialist Albuquerque, NM (505) 254-2272 Nationwide: Tel: (833) 493-AARC Fax: (833) 771-AARC Corporate Office: Two Riverway Drive, Suite 1780, Houston, TX 77056 Tel: (713) 974-AARC Fax: (713) 339-AARC Appendix 4 Page 69 of 202 Regi ,111ul O.[fices: Austin, TX ( 5 I 2) 236-1 I I 0 Dalli1.s, TX (214) 388-2272 El Pa.so, TX (915} 533-2272 McAI Jen, TX (956) 682-6898 San nlonio, TX (210) 444-2272 Environmental Inc Environmental, Occupatlanal Health & Safety Solutions Date of Inspection: 10/24/2018 Mr. Cornelis Zuyderwijk CEO Nature Environmental & Marine Services, LLC 18511 Beaumont Hwy. Houston, TX 77049 RE: Monthly SPCC Inspection Report for October 2018 New Orleans, LA (504) 392-2272 tvtiami, FL (305) 520-2272 Jacksonville, FL (904) 722-2272 Tallahassee, FL (850) 297-2272 Tampa, FL (813) 249-2272 Dear Mr. Comelis Zuyderwijk: Thank you for your time and cooperation during my recent visit to your facility for the required SPCC inspection. Enclosed is the monthly inspection report (in accordance with the requirements of 40 CFR 112.7 (e)) for the Nature Environmental & Marine Services, LLC facility located at 18511 Beaumont Hwy. for October 2018 conducted by AARC Environmental, Inc. The following report should be signed and inserted into the "Appendix C' of the Spill Prevention Control and Countermeasure (SPCC) Plan. Comments itemized in the inspection report indicate a non-conformance issue. This indicates that action is required to address a problem. Please review the comments in the monthly inspection checklist and address the issues immediately. AARC Environmental, Inc. conducts these inspections every month for your facility. If you have any questions, please do not hesitate to call us at (713) 974-2272. Washington, D.C. (202) 5 84-2272 New York, NY (212) 567-2272 Los Angeles, CA (213) 553-9309 Sincerely, Max Rosenbaum Environmental Specialist Albt1querque, NM (505) 254-2272 Nationwide: Tel: (833) 493-AARC Fax: (833) 771-AARC Corporate Office: Two Riverway Drive, Suite 1780, Houston, TX 77056 Tel: (713) 974-AARC Fax: (713) 339-AARC Appendix 4 Page 70 of 202 Environmental Inc Environmental, Occupallonal Health & Safety Solutions Regional C?ffice.\: Austin, TX (512) 236-1 110 Date oflnspection: 09/24/2018 Dallas, 'TX (214) 388-2272 El Paso, TX (915) 533-2272 McAllen, TX Mr. Cornelis Zuyderwijk CEO Nature Environmental & Marine Services, LLC 18511 Beaumont Hwy. Houston, TX 77049 (956) 682-6898 San Antonio, TX (210) 444-2272 RE: Monthly SPCC Inspection Report for September 2018 New Orleans, LA (504) 392-2272 Miami, FL (305) 520-2272 Jacksonville, FL Dear Mr. Cornelis Zuyderwijk: 'Thank you for your time and cooperation during my recent visit to your facility for the required SPCC inspection. Enclosed is the monthly inspection report (in accordance with the requirements of 40 CFR 112.7 (e)) for the Nature Environmental & Marine Services, LLC facility located at 18511 Beaumont Hwy. for September 2018 conducted by AARC Environmental, Inc. The following report should be signed and inserted into the "Appendix ' of the pill Prevention Control and Countermeasure (SPCC) Plan. (904) 722-2272 Tallahassee, FL (850) 297-2272 Comments itemized in the inspection report indicate a non-conformance issue. This indicates that action is required to address a problem. Please review the comments in the monthly inspection checklist and address the issues immediately. Tampa, FL (813) 249-2272 AARC Environmental, Inc. conducts these inspections every month for your facility. If you have any questions, please do not hesitate to call us at (713) 974-2272. Washington, D.C. (202) 584-2272 New York, NY (212) 567-2272 Sincerely, Los Angeles, CA (213) 553-9309 Anthony Carlton Environmental Specialist Albuquerque, NM (505) 254-2272 Nationwide: Tel: (833) 493-AARC Fax: (833) 771-AARC Corpomte Office: Two Riverway Drive, Suite 1780, Houston, TX 77056 Tel: (7 I 3) 974-AARC Fax: (713) 339-AARC Appendix 4 Page 71 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 STI/SPFA SP001 Annual Inspection Checklist MR Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: ,E...,n_..v...,lor,;o,...n,._m,..,.., .n..t,"l"l""'Inc Tel: (833) 493-AARC Fax: (833) 771-AARC Appendix 4 Page 72 of 202 1994-2018 Page 48 STI SP00l Annual Inspection Checklist General Ins ection Information: Inspection Date: Inspector Name (print): Inspector's Signature Prior Inspection Date: _ Retain until date: Title: Tank(s) inspected ID _ Regulatory facility name and ID number (if applicable) Nature Environmental & Marine Services, LLC 1'1umber _ _ [ID Inspection Guidance: For equipment not included in this Standard, follow the manufacturer recommended inspection/testing schedules and procedures. The periodic AST Inspection is intended for monitoring the external AST condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector per paragraph 4.1.2 of the standard. Remove promptly standing water or liquid in the primary tank, secondary containment area, interstice, or spill container. Before discharge to the environment, inspect the liquid for regulated products or other contaminants and disposed of it properly. In order to comply with EPA SPCC (Spill Prevention, Control and Countermeasure) rules, a facility must regularly test liquid level sensing devices to ensure proper operation (40 CFR 112.8(c)(8)(v)). (*) designates an item in a non-conformance status. This indicates that action is required to address a problem. Non-conforming items important to tank or containment integrity require evaluation by an engineer experienced in AST design, a Certified Inspector, or a tank manufacturer who will determine the corrective action. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. Complete this checklist on an annual basis supplemental to the owner monthly-performed inspection checklists. Note: If a change has occurred to the tank system or containment that may affect the SPCC plan, the condition should be evaluated against the current plan requirement by a Professional Engineer knowledgeable in SPCC development and implementation. Item Free of tank settlement or foundation 1 washout? Concrete pad or ring wall free of 2 cracking and spalling? 3 Tank supports in satisfactory condition? Is water able to drain away from tank if 4 tank is resting on a foundation or on the ground? Is the grounding strap between the tank 5 and foundation/supports in good condition? 6 Free of visible signs of coating failure? Free of noticeable distortions, buckling, 7 denting, or bulging? 8 Free of standing water on roof? Are all labels and tags intact and 9 legible? Flanged connection bolts tight and fully 10 engaged with no sign of wear or corrosion? 11 Normal and emergency vents free of Status Tank Foundation/Supports Yes No Yes No NIA Yes No NIA Yes No NIA Comments/ Date Corrected Yes No NIA Tank Shell, Heads and Roof Yes No Yes No Yes No NIA Yes No Tank Manways, Pi i,ing, and Equipment Yes No NIA Tank Equipment Yes No Annual Checklist 1 Appendix 4 Page 73 of 202 12 13 14 15 16 17 18 19 20 21 Item obstructions? Normal vent on tanks storing gasoline equipped with pressure/vacuum vent? Are flame arrestors free of corrosion and are air passages free of blockage? Is the emergency vent in good working condition and functional, as required by manufacturer? Consult manufacturer's requirements. Verify that components are moving freely (including long-bolt manwavs). Is interstitial leak detection equipment in good condition? Are windows on sight gauges clear? Are wire connections intact? If equipment has a test function, does it activate to confirm operation? Are all valves free of leaks, corrosion and other damage? Follow manufacturers' instructions for regular maintenance of these items. Check the following and verify (as applicable): Anti-siphon valve Check valve Gate valve Pressure regulator valve Expansion relief valve Solenoid valve Fire valve Shear valve Are strainers and filters clean and in good condition? Free of missing insulation? Insulation free of visible signs of damage? Insulation adequately protected from water intrusion? Insulation free of noticeable areas of moisture? Insulation free of mold? Free of visible signs of coating failure? Is inventory control being performed 22 and documented if required? Is release detection being performed 23 and documented if required? Are electrical wiring and boxes in good 24 condition? Has the cathodic protection system on 25 the tank been tested as required by the designing engineer? Status Yes No NIA Yes No NIA Yes No NIA Yes No NIA Comments / Date Corrected Yes No NIA Yes No NIA Yes No NIA Yes No NIA Yes No NIA Yes No NIA Yes No NIA Yes No NIA Yes No NIA Insulated Tanks Yes No NIA Yes No NIA Yes No NIA Yes No NIA Tank/ Piping Release Detection Yes No NIA Yes No NIA Other Equipment Yes No NIA Yes No NIA Annual Checklist 2 Appendix 4 Page 74 of 202 Additional Comments: Annual Checklist 3 Appendix 4 Page 75 of 202 STI SP00l Annual Inspection Checklist General Ins ection Information: Inspection Date: Inspector Name (print): Inspector's Signature Tank(s) inspected ID Prior Inspection Date: _ Retain until date: Title: _ Regulatory facility name and ID number (if applicable) Nature Environmental & Marine Services, LLC Number] _ _ [ID Inspection Guidance: For equipment not included in this Standard, follow the manufacturer recommended inspection/testing schedules and procedures. The periodic AST Inspection is intended for monitoring the external AST condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector per paragraph 4.1.2 of the standard. Remove promptly standing water or liquid in the primary tank, secondary containment area, interstice, or spill container. Before discharge to the environment, inspect the liquid for regulated products or other contaminants and disposed of it properly. In order to comply with EPA SPCC (Spill Prevention, Control and Countermeasure) rules, a facility must regularly test liquid level sensing devices to ensure proper operation (40 CFR 112.8(c)(8)(v)). (*) designates an item in a non-conformance status. This indicates that action is required to address a problem. Non-conforming items important to tank or containment integrity require evaluation by an engineer experienced in AST design, a Certified Inspector, or a tank manufacturer who will determine the corrective action. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. Complete this checklist on an annual basis supplemental to the owner monthly-performed inspection checklists. Note: If a change has occurred to the tank system or containment that may affect the SPCC plan, the condition should be evaluated against the current plan requirement by a Professional Engineer knowledgeable in SPCC development and implementation. Item Free of tank settlement or foundation 1 washout? 2 Concrete pad or ring wall free of cracking and spalling? 3 Tank supports in satisfactory condition? Is water able to drain away from tank if 4 tank is resting on a foundation or on the ground? Is the grounding strap between the tank 5 and foundation/supports in good condition? 6 Free of visible signs of coating failure? Free of noticeable distortions, buckling, 7 denting, or bulging? 8 Free of standing water on roof? Are all labels and tags intact and 9 legible? Flanged connection bolts tight and fully 10 engaged with no sign of wear or corrosion? 11 Normal and emergency vents free of Status Tank Foundation/Supports Yes No Yes No NIA Yes No NIA Yes No NIA Comments/ Date Corrected Yes No NIA Tank Shell, Heads and Roof Yes No Yes No Yes No NIA Yes No Tank Manwavs, Piping, and Equipment Yes No NIA Tank Equipment Yes No Annual Checklist 1 Appendix 4 Page 76 of 202 12 ") 13 14 15 16 17 18 19 20 21 Item obstructions? Normal vent on tanks storing gasoline equipped with pressure/vacuum vent? Are flame arrestors free of corrosion and are air passages free of blockage? Is the emergency vent in good working condition and functional, as required by manufacturer? Consult manufacturer's requirements. Verify that components are moving freely (including long-bolt man ways). Is interstitial leak detection equipment in good condition? Are windows on sight gauges clear? Are wire connections intact? If equipment has a test function, does it activate to confirm operation? Are all valves free of leaks, corrosion and other damage? Follow manufacturers' instructions for regular maintenance of these items. Check the following and verify (as applicable): Anti-siphon valve Check valve Gate valve Pressure regulator valve Expansion relief valve Solenoid valve Fire valve Shear valve Are strainers and filters clean and in good condition? Free of missing insulation? Insulation free of visible signs of damage? Insulation adequately protected from water intrusion? Insulation free of noticeable areas of moisture? Insulation free of mold? Free of visible signs of coating failure? Is inventory control being performed 22 and documented if required? Is release detection being performed 23 and documented if required? Are electrical wiring and boxes in good 24 condition? Has the cathodic protection system on 25 the tank been tested as required by the designing engineer? Status Yes No NIA Yes No NIA Yes No NIA Yes No NIA Comments / Date Corrected Yes No NIA Yes No NIA Yes No NIA Yes No NIA Yes No NIA Yes No NIA Yes No NIA Yes No NIA Yes No NIA Insulated Tanks Yes No NIA Yes No NIA Yes No NIA Yes No NIA Tank/ Piping Release Detection Yes No NIA Yes No NIA Other Equipment Yes No NIA Yes No NIA Annual Checklist 2 Appendix 4 Page 77 of 202 Additional Comments: Annual Checklist 3 Appendix 4 Page 78 of 202 STI SP00l Annual Inspection Checklist General Ins ection Information: Inspection Date: Inspector Name (print): Inspector's Signature Tank(s) inspected ID Prior Inspection Date: Retain until date: Title: Regulatory facility name and ID number (if applicable) Nature Environmental & Marine Services, LLC umber Inspection Guidance: For equipment not included in this Standard, follow the manufacturer recommended inspection/testing schedules and procedures. The periodic AST Inspection is intended for monitoring the external AST condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector per paragraph 4.1.2 of the standard. Remove promptly standing water or liquid in the primary tank, secondary containment area, interstice, or spill container. Before discharge to the environment, inspect the liquid for regulated products or other contaminants and disposed of it properly. In order to comply with EPA SPCC (Spill Prevention, Control and Countermeasure) rules, a facility must regularly test liquid level sensing devices to ensure proper operation (40 CFR 112.8(c)(8)(v)). (*) designates an item in a non-conformance status. This indicates that action is required to address a problem. Non-conforming items important to tank or containment integrity require evaluation by an engineer experienced in AST design, a Certified Inspector, or a tank manufacturer who will determine the corrective action. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. Complete this checklist on an annual basis supplemental to the owner monthly-performed inspection checklists. Note: If a change has occurred to the tank system or containment that may affect the SPCC plan, the condition should be evaluated against the current plan requirement by a Professional Engineer knowledgeable in SPCC development and implementation. Item Free of tank settlement or foundation 1 washout? Concrete pad or ring wall free of 2 cracking and spalling? 3 Tank supports in satisfactory condition? Is water able to drain away from tank if 4 tank is resting on a foundation or on the ground? Is the grounding strap between the tank 5 and foundation/supports in good condition? 6 Free of visible signs of coating failure? Free of noticeable distortions, buckling, 7 denting, or bulging? 8 Free of standing water on roof? Are all labels and tags intact and 9 legible? Flanged connection bolts tight and fully 10 engaged with no sign of wear or corrosion? 11 Normal and emergency vents free of Status Tank Foundation/Supports Yes No Yes No NIA Yes No NIA Yes No NIA Comments / Date Corrected Yes No NIA Tank Shell, Heads and Roof Yes No Yes No Yes No NIA Yes No Tank Manways, Piping, and Equipment Yes No NIA Tank Equipment Yes No Annual Checklist 1 Appendix 4 Page 79 of 202 12 13 14 15 16 17 18 19 20 21 Item obstructions? Normal vent on tanks storing gasoline equipped with pressure/vacuum vent? Are flame arrestors free of corrosion and are air passages free of blockage? Is the emergency vent in good working condition and functional, as required by manufacturer? Consult manufacturer's requirements. Verify that components are moving freely (including long-bolt manwavs). Is interstitial leak detection equipment in good condition? Are windows on sight gauges clear? Are wire connections intact? If equipment has a test function, does it activate to confirm operation? Are all valves free of leaks, corrosion and other damage? Follow manufacturers' instructions for regular maintenance of these items. Check the following and verify (as applicable): o Anti-siphon valve o Check valve Gate valve o Pressure regulator valve Expansion relief valve Solenoid valve Fire valve Shear valve Are strainers and filters clean and in good condition? Free of missing insulation? Insulation free of visible signs of damage? Insulation adequately protected from water intrusion? Insulation free of noticeable areas of moisture? Insulation free of mold? Free of visible signs of coating failure? Is inventory control being performed 22 and documented if required? Is release detection being performed 23 and documented if required? Are electrical wiring and boxes in good 24 condition? Has the cathodic protection system on 25 the tank been tested as required by the designing engineer? Status Yes No NIA Yes No NIA Yes No NIA Yes No NIA Comments / Date Corrected Yes No NIA Yes No NIA Yes No NIA Yes No NIA Yes No NIA Yes No NIA Yes No NIA Yes No NIA Yes No NIA Insulated Tanks Yes No NIA Yes No NIA Yes No NIA Yes No NIA Tank / Piping Release Detection Yes No NIA Yes No NIA Other Equipment Yes No NIA Yes No NIA Annual Checklist 2 Appendix 4 Page 80 of 202 Additional Comments: Annual Checklist 3 Appendix 4 Page 81 of 202 STI SP00l Annual Inspection Checklist General Ins ctio11 Information: Inspection Date: _ Prior Inspection Date: Retain until date: Inspector Name (print): _ Title: _ Inspector's Signature _ Tank(s) inspected ID Regulatory facility name and ID number (if applicable) Nature Environmental & Marine Services, LLC [ID f\Jumber Inspection Guidance: For equipment not included in this Standard, follow the manufacturer recommended inspection/testing schedules and procedures. The periodic AST Inspection is intended for monitoring the external AST condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector per paragraph 4.1.2 of the standard. Remove promptly standing water or liquid in the primary tank, secondary containment area, interstice, or spill container. Before discharge to the environment, inspect the liquid for regulated products or other contaminants and disposed of it properly. In order to comply with EPA SPCC (Spill Prevention, Control and Countermeasure) rules, a facility must regularly test liquid level sensing devices to ensure proper operation (40 CFR 112.8(c)(8)(v)). (*) designates an item in a non-conformance status. This indicates that action is required to address a problem. Non-conforming items important to tank or containment integrity require evaluation by an engineer experienced in AST design, a Certified Inspector, or a tank manufacturer who will determine the corrective action. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. Complete this checklist on an annual basis supplemental to the owner monthly-performed inspection checklists. Note: If a change has occurred to the tank system or containment that may affect the SPCC plan, the condition should be evaluated against the current plan requirement by a Professional Engineer knowledgeable in SPCC development and implementation. Item Free of lank settlement or foundation 1 washout? Concrete pad or ring wall free of 2 cracking and spalling? 3 Tank supports in satisfactory condition? Is water able lo drain away from tank if 4 tank is resting on a foundation or on the ground? Is the grounding strap between the tank 5 and foundation/supports in good condition? 6 Free of visible signs of coaling failure? Free of noticeable distortions, buckling, 7 denting, or bulging? 8 Free of standing water on roof? Are all labels and tags intact and 9 legible? Flanged connection bolts tight and fully 10 engaged with no sign of wear or corrosion? 11 Normal and emergency vents free of Status Tank Foundation/Supports Yes No Yes No NIA Yes No NIA Yes No NIA Comments / Date Corrected Yes No NIA Tank Shell, Heads and Roof Yes No Yes No Yes No NIA Yes No Tank Manways, Piping, and Equipment Yes No NIA Tank Equipment Yes No Annual Checklist 1 Appendix 4 Page 82 of 202 12 13 14 15 16 17 18 19 20 21 Item obstructions? Normal vent on tanks storing gasoline equipped with pressure/vacuum vent? Are flame arrestors free of corrosion and are air passages free of blockage? Is the emergency vent in good working condition and functional, as required by manufacturer? Consult manufacturer's requirements. Verify that components are moving freely (including long-bolt manwavs). Is interstitial leak detection equipment in good condition? Are windows on sight gauges clear? Are wire connections intact? If equipment has a test function, does it activate to confirm operation? Are all valves free of leaks, corrosion and other damage? Follow manufacturers' instructions for regular maintenance of these items. Check the following and verify (as applicable): Anti-siphon valve Check valve Gate valve Pressure regulator valve Expansion relief valve Solenoid valve Fire valve Shear valve Are strainers and filters clean and in good condition? Free of missing insulation? Insulation free of visible signs of damage? Insulation adequately protected from water intrusion? Insulation free of noticeable areas of moisture? Insulation free of mold? Free of visible signs of coating failure? Is inventory control being performed 22 and documented if required? Is release detection being performed 23 and documented if required? Are electrical wiring and boxes in good 24 condition? Has the cathodic protection system on 25 the tank been tested as required by the designing engineer? Status Yes No NIA Yes No NIA Yes No NIA Yes No NIA Comments / Date Corrected Yes No NIA Yes No NIA Yes No NIA Yes No NIA Yes No NIA Yes No NIA Yes No NIA Yes No NIA Yes No NIA Insulated Tanks Yes No NIA Yes No NIA Yes No NIA Yes No NIA Tank/ Piping Release Detection Yes No NIA Yes No NIA Other Equipment Yes No NIA Yes No NIA Annual Checklist 2 Appendix 4 Page 83 of 202 n Additional Comments: Annual Checklist 3 Appendix 4 Page 84 of 202 STI SP00l Annual Inspection Checklist General ln ection Information: Inspection Date: Inspector Name (print): Inspector's Signature Prior Inspection Date: Retain until date: Title: Tank(s) inspected ID Regulatory facility name and ID number (if applicable) Nature Environmental & Marine Services, LLC Number _ [ID Inspection Guidance: For equipment not included in this Standard, follow the manufacturer recommended inspection/testing schedules and procedures. The periodic AST Inspection is intended for monitoring the external AST condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector per paragraph 4.1.2 of the standard. Remove promptly standing water or liquid in the primary tank, secondary containment area, interstice, or spill container. Before discharge to the environment, inspect the liquid for regulated products or other contaminants and disposed of it properly. In order to comply with EPA SPCC (Spill Prevention, Control and Countermeasure) rules, a facility must regularly test liquid level sensing devices to ensure proper operation (40 CFR 112.S(c)(S)(v)). (*) designates an item in a non-conformance status. This indicates that action is required to address a problem. Non-conforming items important to tank or containment integrity require evaluation by an engineer experienced in AST design, a Certified Inspector, or a tank manufacturer who will determine the corrective action. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. Complete this checklist on an annual basis supplemental to the owner monthly-performed inspection checklists. Note: If a change has occurred to the tank system or containment that may affect the SPCC plan, the condition should be evaluated against the current plan requirement by a Professional Engineer knowledgeable in SPCC development and implementation. Item Free of tank settlement or foundation 1 washout? Concrete pad or ring wall free of 2 cracking and spalling? 3 Tank supports in satisfactory condition? Is water able to drain away from tank if 4 tank is resting on a foundation or on the ground? Is the grounding strap between the lank 5 and foundation/supports in good condition? 6 Free of visible signs of coating failure? Free of noticeable distortions, buckling, 7 denting, or bulging? 8 Free of standing water on roof? Are all labels and tags intact and 9 legible? Flanged connection bolts tight and fully 10 engaged with no sign of wear or corrosion? 11 Normal and emergency vents free of Annual Checklist Status Tank Foundation/Suooorts Yes No Yes No NIA Yes No NIA Yes No NIA Comments / Date Corrected Yes No NIA Tank Shell, Heads and Roof Yes No Yes No Yes No NIA Yes No Tank Manways, Piping, and Equipment Yes No NIA Tank Equipment Yes No Appendix 4 Page 85 of 202 l'.2 13 14 15 16 17 18 19 20 21 Item obstructions? Normal vent on tanks storing gasoline equipped with pressure/vacuum vent? Are flame arrestors free of corrosion and are air passages free of blockage? Is the emergency vent in good working condition and functional, as required by manufacturer? Consult manufacturer's requirements. Verify that components are moving freely (including long-bolt manways). Is interstitial leak detection equipment in good condition? Are windows on sight gauges clear? Are wire connections intact? If equipment has a test function, does it activate to confirm operation? Are all valves free of leaks, corrosion and other damage? Follow manufacturers' instructions for regular maintenance of these items. Check the following and verify (as applicable): o Anti-siphon valve o Check valve o Gate valve Pressure regulator valve o Expansion relief valve o Solenoid valve Fire valve o Shear valve Are strainers and filters clean and in good condition? Free of missing insulation? Insulation free of visible signs of damage? Insulation adequately protected from water intrusion? Insulation free of noticeable areas of moisture? Insulation free of mold? Free of visible signs of coaling failure? Is inventory control being performed 22 and documented if required? Is release detection being performed 23 and documented if required? Are electrical wiring and boxes in good 24 condition? Has the cathodic protection system on 25 the tank been tested as required by the designing engineer? Status Yes No N/A Yes No N/A Yes No N/A Yes No N/A Comments / Date Corrected Yes No oN/A Yes No oN/A Yes No N/A Yes No N/A Yes No N/A Yes No NIA Yes No NIA Yes No N/A Yes No NIA Insulated Tanks Yes No N/A Yes No N/A Yes No NIA Yes No N/A Tank/ Piping Release Detection Yes No NIA Yes No N/A Other Equipment Yes No NIA Yes No NIA Annual Checklist 2 Appendix 4 Page 86 of 202 Additional Comments: Annual Checklist 3 Appendix 4 Page 87 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 STI/SPFA SP001 Monthly Inspection Checklist A'II EnvlronmentaJ Inc (nvvM ,OcwpationalHYll:h&Safef"fSdlJ9001 Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 49 Appendix 4 Page 88 of 202 STI SP00l Monthly Inspection Checklist General Ins ection Information: Inspection Date: Inspector Name (print): Inspector's Signature Tank(s) inspected ID Prior Inspection Date: Retain until date: Title: _ Regulatory facility name and ID number (if applicable) Nature Environmental & Marine Services, LLC [ID Number Inspection Guidance: Inspections of multiple tanks may be captured on one form as long as the tanks are substantially the same. For equipment not included in this Standard, follow the manufacturer recommended inspection/testing schedules and procedures. The periodic AST Inspection is intended for monitoring the external AST condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector per paragraph 4.1.2 of the standard. Upon discovery of water in the primary tank, secondary containment area, interstice, or spill container, remove promptly or take other corrective action. Inspect the liquid for regulated products or other contaminants and dispose of properly. Non-conforming items important to tank or containment integrity require evaluation by an engineer experienced in AST design, a Certified Inspector, or a tank manufacturer who will determine the corrective action. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. After severe weather (snow, ice, wind storms) or maintenance (such as coating) that could affect the operation of critical components (normal and emergency vents, valves), an inspection of these components is required as soon as the equipment is safely accessible after the event. 1 2 3 4 5 6 7 8 Item Is tank exterior (roof, shell, heads, bottom, connections, fittings, valves, etc.) free of visible leaks? Note: If "No", identify tank and describe leak and actions taken. Is the tank liquid level gauge legible and in good working condition? Is the area around the tank (concrete surfaces, ground, containment, etc.) free of visible signs of leakage? Is the primary tank free of water or has another preventative measure been taken? NOTE: Refer to paragraphs 6.10 and 6.11 of the standard for alternatives for Category 1 tanks. NIA is only appropriate for these alternatives. For double-wall or double bottom tanks or CE-ASTs, is interstitial monitoring equipment (where applicable) in good working condition? For double-wall tanks or double bottom tanks or CE-ASTs, is interstice free of liquid? Remove the liquid if it is found. If tank product is found, investigate possible leak. If overfill equipment has a "test" button, does it activate the audible horn or light to confirm operation? If battery operated, replace battery if needed. Is overfill prevention equipment in good working condition? If it is equipped with a mechanical test mechanism, actuate the Status Tank and Piping Yes No Yes No NIA Yes No Comments / Date Corrected Yes No NIA Yes No NIA Yes No NIA Equipment on tank Yes No NIA Yes No NIA Monthly Checklist 1 Appendix 4 Page 89 of 202 9 10 11 12 13 14 15 16 17 17 Item mechanism to confirm operation. Is the spill container (spill bucket) empty, free of visible leaks and in good working condition? Are piping connections to the tank (valves, fittings, pumps, etc.) free of visible leaks? Note: If "No", identify location and describe leak. Do the ladders/platforms/walkways appear to be secure with no sign of severe corrosion or damage? Is the containment free of excess liquid, debris, cracks, corrosion, erosion, fire hazards and other integrity issues? Status Yes No NIA Yes No Yes No NIA Containment Yes No NIA Comments / Date Corrected Are dike drain valves closed and in good working condition? Yes No NIA Are containment egress pathways clear and any gates/doors operable? Yes No NIA Concrete Exterior AST (CE-AST) Inspect all sides for cracks in concrete. Are there any cracks in the concrete exterior larger than 1/16"? Yes No NIA Inspect concrete exterior body of the tank for cleanliness, need of coating, or rusting where applicable. Tank exterior in acceptable condition? Yes No NIA Visual inspect all tank top openings including nipples, manways, tank top overfill containers, and leak detection tubes. Is the sealant between all tank top openings and concrete intact and in good condition? Yes No NIA Other Conditions Is the system free of any other conditions that need to be addressed for continued safe operation? Yes No Additional Comments: Monthly Checklist 2 Appendix 4 Page 90 of 202  Monthly Checklist 3 Appendix 4 Page 91 of 202 STI SP00l Monthly Inspection Checklist General Ins ection Information: Inspection Date: Inspector Name (print): Inspector's Signature Tank(s) inspected ID Prior Inspection Date: Retain until date: Title: _ _ Regulatory facility name and ID number (if applicable) Nature Environmental & Marine Services, LLC [ID Number Inspection Guidance: Inspections of multiple tanks may be captured on one form as long as the tanks are substantially the same. For equipment not included in this Standard, follow the manufacturer recommended inspection/testing schedules and procedures. The periodic AST Inspection is intended for monitoring the external AST condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector per paragraph 4.1.2 of the standard. Upon discovery of water in the primary tank, secondary containment area, interstice, or spill container, remove promptly or take other corrective action. Inspect the liquid for regulated products or other contaminants and dispose of properly. Non-conforming items important to tank or containment integrity require evaluation by an engineer experienced in AST design, a Certified Inspector, or a tank manufacturer who will determine the corrective action. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. After severe weather (snow, ice, wind storms) or maintenance (such as coating) that could affect the operation of critical components (normal and emergency vents, valves), an inspection of these components is required as soon as the equipment is safely accessible after the event. 1 2 Item Is tank exterior (roof, shell, heads, bottom, connections, fittings, valves, etc.) free of visible leaks? Note: If "No", idenlifiJ tank and describe leak and actions taken. Is the tank liquid level gauge legible and in good working condition? Is the area around the tank (concrete 3 surfaces, ground, containment, etc.) free of visible signs of leakage? Is the primary tank free of water or has another preventative measure been taken? NOTE: Refer to paragraphs 6.10 and 6.11 of 4 the standard for alternatives for Category 1 tanks. NIA is only appropriate for these alternatives. For double-wall or double bottom tanks or CE-ASTs, is interstitial monitoring 5 equipment (where applicable) in good working condition? For double-wall tanks or double bottom tanks or CE-ASTs, is interstice free of liquid? 6 Remove the liquid if it is found. If tank product is found, investigate possible leak. 7 If overfill equipment has a "test" button, does it activate the audible horn or light to confirm operation? If battery operated, replace battery if needed. 8 Is overfill prevention equipment in good working condition? If it is equipped with a mechanical test mechanism, actuate the Status Tank and Piping Yes No Yes No NIA Yes No Comments / Date Corrected Yes No NIA Yes No NIA Yes No NIA Equipment on tank Yes No NIA Yes No NIA Monthly Checklist 1 Appendix 4 Page 92 of 202 9 10 11 12 13 14 15 16 17 17 Item mechanism to confirm operation. Is the spill container (spill bucket) empty, free of visible leaks and in good working condition? Are piping connections to the tank (valves, fittings, pumps, etc.) free of visible leaks? Note: If "No", identify location and describe leak. Do the ladders/platforms/walkways appear to be secure with no sign of severe corrosion or damage? Is the containment free of excess liquid, debris, cracks, corrosion, erosion, fire hazards and other integrity issues? Are dike drain valves closed and in good working condition? Status Yes No NIA Yes No Yes No NIA Containment Yes No NIA Yes No NIA Comments / Date Corrected Are containment egress pathways clear and any gates/doors operable? Yes No NIA Concrete Exterior AST (CE-AST) Inspect all sides for cracks in concrete. Are there any cracks in the concrete exterior larger than 1/16"? Yes No NIA Inspect concrete exterior body of the tank for cleanliness, need of coating, or rusting where applicable. Tank exterior in acceptable condition? Yes No NIA Visual inspect all tank top openings including nipples, manways, tank top overfill containers, and leak detection tubes. Is the sealant between all tank top openings and concrete intact and in good condition? Yes No NIA Other Conditions Is the system free of any other conditions that need to be addressed for continued safe operation? Yes No Additional Comments: Monthly Checklist 2 Appendix 4 Page 93 of 202  Monthly Checklist 3 Appendix 4 Page 94 of 202 STI SP00l Monthly Inspection Checklist General Ins ection Information: Inspection Date: _ Inspector Name (print): Prior Inspection Date: _ Retain until date: Title: Inspector's Signature Tank(s) inspected ID _ Regulatory facility name and ID number (if applicable) Nature Environmental & Marine Services, LLC Number _ [ID Inspection Guidance: Inspections of multiple tanks may be captured on one form as long as the tanks are substantially the same. For equipment not included in this Standard, follow the manufacturer recommended inspection/testing schedules and procedures. The periodic AST Inspection is intended for monitoring the external AST condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector per paragraph 4.1.2 of the standard. Upon discovery of water in the primary tank, secondary containment area, interstice, or spill container, remove promptly or take other corrective action. Inspect the liquid for regulated products or other contaminants and dispose of properly. Non-conforming items important to tank or containment integrity require evaluation by an engineer experienced in AST design, a Certified Inspector, or a tank manufacturer who will determine the corrective action. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. After severe weather (snow, ice, wind storms) or maintenance (such as coating) that could affect the operation of critical components (normal and emergency vents, valves), an inspection of these components is required as soon as the equipment is safely accessible after the event. 1 2 3 4 5 6 Item Is tank exterior (roof, shell, heads, bottom, connections, fittings, valves, etc.) free of visible leaks? Note: If "No", identifiJ tank and describe leak and actions taken. Is the tank liquid level gauge legible and in good working condition? Is the area around the tank (concrete surfaces, ground, containment, etc.) free of visible signs of leakage? Is the primary tank free of water or has another preventative measure been taken? NOTE: Refer to paragraphs 6.10 and 6.11 of the standard for alternatives for Category 1 tanks. N/A is only appropriate for these alternatives. For double-wall or double bottom tanks or CE-ASTs, is interstitial monitoring equipment (where applicable) in good working condition? For double-wall tanks or double bottom tanks or CE-ASTs, is interstice free of liquid? Remove the liquid if it is found. If tank product is found, investigate possible leak. 7 If overfill equipment has a "test'' button, does it activate the audible horn or light to confirm operation? If battery operated, replace battery if needed. 8 Is overfill prevention equipment in good working condition? If it is equipped with a mechanical test mechanism, actuate the Status Tank and Piping Yes No Yes No NIA Yes No Comments / Date Corrected Yes No NIA Yes No NIA Yes No NIA Equipment on tank Yes No NIA Yes No NIA Monthly Checklist 1 Appendix 4 Page 95 of 202 9 10 11 12 13 14 15 16 17 17 Item mechanism to confirm operation. ls the spill container (spill bucket) empty, free of visible leaks and in good working condition? Are piping connections to the tank (valves, fittings, pumps, etc.) free of visible leaks? Note: If "No", identify location and describe leak. Do the ladders/platforms/walkways appear to be secure with no sign of severe corrosion or damage? ls the containment free of excess liquid, debris, cracks, corrosion, erosion, fire hazards and other integrity issues? Status Yes No NIA Yes No Yes No NIA Containment Yes No NIA Comments / Date Corrected Are dike drain valves closed and in good working condition? Yes No NIA Are containment egress pathways clear and any gates/doors operable? Yes No NIA Concrete Exterior AST (CE-AST) Inspect all sides for cracks in concrete. Are there any cracks in the concrete exterior larger than 1/16"? Yes No NIA Inspect concrete exterior body of the tank for cleanliness, need of coating, or rusting where applicable. Tank exterior in acceptable condition? Yes No NIA Visual inspect all tank top openings including nipples, manways, tank top overfill containers, and leak detection tubes. ls the sealant between all tank top openings and concrete intact and in good condition? Yes No NIA Other Conditions ls the system free of any other conditions that need to be addressed for continued safe operation? Yes No Additional Comments: Monthly Checklist 2 Appendix 4 Page 96 of 202  Monthly Checklist 3 Appendix 4 Page 97 of 202 STI SP00l Monthly Inspection Checklist General Ins ection Information: Inspection Date: Inspector Name (print): Inspector's Signature Tank(s) inspected ID Prior Inspection Date: _ Retain until date: Title: Regulatory facility name and ID number (if applicable) Nature Environmental & Marine Services, LLC [ID Number Inspection Guidance: Inspections of multiple tanks may be captured on one form as long as the tanks are substantially the same. For equipment not included in this Standard, follow the manufacturer recommended inspection/testing schedules and procedures. The periodic AST Inspection is intended for monitoring the external AST condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector per paragraph 4.1.2 of the standard. Upon discovery of water in the primary tank, secondary containment area, interstice, or spill container, remove promptly or take other corrective action. Inspect the liquid for regulated products or other contaminants and dispose of properly. Non-conforming items important to tank or containment integrity require evaluation by an engineer experienced in AST design, a Certified Inspector, or a tank manufacturer who will determine the corrective action. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. After severe weather (snow, ice, wind storms) or maintenance (such as coating) that could affect the operation of critical components (normal and emergency vents, valves), an inspection of these components is required as soon as the equipment is safely accessible after the event. 1 Item Is tank exterior (roof, shell, heads, bottom, connections, fittings, valves, etc.) free of visible leaks? Note: If "No", idenliftJ lank and describe leak and actions taken. Is the tank liquid level gauge legible and in 2 e:ood workine: condition? Is the area around the tank (concrete 3 surfaces, ground, containment, etc.) free of visible signs of leakage? Is the primary tank free of water or has another preventative measure been taken? NOTE: Refer to paragraphs 6.10 and 6.11 of 4 the standard for alternatives for Category 1 tanks. NIA is only appropriate for these a lterna tives. For double-wall or double bottom tanks or CE-ASTs, is interstitial monitoring 5 equipment (where applicable) in good working condition? For double-wall tanks or double bottom tanks or CE-ASTs, is interstice free of liquid? 6 Remove the liquid if it is found. If tank product is found, investigate possible leak. 7 If overfill equipment has a "test" button, does it activate the audible horn or light to confirm operation? If battery operated, replace battery if needed. 8 Is overfill prevention equipment in good working condition? If it is equipped with a mechanical test mechanism, actuate the Status Tank and Piping Yes No Yes No NIA Yes No Comments / Date Corrected Yes No NIA Yes No NIA Yes No NIA Equipment on tank Yes No NIA Yes No NIA Monthly Checklist 1 Appendix 4 Page 98 of 202 9 10 11 12 13 14 15 16 17 17 Item mechanism to confirm operation. Is the spill container (spill bucket) empty, free of visible leaks and in good working condition? Are piping connections to the tank (valves, fittings, pumps, etc.) free of visible leaks? Note: If "No", identify location and describe leak. Do the ladders/platforms/walkways appear to be secure with no sign of severe corrosion or damage? Is the containment free of excess liquid, debris, cracks, corrosion, erosion, fire hazards and other integrity issues? Status Yes No NIA Yes No Yes No NIA Containment Yes No NIA Comments/ Date Corrected Are dike drain valves closed and in good working condition? Yes No NIA Are containment egress pathways clear and any gates/doors operable? Yes No NIA Concrete Exterior AST (CE-AST) Inspect all sides for cracks in concrete. Are there any cracks in the concrete exterior larger than 1/16"? Yes No NIA Inspect concrete exterior body of the tank for cleanliness, need of coating, or rusting where applicable. Tank exterior in acceptable condition? Yes No NIA Visual inspect all tank top openings including nipples, manways, tank top overfill containers, and leak detection tubes. Is the sealant between all tank top openings and concrete intact and in good condition? Yes No NIA Other Conditions Is the system free of any other conditions that need to be addressed for continued safe operation? Yes No Additional Comments: Monthly Checklist 2 Appendix 4 Page 99 of 202  Monthly Checklist 3 Appendix 4 Page 100 of 202 STI SP00l Monthly Inspection Checklist General Ins ectfon Information: Inspection Date: Inspector Name (print): Inspector's Signature Prior Inspection Date: Retain until date: Title: _ Tank(s) inspected ID Regulatory facility name and ID number (if applicable) Nature Environmental & Marine Services, LLC [ID Number Inspection Guidance: Inspections of multiple tanks may be captured on one form as long as the tanks are substantially the same. For equipment not included in this Standard, follow the manufacturer recommended inspection/testing schedules and procedures. The periodic AST Inspection is intended for monitoring the external AST condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector per paragraph 4.1.2 of the standard. Upon discovery of water in the primary tank, secondary containment area, interstice, or spill container, remove promptly or take other corrective action. Inspect the liquid for regulated products or other contaminants and dispose of properly. Non-conforming items important to tank or containment integrity require evaluation by an engineer experienced in AST design, a Certified Inspector, or a tank manufacturer who will determine the corrective action. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. After severe weather (snow, ice, wind storms) or maintenance (such as coating) that could affect the operation of critical components (normal and emergency vents, valves), an inspection of these components is required as soon as the equipment is safely accessible after the event. Item Is tank exterior (roof, shell, heads, bottom, connections, fittings, valves, etc.) free of 1 visible leaks? Note: If "No", identify tank and describe leak and actions taken. Is the tank liquid level gauge legible and in 2 good working condition? Is the area around the tank (concrete 3 surfaces, ground, containment, etc.) free of visible signs of leakage? Is the primary tank free of water or has another preventative measure been taken? NOTE: Refer to paragraphs 6.10 and 6.11 of 4 the standard for alternatives for Category 1 tanks. NIA is only appropriate for these alternatives. For double-wall or double bottom tanks or CE-ASTs, is interstitial monitoring 5 equipment (where applicable) in good working condition? For double-wall tanks or double bottom tanks or CE-ASTs, is interstice free of liquid? 6 Remove the liquid if it is found. If tank product is found, investigate possible leak. 7 If overfill equipment has a "test" button, does it activate the audible horn or light to confirm operation? If battery operated, replace battery if needed. 8 Is overfill prevention equipment in good working condition? If it is equipped with a mechanical test mechanism, actuate the Status Tank and Piping Yes No Yes No NIA Yes No Comments / Date Corrected Yes No NIA Yes No NIA Yes No NIA Equipment on tank Yes No NIA Yes No NIA Monthly Checklist 1 Appendix 4 Page 101 of 202 Item mechanism to confirm operation. 9 Is the spill container (spill bucket) empty, free of visible leaks and in good working condition? 10 Are piping connections to the tank (valves, fittings, pumps, etc.) free of visible leaks? Note: If "No", identify location and describe leak. 11 Do the ladders/platforms/walkways appear to be secure with no sign of severe corrosion or damage? Is the containment free of excess liquid, 12 debris, cracks, corrosion, erosion, fire hazards and other integrity issues? Status Yes No NIA Yes No Yes No NIA Containment Yes No NIA Comments / Date Corrected 13 Are dike drain valves closed and in good working condition? Yes No NIA 14 Are containment egress pathways clear and any gates/doors operable? Yes No NIA Concrete Exterior AST (CE-AST) Inspect all sides for cracks in concrete. Are 15 there any cracks in the concrete exterior larger than 1/16"? Yes No NIA Inspect concrete exterior body of the tank for 16 cleanliness, need of coating, or rusting where Yes No NIA applicable. Tank exterior in acceptable condition? Visual inspect all tank top openings including nipples, manways, tank top 17 overfill containers, and leak detection tubes. Is the sealant between all tank top openings and concrete intact and in good condition? Yes No NIA Other Conditions Is the system free of any other conditions 17 that need to be addressed for continued safe operation? Yes No Additional Comments: Monthly Checklist 2 Appendix 4 Page 102 of 202  Monthly Checklist 3 Appendix 4 Page 103 of 202 STI SP00l Monthly Inspection Checklist General Ins ection Information: Inspection Date: Inspector Name (print): Inspector's Signature Prior Inspection Date: _ Retain until date: Title: Tank(s) inspected ID _ Regulatory facility name and ID number (if applicable) Nature Environmental & Marine Services, LLC Number _ [ID Inspection Guidance: Inspections of multiple tanks may be captured on one form as long as the tanks are substantially the same. For equipment not included in this Standard, follow the manufacturer recommended inspection/testing schedules and procedures. The periodic AST Inspection is intended for monitoring the external AST condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector per paragraph 4.1.2 of the standard. Upon discovery of water in the primary tank, secondary containment area, interstice, or spill container, remove promptly or take other corrective action. Inspect the liquid for regulated products or other contaminants and dispose of properly. Non-conforming items important to tank or containment integrity require evaluation by an engineer experienced in AST design, a Certified Inspector, or a tank manufacturer who will determine the corrective action. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. After severe weather (snow, ice, wind storms) or maintenance (such as coating) that could affect the operation of critical components (normal and emergency vents, valves), an inspection of these components is required as soon as the equipment is safely accessible after the event. 1 Item Is tank exterior (roof, shell, heads, bottom, connections, fittings, valves, etc.) free of visible leaks? Note: If "No", identify tank and describe leak and actions taken. Is the tank liquid level gauge legible and in 2 good working condition? Is the area around the tank (concrete 3 surfaces, ground, containment, etc.) free of visible signs of leakage? Is the primary tank free of water or has another preventative measure been taken? NOTE: Refer to paragraphs 6.10 and 6.11 of 4 the standard for alternatives for Category 1 tanks. NIA is only appropriate for these alternatives. For double-wall or double bottom tanks or CE-ASTs, is interstitial monitoring 5 equipment (where applicable) in good working condition? For double-wall tanks or double bottom tanks or CE-ASTs, is interstice free of liquid? 6 Remove the liquid if it is found. If tank product is found, investigate possible leak. 7 If overfill equipment has a "test" button, does it activate the audible horn or light to confirm operation? If battery operated, replace battery if needed. 8 Is overfill prevention equipment in good working condition? If it is equipped with a mechanical test mechanism, actuate the Monthly Checklist Status Tank and Piping Yes No Yes No NIA Yes No Comments / Date Corrected Yes No NIA Yes No NIA Yes No NIA Equipment on tank Yes No NIA Yes No NIA Appendix 4 Page 104 of 202 9 10 11 12 13 14 15 16 17 17 Item mechanism to confirm operation. Is the spill container (spill bucket) empty, free of visible leaks and in good working condition? Are piping connections to the tank (valves, fittings, pumps, etc.) free of visible leaks? Note: If "No", identifiJ location and describe leak. Do the ladders/platforms/walkways appear to be secure with no sign of severe corrosion or damage? Is the containment free of excess liquid, debris, cracks, corrosion, erosion, fire hazards and other integrity issues? Status Yes No NIA Yes No Yes No NIA Containment Yes No NIA Comments / Date Corrected Are dike drain valves closed and in good working condition? Yes No NIA Are containment egress pathways clear and any gates/doors operable? Yes No NIA Concrete Exterior AST (CE-AST) Inspect all sides for cracks in concrete. Are there any cracks in the concrete exterior larger than 1/16"? Yes No NIA Inspect concrete exterior body of the tank for cleanliness, need of coating, or rusting where applicable. Tank exterior in acceptable condition? Yes No NIA Visual inspect all tank top openings including nipples, manways, tank top overfill containers, and leak detection tubes. Is the sealant between all tank top openings and concrete intact and in good condition? Yes No NIA Other Conditions Is the system free of any other conditions that need to be addressed for continued safe operation? Yes No Additional Comments: Monthly Checklist 2 Appendix 4 Page 105 of 202  Monthly Checklist 3 Appendix 4 Page 106 of 202 STI SP00l Monthly Inspection Checklist General Ins ection Information: Inspection Date: Inspector Name (print): Inspector's Signature Tank(s) inspected ID Prior Inspection Date: Retain until date: _ _ Title: _ _ _ Regulatory facility name and ID number (if applicable) Nature Environmental & Marine Services, LLC [ID /\Jumber Inspection Guidance: Inspections of multiple tanks may be captured on one form as long as the tanks are substantially the same. For equipment not included in this Standard, follow the manufacturer recommended inspection/testing schedules and procedures. The periodic AST Inspection is intended for monitoring the external AST condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector per paragraph 4.1.2 of the standard. Upon discovery of water in the primary tank, secondary containment area, interstice, or spill container, remove promptly or take other corrective action. Inspect the liquid for regulated products or other contaminants and dispose of properly. Non-conforming items important to tank or containment integrity require evaluation by an engineer experienced in AST design, a Certified Inspector, or a tank manufacturer who will determine the corrective action. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. After severe weather (snow, ice, wind storms) or maintenance (such as coating) that could affect the operation of critical components (normal and emergency vents, valves), an inspection of these components is required as soon as the equipment is safely accessible after the event. 1 2 Item Is tank exterior (roof, shell, heads, bottom, connections, fittings, valves, etc.) free of visible leaks? Note: If "No", identify tank and describe leak and actions taken. Is the tank liquid level gauge legible and in good working condition? Is the area around the tank (concrete 3 surfaces, ground, containment, etc.) free of visible signs of leakage? Is the primary tank free of waler or has another preventative measure been taken? NOTE: Refer lo paragraphs 6.10and 6.11 of 4 the standard for alternatives for Category 1 tanks. NIA is only appropriate for these alternatives. For double-wall or double bottom tanks or 5 CE-ASTs, is interstitial monitoring equipment (where applicable) in good working condition? For double-wall tanks or double bottom tanks or CE-ASTs, is interstice free of liquid? 6 Remove the liquid if ii is found. If lank product is found, investigate possible leak. 7 If overfill equipment has a "test" button, does it activate the audible horn or light to confirm operation? If battery operated, replace battery if needed. 8 Is overfill prevention equipment in good working condition? If it is equipped with a mechanical test mechanism, actuate the Status Tank and Piping Yes No Yes No NIA Yes No Comments / Date Corrected Yes No NIA Yes No NIA Yes No NIA Equipment on tank Yes No NIA Yes No NIA Monthly Checklist l Appendix 4 Page 107 of 202 9 10 11 12 13 14 15 16 17 17 Item mechanism to confirm operation. Is the spill container (spill bucket) empty, free of visible leaks and in good working condition? Are piping connections to the tank (valves, fittings, pumps, etc.) free of visible leaks? Note: If "No", identify location and describe leak. Do the ladders/platforms/walkways appear to be secure with no sign of severe corrosion or damage? Is the containment free of excess liquid, debris, cracks, corrosion, erosion, fire hazards and other integrity issues? Status Yes No NIA Yes No Yes No NIA Containment Yes No NIA Comments / Date Corrected Are dike drain valves closed and in good working condition? Yes No NIA Are containment egress pathways clear and any gates/doors operable? Yes No NIA Concrete Exterior AST (CE-AST) Inspect all sides for cracks in concrete. Are there any cracks in the concrete exterior larger than 1/16"? Yes No NIA Inspect concrete exterior body of the tank for cleanliness, need of coating, or rusting where applicable. Tank exterior in acceptable condition? Yes No NIA Visual inspect all tank top openings including nipples, manways, tank top overfill containers, and leak detection tubes. Is the sealant between all tank top openings and concrete intact and in good condition? Yes No NIA Other Conditions Is the system free of any other conditions that need to be addressed for continued safe operation? Yes No Additional Comments: Monthly Checklist 2 Appendix 4 Page 108 of 202  Monthly Checklist 3 Appendix 4 Page 109 of 202 STI SP00l Monthly Inspection Checklist General Ins ection Information: Inspection Date: Inspector Name (print): Inspector's Signature Tank(s) inspected ID Prior Inspection Date: Retain until date: Title: _ Regulatory facility name and ID number (if applicable) Nature Environmental & Marine Services, LLC [ID Number Inspection Guidance: Inspections of multiple tanks may be captured on one form as long as the tanks are substantially the same. For equipment not included in this Standard, follow the manufacturer recommended inspection/testing schedules and procedures. The periodic AST Inspection is intended for monitoring the external AST condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector per paragraph 4.1.2 of the standard. Upon discovery of water in the primary tank, secondary containment area, interstice, or spill container, remove promptly or take other corrective action. Inspect the liquid for regulated products or other contaminants and dispose of properly. Non-conforming items important to tank or containment integrity require evaluation by an engineer experienced in AST design, a Certified Inspector, or a tank manufacturer who will determine the corrective action. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. After severe weather (snow, ice, wind stonns) or maintenance (such as coating) that could affect the operation of critical components (nonnal and emergency vents, valves), an inspection of these components is required as soon as the equipment is safely accessible after the event. Item Is tank exterior (roof, shell, heads, bottom, connections, fittings, valves, etc.) free of 1 visible leaks? Note: If "No", identify tank and describe leak and actions taken. 2 Is the tank liquid level gauge legible and in !?ood workin!? condition? Is the area around the tank (concrete 3 surfaces, ground, containment, etc.) free of visible signs of leakage? Is the primary tank free of water or has another preventative measure been taken? 4 NOTE: Refer to paragraphs 6.10 and 6.11 of the standard for alternatives for Category 1 tanks. NIA is only appropriate for these alternatives. For double-wall or double bottom tanks or 5 CE-ASTs, is interstitial monitoring equipment (where applicable) in good working condition? For double-wall tanks or double bottom tanks or CE-ASTs, is interstice free of liquid? 6 Remove the liquid if it is found. If tank vroduct is found, investi!?ate vossible leak. 7 If overfill equipment has a "test" button, does it activate the audible horn or light to confirm operation? If battery operated, revlace batterv if needed. 8 Is overfill prevention equipment in good working condition? If it is equipped with a mechanical test mechanism, actuate the Status Tank and Piping Yes No Yes No NIA Yes No Yes No NIA Yes No NIA Yes No NIA Equipment on tank Yes No NIA Yes No NIA Comments / Date Corrected Monthly Checklist 1 Appendix 4 Page 110 of 202 9 10 11 12 13 14 15 16 17 17 Item mechanism to confirm operation. Is the spill container (spill bucket) empty, free of visible leaks and in good working condition? Are piping connections to the tank (valves, fittings, pumps, etc.) free of visible leaks? Note: If "No", identify location and describe leak. Do the ladders/platforms/walkways appear to be secure with no sign of severe corrosion or damage? Is the containment free of excess liquid, debris, cracks, corrosion, erosion, fire hazards and other integrity issues? Status Yes No NIA Yes No Yes No NIA Containment Yes No NIA Comments / Date Corrected Are dike drain valves closed and in good working condition? Yes No NIA Are containment egress pathways clear and any gates/doors operable? Yes No NIA Concrete Exterior AST (CE-AST) Inspect all sides for cracks in concrete. Are there any cracks in the concrete exterior larger than 1/16"? Yes No NIA Inspect concrete exterior body of the tank for cleanliness, need of coating, or rusting where applicable. Tank exterior in acceptable condition? Yes No NIA Visual inspect all tank top openings including nipples, manways, tank top overfill containers, and leak detection tubes. Is the sealant between all tank top openings and concrete intact and in good condition? Yes No NIA Other Conditions Is the system free of any other conditions that need to be addressed for continued safe operation? Yes No Additional Comments: Monthly Checklist 2 Appendix 4 Page 111 of 202 STI SP00l Monthly Inspection Checklist General Ins ection Information: Inspection Date: Inspector Name (print): Inspector's Signature Tank(s) inspected ID Prior Inspection Date: _ Retain until date: _ Title: _ _ _ Regulatory facility name and ID number (if applicable) Nature Environmental & Marine Services, LLC [ID Number Inspection Guidance: Inspections of multiple tanks may be captured on one form as long as the tanks are substantially the same. For equipment not included in this Standard, follow the manufacturer recommended inspection/testing schedules and procedures. The periodic AST Inspection is intended for monitoring the external AST condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector per paragraph 4.1.2 of the standard. Upon discovery of water in the primary tank, secondary containment area, interstice, or spill container, remove promptly or take other corrective action. Inspect the liquid for regulated products or other contaminants and dispose of properly. Non-conforming items important to tank or containment integrity require evaluation by an engineer experienced in AST design, a Certified Inspector, or a tank manufacturer who will determine the corrective action. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. After severe weather (snow, ice, wind storms) or maintenance (such as coating) that could affect the operation of critical components (normal and emergency vents, valves), an inspection of these components is required as soon as the equipment is safely accessible after the event. Item Is tank exterior (roof, shell, heads, bottom, connections, fittings, valves, etc.) free of 1 visible leaks? Note:If "No", identify tank and describe leak and actions taken. 2 Is the tank liquid level gauge legible and in good working condition? Is the area around the tank (concrete 3 surfaces, ground, containment, etc.) free of visible signs of leakage? Is the primary lank free of waler or has another preventative measure been taken? 4 NOTE: Refer lo paragraphs 6.10 and 6.11 of the standard for alternatives for Category 1 tanks. NIA is only appropriate for these alternatives. For double-wall or double bottom tanks or CE-ASTs, is interstitial monitoring 5 equipment (where applicable) in good working condition? For double-wall tanks or double bottom tanks or CE-ASTs, is interstice free of liquid? 6 Remove the liquid if it is found. If tank product is found, investigate possible leak. 7 If overfill equipment has a "test" button, does it activate the audible horn or light to confirm operation? If battery operated, replace battery if needed. 8 Is overfill prevention equipment in good working condition? If it is equipped with a mechanical lest mechanism, actuate the Monthly Checklist Status Tank and Piping Yes No Yes No NIA Yes No Comments / Date Corrected Yes No NIA Yes No NIA Yes No NIA Equipment on tank Yes No NIA Yes No NIA Appendix 4 Page 112 of 202 9 10 11 12 13 14 15 16 17 17 Item mechanism to confirm operation. Is the spill container (spill bucket) empty, free of visible leaks and in good working condition? Are piping connections to the tank (valves, fittings, pumps, etc.) free of visible leaks? Note: If "No", idenlifiJ location and describe leak. Do the ladders/platforms/walkways appear to be secure with no sign of severe corrosion or damage? Is the containment free of excess liquid, debris, cracks, corrosion, erosion, fire hazards and other integrity issues? Status Yes No NIA Yes No Yes No NIA Containment Yes No NIA Comments / Date Corrected Are dike drain valves closed and in good working condition? Yes No NIA Are containment egress pathways clear and any gates/doors operable? Yes No NIA Concrete Exterior AST (CE-AST) Inspect all sides for cracks in concrete. Are there any cracks in the concrete exterior larger than 1/16"? Yes No NIA Inspect concrete exterior body of the tank for cleanliness, need of coating, or rusting where applicable. Tank exterior in acceptable condition? Yes No NIA Visual inspect all tank top openings including nipples, manways, tank top overfill containers, and leak detection tubes. Is the sealant between all tank top openings and concrete intact and in good condition? Yes No NIA Other Conditions Is the system free of any other conditions that need to be addressed for continued safe operation? Yes No Additional Comments: Monthly Checklist 2 Appendix 4 Page 113 of 202 ) Monthly Checklist 3 Appendix 4 Page 114 of 202  Monthly Checklist 3 Appendix 4 Page 115 of 202 STI SP00l Monthly Inspection Checklist General Ins ection Information: Inspection Date: Inspector Name (print): Inspector's Signature Prior Inspection Date: Retain until date: _ Title: _ Tank(s) inspected ID _ Regulatory facility name and ID number (if applicable) Nature Environmental & Marine Services, LLC Number _ [ID Inspection Guidance: Inspections of multiple tanks may be captured on one form as long as the tanks are substantially the same. For equipment not included in this Standard, follow the manufacturer recommended inspection/testing schedules and procedures. The periodic AST Inspection is intended for monitoring the external AST condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector per paragraph 4.1.2 of the standard. Upon discovery of water in the primary tank, secondary containment area, interstice, or spill container, remove promptly or take other corrective action. Inspect the liquid for regulated products or other contaminants and dispose of properly. Non-conforming items important to tank or containment integrity require evaluation by an engineer experienced in AST design, a Certified Inspector, or a tank manufacturer who will determine the corrective action. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. After severe weather (snow, ice, wind storms) or maintenance (such as coating) that could affect the operation of critical components (normal and emergency vents, valves), an inspection of these components is required as soon as the equipment is safely accessible after the event. 1 2 3 4 5 6 7 8 Item Is tank exterior (roof, shell, heads, bottom, connections, fittings, valves, etc.) free of visible leaks? Note: If "No", idenlifiJ lank and describe leak and actions taken. Is the tank liquid level gauge legible and in good working condition? Is the area around the tank (concrete surfaces, ground, containment, etc.) free of visible signs of leakage? Is the primary tank free of water or has another preventative measure been taken? NOTE: Refer to paragraphs 6.10 and 6.11 of the standard for alternatives for Category 1 tanks. NIA is only appropriate for these alternatives. For double-wall or double bottom tanks or CE-ASTs, is interstitial monitoring equipment (where applicable) in good working condition? For double-wall tanks or double bottom tanks or CE-ASTs, is interstice free of liquid? Remove the liquid if it is found. If tank product is found, investigate possible leak. If overfill equipment has a "test" button, does it activate the audible horn or light to confirm operation? If battery operated, replace battery if needed. Is overfill prevention equipment in good working condition? If it is equipped with a mechanical test mechanism, actuate the Status Tank and Piping Yes No Yes No NIA Yes No Yes No NIA Yes No NIA Yes No NIA Equipment on tank Yes No NIA Yes No NIA Comments / Date Corrected Monthly Checklist 1 Appendix 4 Page 116 of 202 9 10 11 12 13 14 15 16 17 17 Item mechanism to confirm operation. Is the spill container (spill bucket) empty, free of visible leaks and in good working condition? Are piping connections to the tank (valves, fittings, pumps, etc.) free of visible leaks? Note: If "No", identify location and describe leak. Do the ladders/platforms/walkways appear to be secure with no sign of severe corrosion or damage? Is the containment free of excess liquid, debris, cracks, corrosion, erosion, fire hazards and other integrity issues? Status Yes No NJA Yes No Yes No NIA Containment Yes No NIA Comments/ Date Corrected Are dike drain valves closed and in good working condition? Yes No NIA Are containment egress pathways clear and any gates/doors operable? Yes No NIA Concrete Exterior AST (CE-AST) Inspect all sides for cracks in concrete. Are there any cracks in the concrete exterior larger than 1/16"? Yes No NIA Inspect concrete exterior body of the tank for cleanliness, need of coating, or rusting where applicable. Tank exterior in acceptable condition? Yes No NIA Visual inspect all tank top openings including nipples, manways, tank top overfill containers, and leak detection tubes. Is the sealant between all tank top openings and concrete intact and in good condition? Yes No NIA Other Conditions Is the system free of any other conditions that need to be addressed for continued safe operation? Yes No Additional Comments: Monthly Checklist 2 Appendix 4 Page 117 of 202  Monthly Checklist 3 Appendix 4 Page 118 of 202 STI SP00l Monthly Inspection Checklist General Ins ction Information: Inspection Date: Inspector Name (print): Inspector's Signature Prior Inspection Date: Retain until date: Title: _ Tank(s) inspected ID Regulatory facility name and ID number (if applicable) Nature Environmental & Marine Services, LLC [ID Number Inspection Guidance: Inspections of multiple tanks may be captured on one form as long as the tanks are substantially the same. For equipment not included in this Standard, follow the manufacturer recommended inspection/testing schedules and procedures. The periodic AST Inspection is intended for monitoring the external AST condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector per paragraph 4.1.2 of the standard. Upon discovery of water in the primary tank, secondary containment area, interstice, or spill container, remove promptly or take other corrective action. Inspect the liquid for regulated products or other contaminants and dispose of properly. Non-conforming items important to tank or containment integrity require evaluation by an engineer experienced in AST design, a Certified Inspector, or a tank manufacturer who will determine the corrective action. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. After severe weather (snow, ice, wind storms) or maintenance (such as coating) that could affect the operation of critical components (normal and emergency vents, valves), an inspection of these components is required as soon as the equipment is safely accessible after the event. 1 Item Is tank exterior (roof, shell, heads, bottom, connections, fittings, valves, etc.) free of visible leaks? Note: If "No", identify tank and describe leak and actions taken. Is the tank liquid level gauge legible and in 2 good working condition? Is the area around the tank (concrete 3 surfaces, ground, containment, etc.) free of visible signs of leakage? Is the primary tank free of water or has another preventative measure been taken? NOTE: Refer to paragraphs 6.10 and 6.11 of 4 the standard for alternatives for Category 1 tanks. NIA is only appropriate for these alternatives. For double-wall or double bottom tanks or CE-ASTs, is interstitial monitoring 5 equipment (where applicable) in good working condition? For double-wall tanks or double bottom tanks or CE-ASTs, is interstice free of liquid? 6 Remove the liquid if it is found. If tank product is found, investigate possible leak. 7 If overfill equipment has a "test" button, does it activate the audible horn or light to confirm operation? If battery operated, replace battery if needed. 8 Is overfill prevention equipment in good working condition? If it is equipped with a mechanical test mechanism, actuate the Monthly Checklist Status Tank and Piping Yes No Yes No NIA Yes No Comments / Date Corrected Yes No NIA Yes No NIA Yes No NIA Equipment on tank Yes No NIA Yes No NIA Appendix 4 Page 119 of 202 9 ) 10 11 12 13 14 15 16 17 17 Item mechanism to confirm operation. Is the spill container (spill bucket) empty, free of visible leaks and in good working condition? Are piping connections to the tank (valves, fittings, pumps, etc.) free of visible leaks? Note: If "No", identifiJ location and describe leak. Do the ladders/platforms/walkways appear to be secure with no sign of severe corrosion or damage? Is the containment free of excess liquid, debris, cracks, corrosion, erosion, fire hazards and other integrity issues? Are dike drain valves closed and in good working condition? Status Yes No N/A Yes No Yes No NIA Containment Yes No NIA Yes No NIA Comments / Date Corrected Are containment egress pathways clear and any gates/doors operable? Yes No NIA Concrete Exterior AST (CE-AST) Inspect all sides for cracks in concrete. Are there any cracks in the concrete exterior larger than 1/16"? Yes No NIA Inspect concrete exterior body of the tank for cleanliness, need of coating, or rusting where applicable. Tank exterior in acceptable condition? Yes No NIA Visual inspect all tank top openings including nipples, manways, tank top overfill containers, and leak detection tubes. Is the sealant between all tank top openings and concrete intact and in good condition? Yes No NIA Other Conditions Is the system free of any other conditions that need to be addressed for continued safe operation? Yes No Additional Comments: Monthly Checklist 2 Appendix 4 Page 120 of 202  Monthly Checklist 3 Appendix 4 Page 121 of 202 STI SP00l Monthly Inspection Checklist General Ins ection Information: Inspection Date: Inspector Name (print): Inspector's Signature Prior Inspection Date: Retain until date: _ Title: _ Tank(s) inspected ID _ Regulatory facility name and ID number (if applicable) Nature Environmental & Marine Services, LLC [ID Number Inspection Guidance: Inspections of multiple tanks may be captured on one form as long as the tanks are substantially the same. For equipment not included in this Standard, follow the manufacturer recommended inspection/testing schedules and procedures. The periodic AST Inspection is intended for monitoring the external AST condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector per paragraph 4.1.2 of the standard. Upon discovery of water in the primary tank, secondary containment area, interstice, or spill container, remove promptly or take other corrective action. Inspect the liquid for regulated products or other contaminants and dispose of properly. Non-conforming items important to tank or containment integrity require evaluation by an engineer experienced in AST design, a Certified Inspector, or a tank manufacturer who will determine the corrective action. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. After severe weather (snow, ice, wind storms) or maintenance (such as coating) that could affect the operation of critical components (normal and emergency vents, valves), an inspection of these components is required as soon as the equipment is safely accessible after the event. I 2 3 4 5 6 Item Is tank exterior (roof, shell, heads, bottom, connections, fittings, valves, etc.) free of visible leaks? Note: If "No", identify tank and describe leak and actions taken. Is the tank liquid level gauge legible and in good working condition? Is the area around the tank (concrete surfaces, ground, containment, etc.) free of visible signs of leakage? Is the primary tank free of water or has another preventative measure been taken? NOTE: Refer to paragraphs 6.10 and 6.11 of the standard for alternatives for Category 1 tanks. N/A is only appropriate for these alternatives. For double-wall or double bottom tanks or CE-ASTs, is interstitial monitoring equipment (where applicable) in good working condition? For double-wall tanks or double bottom tanks or CE-ASTs, is interstice free of liquid? Remove the liquid if it is found. If tank product is found, investigate possible leak. 7 If overfill equipment has a "test" button, does it activate the audible horn or light to confirm operation? If battery operated, replace battery if needed. 8 Is overfill prevention equipment in good working condition? If it is equipped with a mechanical test mechanism, actuate the Monthly Checklist Status Tank and Piping Yes No Yes No NIA Yes No Yes No NIA Yes No NIA Yes No NIA Eauipment on tank Yes No NIA Yes No NIA Comments I Date Corrected Appendix 4 Page 122 of 202 9 I 10 11 12 13 14 15 16 17 17 Item mechanism to confirm operation. Is the spill container (spill bucket) empty, free of visible leaks and in good working condition? Are piping connections to the tank (valves, fittings, pumps, etc.) free of visible leaks? Note: If "No", identifiJ location and describe leak. Do the ladders/platforms/walkways appear to be secure with no sign of severe corrosion or damage? Is the containment free of excess liquid, debris, cracks, corrosion, erosion, fire hazards and other integrity issues? Are dike drain valves closed and in good working condition? Status Yes No NIA Yes No Yes No NIA Containment Yes No NIA Yes No NIA Comments / Date Corrected Are containment egress pathways clear and any gates/doors operable? Yes No NIA Concrete Exterior AST (CE-AST) Inspect all sides for cracks in concrete. Are there any cracks in the concrete exterior larger than 1/16"? Yes No NIA Inspect concrete exterior body of the tank for cleanliness, need of coating, or rusting where applicable. Tank exterior in acceptable condition? Yes No NIA Visual inspect all tank top openings including nipples, manways, tank top overfill containers, and leak detection tubes. Is the sealant between all tank top openings and concrete intact and in good condition? Yes No NIA Other Conditions Is the system free of any other conditions that need to be addressed for continued safe operation? Yes No Additional Comments: Monthly Checklist 2 Appendix 4 Page 123 of 202  Monthly Checklist 3 Appendix 4 Page 124 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 STI/SPFA SP001 Portable Container Monthly Inspection Checklist MR Environmental Inc Oc Hullh&Saffl'(Sohmru Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 50 Appendix 4 Page 125 of 202 STI SP00l Portable Container Monthly Inspection Checklist General Ins ection Information: Inspection Date: Inspector Name (print): Inspector's Signature Tank(s) inspected ID Prior Inspection Date: Retain until date: Title: _ _ Regulatory facility name and ID number (if applicable)Nature Environmental & Marine Services, LLC [ID r--Jumber Inspection Guidance: This periodic inspection is intended for monitoring the external condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector who is familiar with the site and can identify changes and developing problems. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. Item Are all portable container(s) within 1 designated storage area? Is the containment and storage area 2 free of excess liquid, debris, cracks or fire hazards? Are drain valves closed and in good 3 working condition? Are containment egress pathways 4 clear and any gates/doors operable? Is the container free of leaks? 5 Note: If "No", identifiJ container and describe leak. Is the container free of distortions, 6 buckling, denting or bulging? Area: Area: Area: Portable Container Containment/Storage Area Yes No Yes No Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Yes No NIA Yes No NIA Container Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Yes No Yes No Area: Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Additional Comments: Portable Container Checklist Appendix 4 Page 126 of 202 STI SP00l Portable Container Monthly Inspection Checklist General Ins ection Information: Inspection Date: Inspector Name (print): Inspector's Signature Tank(s) inspected ID Prior Inspection Date: _ Retain until date: _ Title: _ Regulatory facility name and ID number (if applicable)Nature Environmental & Marine Services, LLC ID Number Inspection Guidance: This periodic inspection is intended for monitoring the external condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector who is familiar with the site and can identify changes and developing problems. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. Item 1 2 3 4 5 6 Are all portable container(s) within designated storage area? Is the containment and storage area free of excess liquid, debris, cracks or fire hazards? Are drain valves closed and in good working condition? Are containment egress pathways clear and any gates/doors operable? Is the container free of leaks? Note: If "No", idenlifiJ container and describe leak. Is the container free of distortions, buckling, denting or bulging? Area: Area: Area: Portable Container Containment/Storage Area Yes No Yes No Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Yes No NIA Yes No NIA Container Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Yes No Yes No Area: Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Additional Comments: Portable Container Checklist 1 Appendix 4 Page 127 of 202 STI SP00l Portable Container Monthly Inspection Checklist General Ins ection Information: Inspection Date: Inspector Name (print): Prior Inspection Date: Retain until date: Title: Inspector's Signature Tank(s) inspected ID _ _ Regulatory facility name and ID number (if applicable)Nature Environmental & Marine Services, LLC ID 1\lurnber Inspection Guidance: This periodic inspection is intended for monitoring the external condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector who is familiar with the site and can identify changes and developing problems. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. Item I 2 3 4 5 6 Are all portable container(s) within designated storage area? Is the containment and storage area free of excess liquid, debris, cracks or fire hazards? Are drain valves closed and in good working condition? Are containment egress pathways clear and any gates/doors operable? Is the container free of leaks? Note: If "No", identify container and describe leak. Is the container free of distortions, buckling, denting or bulging? Area: Area: Area: Portable Container Containment/Storage Area Yes No Yes No Yes No Yes No Yes No oN/A Yes No oN/A Yes No Yes No Yes No oN/A Yes No oN/A Container Yes No Yes No Yes No oN/A Yes No oN/A Yes No Yes No Yes No Yes No Area: Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Additional Comments: Portable Container Checklist I Appendix 4 Page 128 of 202 STI SP00l Portable Container Monthly Inspection Checklist General Ins ection Information: Inspection Date: Inspector Name (print): Inspector's Signature Prior Inspection Date: Retain until date: Title: _ Tank(s) inspected ID Regulatory facility name and ID number (if applicable)Nature Environmental & Marine Services, LLC ID l\lumber Inspection Guidance: This periodic inspection is intended for monitoring the external condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector who is familiar with the site and can identify changes and developing problems. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. Item 1 2 3 4 5 6 Are all portable container(s) within designated storage area? Is the containment and storage area free of excess liquid, debris, cracks or fire hazards? Are drain valves closed and in good working condition? Are containment egress pathways clear and any gates/doors operable? Is the container free of leaks? Note: If "No", identifiJ container and describe leak. Is the container free of distortions, buckling, denting or bulging? Area: Area: Area: Portable Container Containment/Storage Area Yes No Yes No Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Yes No NIA Yes No NIA Container Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Yes No Yes No Area: Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Additional Comments: Portable Container Checklist 1 Appendix 4 Page 129 of 202 STI SP00l Portable Container Monthly Inspection Checklist General Ins ection Information: Inspection Date: Inspector Name (print): Inspector's Signature Tank(s) inspected ID Prior Inspection Date: Retain until date: Title: _ Regulatory facility name and ID number (if applicable)Nature Environmental & Marine Services, LLC ID Number Inspection Guidance: This periodic inspection is intended for monitoring the external condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector who is familiar with the site and can identify changes and developing problems. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. Item 1 2 3 4 5 6 Are all portable container(s) within designated storage area? Is the containment and storage area free of excess liquid, debris, cracks or fire hazards? Are drain valves closed and in good working condition? Are containment egress pathways clear and any gates/doors operable? Is the container free of leaks? Note: If "No", idenlifiJ container and describe leak. Is the container free of distortions, buckling, denting or bulging? Area: Area: Area: Portable Container Containment/Storage Area Yes No Yes No Yes No Yes No Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No NIA Yes No NIA Container Yes No Yes No NIA Yes No NIA Yes No Yes No Yes No Yes No Area: Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Additional Comments: Portable Container Checklist 1 Appendix 4 Page 130 of 202 STI SP00l Portable Container Monthly Inspection Checklist General Ins ection Information: Inspection Date: Inspector Name (print): Inspector's Signature Tank(s) inspected ID Prior Inspection Date: Retain until date: Title: Regulatory facility name and ID number (if applicable)Nature Environmental & Marine Services, LLC ID f\lumber Inspection Guidance: This periodic inspection is intended for monitoring the external condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector who is familiar with the site and can identify changes and developing problems. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. Item 1 2 3 4 5 6 Are all portable container(s) within designated storage area? Is the containment and storage area free of excess liquid, debris, cracks or fire hazards? Are drain valves closed and in good working condition? Are containment egress pathways clear and any gates/doors operable? Is the container free of leaks? Note: If "No", identify container and describe leak. Is the container free of distortions, buckling, denting or bulging? Area: Area: Area: Portable Container Containment/Storage Area Yes No Yes No Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Yes No NIA Yes No NIA Container Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Yes No Yes No Area: Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Additional Comments: Portable Container Checklist 1 Appendix 4 Page 131 of 202 STI SP00l Portable Container Monthly Inspection Checklist General ln pection Information: Inspection Date: Inspector Name (print): Inspector's Signature Tank(s) inspected ID Prior Inspection Date: Retain until date: _ Title: _ Regulatory facility name and ID number (if applicable)Nature Environmental & Marine Services, LLC ID Number Inspection Guidance: This periodic inspection is intended for monitoring the external condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector who is familiar with the site and can identify changes and developing problems. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. Item Are all portable container(s) within 1 designated storage area? Is the containment and storage area 2 free of excess liquid, debris, cracks or fire hazards? Are drain valves closed and in good 3 working condition? Are containment egress pathways 4 clear and any gates/doors operable? Is the container free of leaks? 5 Note: If "No", identify container and describe leak. Is the container free of distortions, 6 buckling, denting or bulging? Area: Area: Area: Portable Container Containment/Storage Area Yes No Yes No Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Yes No NIA Yes No NIA Container Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Yes No Yes No Area: Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Additional Comments: Portable Container Checklist 1 Appendix 4 Page 132 of 202 STI SP00l Portable Container Monthly Inspection Checklist General lns ection Information: Inspection Date: _ Inspector Name (print): Inspector's Signature Tank(s) inspected ID Prior Inspection Date: Retain until date: Title: _ _ Regulatory facility name and ID number (if applicable)Nature Environmental & Marine Services, LLC ID Number Inspection Guidance: This periodic inspection is intended for monitoring the external condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector who is familiar with the site and can identify changes and developing problems. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. Item 1 2 3 4 5 6 Are all portable container(s) within designated storage area? Is the containment and storage area free of excess liquid, debris, cracks or fire hazards? Are drain valves closed and in good working condition? Are containment egress pathways clear and any gales/doors operable? Is the container free of leaks? Note: If "No", idenlifiJ container and describe leak. Is the container free of distortions, buckling, denting or bulging? Area: Area: Area: Portable Container Containment/Storage Area Yes No Yes No Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Yes No NIA Yes No NIA Container Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Yes No Yes No Area: Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Additional Comments: Portable Container Checklist Appendix 4 Page 133 of 202 STI SP00l Portable Container Monthly Inspection Checklist General In ection Information: Inspection Date: Inspector Name (print): Inspector's Signature Tank(s) inspected ID Prior Inspection Date: Retain until date: _ Title: _ _ _ Regulatory facility name and ID number (if applicable)Nature Environmental & Marine Services, LLC ID Number Inspection Guidance: This periodic inspection is intended for monitoring the external condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector who is familiar with the site and can identify changes and developing problems. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. Item Are all portable container(s) within 1 designated storage area? Is the containment and storage area 2 free of excess liquid, debris, cracks or fire hazards? Are drain valves closed and in good 3 working condition? Are containment egress pathways 4 clear and anv gates/doors operable? Is the container free of leaks? 5 Note: If "No", identifiJ container and describe leak. Is the container free of distortions, 6 buckling, denting or bulging? Area: Area: Area: Portable Container Containment/Storage Area Yes No Yes No Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Yes No NIA Yes No NIA Container Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Yes No Yes No Area: Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Additional Comments: Portable Container Checklist Appendix 4 Page 134 of 202 STI SP00l Portable Container Monthly Inspection Checklist General Ins ection Information: Inspection Date: Inspector Name (print): Inspector's Signature Tank(s) inspected ID Prior Inspection Date: Retain until date: Title: _ _ Regulatory facility name and ID number (if applicable)Nature Environmental & Marine Services, LLC f!D Number Inspection Guidance: This periodic inspection is intended for monitoring the external condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector who is familiar with the site and can identify changes and developing problems. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. Item Are all portable container(s) within 1 designated storage area? Is the containment and storage area 2 free of excess liquid, debris, cracks or fire hazards? Are drain valves closed and in good 3 working condition? Are containment egress pathways 4 clear and any gates/doors operable? Is the container free of leaks? 5 Note: If "No", identify container and describe leak. Is the container free of distortions, 6 buckling, denting or bulging? Area: Area: Area: Portable Container Containment/Storage Area Yes No Yes No Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Yes No NIA Yes No NIA Container Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Yes No Yes No Area: Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Additional Comments: Portable Container Checklist l Appendix 4 Page 135 of 202 STI SP00l Portable Container Monthly Inspection Checklist General Ins ection Information: Inspection Date: Inspector Name (print): Inspector's Signature Tank(s) inspected ID Prior Inspection Date: Retain until date: Title: _ _ Regulatory facility name and ID number (if applicable)Nature Environmental & Marine Services, LLC ID Number Inspection Guidance: This periodic inspection is intended for monitoring the external condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector who is familiar with the site and can identify changes and developing problems. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. Item Are all portable container(s) within 1 designated storage area? Is the containment and storage area 2 free of excess liquid, debris, cracks or fire hazards? Are drain valves closed and in good 3 working condition? Are containment egress pathways 4 clear and any gates/doors operable? Is the container free of leaks? 5 Note: If "No", idenliftJ contniner 1111d describe leak. Is the container free of distortions, 6 buckling, denting or bulging? Area: Area: Area: Portable Container Containment/Storage Area Yes No Yes No Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Yes No NIA Yes No NIA Container Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Yes No Yes No Area: Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Additional Comments: Portable Container Checklist 1 Appendix 4 Page 136 of 202 STI SP00l Portable Container Monthly Inspection Checklist General Lns ection Information: Inspection Date: Inspector Name (print): Inspector's Signature Tank(s) inspected ID Prior Inspection Date: _ Retain until date: _ Title: _ Regulatory facility name and ID number (if applicable)Nature Environmental & Marine Services, LLC ID Number Inspection Guidance: This periodic inspection is intended for monitoring the external condition and its containment structure. This visual inspection does not require a Certified Inspector. It shall be performed by an owner's inspector who is familiar with the site and can identify changes and developing problems. Note the non-conformance and corresponding corrective action in the comment section. Retain the completed checklists for at least 36 months. Item Are all portable container(s) within 1 designated storage area? Is the containment and storage area 2 free of excess liquid, debris, cracks or fire hazards? Are drain valves closed and in good 3 working condition? Are containment egress pathways 4 clear and any gates/doors operable? Is the container free of leaks? 5 Note: If "No", idenlifiJ container and describe leak. Is the container free of distortions, 6 buckling, denting or bulging? Area: Area: Area: Portable Container Containment/Storage Area Yes No Yes No Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Yes No NIA Yes No NIA Container Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Yes No Yes No Area: Yes No Yes No Yes No NIA Yes No NIA Yes No Yes No Additional Comments: Portable Container Checklist 1 Appendix 4 Page 137 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC - 18511 Beaumont TX 77049 Hwy, Houston, APPENDIX D: RECORD OF CONTAINMENT DRAINAGE This record must be completed when rainwater from diked areas is drained into a storm drain or into an open watercourse, lake, or pond, and bypasses the water treatment system. The bypass valve must normally be sealed in closed position and opened and resealed following drainage under responsible supervision. Records are maintained with the SPCC Plan at the office located at 18511 Beaumont Hwy, Houston, TX 77049. MR Envlronmental Inc rrw!ranmtnuJ,<>m, Heahh& Snknlon Two Riverway Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 51 Appendix 4 Page 138 of 202 Record of Containment Drainage Nature Environmental and Marine Services, LLC Start Time End Time Signature [hh:mm AMIPM] [hh:mm AMIPM] 1 1 Appendix 4 Page 139 of 202 Date Record of Containment Drainage Nature Environmental and Marine Services, LLC Containment t 1 I 2 I 3 I 4 I s I 61 Visible Sheen [Yes I No] Start Time End Time [hh:mm AMIPM] [hh:mm AMIPM] Signature - -- - - Appendix 4 Page 140 of 202 Date Record of Containment Drainage Nature Environmental and Marine Services, LLC Containment [ 1 I 2 I 3 I 4 I s I 61 Visible Sheen [Yes I Nol Start Time End Time [hh:mm AMIPM] [hh:mm AMIPM] Signature --- -- - -- Appendix 4 Page 141 of 202 Date Record of Containment Drainage Nature Environmental and Marine Services, LLC Containment [ 1 I 2 I 3 I 4 I s I 61 Visible Sheen [Yes I Nol Start Time [hh:mm AMIPM] End Time [hh:mm AMIPM] Signature - - - -- - - Appendix 4 Page 142 of 202 Date Record of Containment Drainage Nature Environmental and Marine Services, LLC Containment [ 1 I 2 I 3 I 4 I s I 61 Visible Sheen rves I No] Start Time End Time [hh:mm AMIPM] [hh:mm AMIPM] Signature - - - -- - --- Appendix 4 Page 143 of 202 Date Record of Containment Drainage Nature Environmental and Marine Services, LLC Containment [ 1 I 2 I 3 I 4 I s I 61 Visible Sheen [Yes I Nol Start Time End Time [hh:mm AMIPM] [hh:mm AMIPM] Signature -- Appendix 4 Page 144 of 202 Date Record of Containment Drainage Nature Environmental and Marine Services, LLC Containment [ 1 I 2 I 3 I 4 I s I 61 Visible Sheen [Yes I No] Start Time End Time [hh:mm AMIPM] [hh:mm AMIPM] Signature - - - --- - - -- Appendix 4 Page 145 of 202 Date Record of Containment Drainage Nature Environmental and Marine Services, LLC Containment (11213141516) Visible Sheen [Yes I No] Start Time End Time [hh:mm AMIPM] [hh:mm AMIPM] Signature - - - . -- Appendix 4 Page 146 of 202 Date Record of Containment Drainage Nature Environmental and Marine Services, LLC Containment C 1 I 2 I 3 I 4 I s I 61 Visible Sheen rves I No] Start Time End Time [hh:mm AMIPM] [hh:mm AMIPM] Signature - - -- Appendix 4 Page 147 of 202 Date Record of Containment Drainage Nature Environmental and Marine Services, LLC Containment C 1 I 2 I 3 I 4 I s I 61 Visible Sheen rves I No] Start Time End Time [hh:mm AMIPM] [hh:mm AMIPM] Signature - - -- -- - Appendix 4 Page 148 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 APPENDIX E: RECORD OF ANNUAL DISCHARGE PREVENTION BRIEFINGS AND TRAINING Briefings will be scheduled and conducted by the facility owner or operator for operating personnel at regular intervals to ensure adequate understanding of this SPCC Plan. The briefings will also highlight and describe known discharge events or failures, malfunctioning components, and recently implemented precautionary measures and best practices. Personnel will also be instructed in operation and maintenance of equipment to prevent the discharge of oil, and in applicable pollution laws, rules, and regulations. Facility operators and other personnel will have an opportunity during the briefings to share recommendations concerning health, safety, and environmental issues encountered during facility operations. MR Environmental Inc .OmJJ>IIIO(ialf &Saf9YSmtttiMs Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 52 Appendix 4 Page 149 of 202 Annual Discharge Prevention Briefings and Training Log Type of Briefing: lnstructor(s): Date: Nature Environmental and Marine Services, LLC OJN L N"'-1. -o -l . Employees in Attendance Signature 'fv\ t.. L,, i O (', A WR _,. Jlsc (.) fL_ ,;.- h A_.ft - IJ .- ..1'.A ) 0 ('Q ,a :_: \} }: u /1u I- Appendix 4 Page 150 of 202 Annual Discharge Prevention Briefings and Training Log Type of Briefing: lnstructor(s): Nature Environmental and Marine Services, LLC Date: Employees in Attendance Signature Appendix 4 Page 151 of 202 Annual Discharge Prevention Briefings and Training Log Type of Briefing: lnstructor(s): Nature Environmental and Marine Services, LLC Date: Employees in Attendance Signature - Appendix 4 Page 152 of 202 Annual Discharge Prevention Briefings and Training Log Type of Briefing: lnstructor(s): Date: Nature Environmental and Marine Services, LLC Employees in Attendance Signature - Appendix 4 Page 153 of 202 Annual Discharge Prevention Briefings and Training Log Type of Briefing: lnstructor(s): Nature Environmental and Marine Services, LLC Date: Employees in Attendance Signature -- - - Appendix 4 Page 154 of 202 Annual Discharge Prevention Briefings and Training Log Type of Briefing: lnstructor(s): Nature Environmental and Marine Services, LLC Date: Employees in Attendance Signature -- Appendix 4 Page 155 of 202 Annual Discharge Prevention Briefings and Training Log Type of Briefing: lnstructor{s): Nature Environmental and Marine Services, LLC Date: Employees in Attendance Signature -- Appendix 4 Page 156 of 202 Annual Discharge Prevention Briefings and Training Log Type of Briefing: lnstructor(s): Nature Environmental and Marine Services, LLC Date: Employees in Attendance Signature - - Appendix 4 Page 157 of 202 Annual Discharge Prevention Briefings and Training Log Type of Briefing: lnstructor(s): Nature Environmental and Marine Services, LLC Date: Employees in Attendance Signature - Appendix 4 Page 158 of 202 n Annual Discharge Prevention Briefings and Training Log Nature Environmental and Marine Services, LLC Type of Briefing: lnstructor{s}: Date: Employees in Attendance Signature - - Appendix 4 Page 159 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 APPENDIX F: VOLUME REQUIRED OF SECONDARY CONTAINMENT For Tank T-1: Determination of volume of Containment, C-1 Length (ft) = 52.5 (ft) Width (ft) = 12.5 (ft) Height (ft) = 1.17 (ft) Vc.1 = Length x Width x Height = 52.5 (ft) X 12.5 (ft) X 1.17 (ft)= 768 (ft3) Vc.1 = 768 (ft3) X 7.48 = 5,745 gal Tank T-1 is a Dragon design frac tank with a volume of 500 barrels (bbl) Vr.1 = 500 bbl x 42 gal/bbl = 21,000 gallons For Tank measurements please see drawings in Appendix A, Figure A-3. The existing secondary containment C-1 volume is insufficient to contain the capacity of the largest single container (T-1) including sufficient freeboard to contain precipitation. Within three months of the implementation of this plan the facility must provide secondary containment sufficient to hold the full capacity of T-1 and sufficient freeboard to contain precipitation. Once provided Nature Environmental and Marine Services, LLC must keep the secondary containment clear of debris. The facility must ensure that the secondary containment system must be free of cracks, holes, or gaps and be sufficiently impervious to contain leaks, spills, and accumulated rainfall until the collected material is detected and removed. T-1 is located outside so the owner or operator needs to provide extra volume for a freeboard of 9.9 inches. MR Environmental Inc r,,,.t,on-.uol,O;cupmlonal &'iiltef>/5"1utioni Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 53 Appendix 4 Page 160 of 202 The existing secondary containment C-1 is sufficient to contain the capacity of the largest single container (T-1) including sufficient freeboard to contain precipitation. Appendix 4 Page 161 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 Precipitation for 25-year, 24-hour event in Harris County = 9.9 (in) Freeboard, FB Freeboard Volume, VFs = 9.9 (in)/ 12 (in/ft) = 52.5 (ft) X 12.5 (ft) X 0.825 (ft) = 541 (ft3) x 7.48 (gal/ ft3) = 0.825 (ft) = 541 (ft3) = 4,047 (gal) Required secondary containment volume VReq. sc = V TANKT-1 + VFB = 21,000 + 4,047 = 25,047 (gal) Leaving the same dimensions for length and width the additional volume means that the secondary containment must be at least 5'-2" height. The owner or operator need to discuss options with the PE in order to comply with the SPCC regulations. The facility has made a written commitment to have manpower, equipment, and materials available to the facility to respond to a release. During the time until adequate secondary containment is provided, the facility must deploy active secondary containment. For Tank T-2: Determination of volume of Containment, C-2 Length (ft) = 52.5 (ft) Width (ft) = 12.5 (ft) Height (ft) = 1.17 (ft) Vc-2 = Length x Width x Height = 52.5 (ft) X 12.5 (ft) X 1.17 (ft) = 768 (ft3) Vc-2= 768 (ft3) X 7.48 = 5,745 gal Tank T-2 is a Dragon design frac tank with a volume of 500 barrels (bbl) Vr.2 = 500 bbl x 42 gal/bbl = 21,000 gallons For Tank measurements please see drawings in Appendix A, Figure A-3. MR Envlronment,11 Inc 0 , ................ l'Yl,'fl,w,,t'f Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 54 Appendix 4 Page 162 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 The existing secondary containment C-2 volume is insufficient to contain the capacity of the largest single container (T-2) including sufficient freeboard to contain precipitation. Within three months of the implementation of this plan the facility must provide secondary containment sufficient to hold the full capacity of T-2 and sufficient freeboard to contain precipitation. Once provided Nature Environmental and Marine Services, LLC must keep the secondary containment clear of debris. The facility must ensure that the secondary containment system must be free of cracks, holes, or gaps and be sufficiently impervious to contain leaks, spills, and accumulated rainfall until the collected material is detected and removed. T-2 is located outside so the owner or operator needs to provide extra volume for a freeboard of 9.9 inches. Precipitation for 25-year, 24-hour event in Harris County = 9.9 (in) Freeboard, FB Freeboard Volume, VFe = 9.9 (in)/ 12 (in/ft) : 52.5 (ft) X 12.5 (ft) X 0.825 (ft) = 541 (ft3) x 7.48 (gal/ ft3) = 0.825 (ft) = 541 (ft3) = 4,047 (gal) Required secondary containment volume VReq. sc = V TANK T-1 + VFB = 21,000 + 4,047 = 25,047 (gal) Leaving the same dimensions for length and width the additional volume means that the secondary containment must be at least 5'-2" height. The owner or operator need to discuss options with the PE in order to comply with the SPCC regulations. The facility has made a written commitment to have manpower, equipment, and materials available to the facility to respond to a release. During the time until adequate secondary containment is provided, the facility must deploy active secondary containment. JIM Environmental Inc nwlroornwn. OaupmoMI Hl!ahh&, Sal'ltV Solution, Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 55 Appendix 4 Page 163 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 For Tank T-3: Determination of volume of Containment, C-3 Length (ft) = 19.083 (ft) Width (ft) = 18.67 (ft) Height (ft) = 0.458 (ft) Vc.3 = Length X Width X Height = 19.083 (ft) X 18.67 (ft) X 0.458 (ft) = 163 (ft3) Vc.3= 163 (ft3) X 7.48 = 1,219 gal The design of the secondary containment has a ramp that must be deducted from the secondary containment volume. The ramp is a right triangle with the following dimensions: Height = 5.5" = 0.458' Length = 50" = 4.17' Width = 10' Area of a right triangle = (L)(H) = x 4.17 x 0.458 = 0.95 ft2 Volume = Area x W = 0.95 ft2 x 10 ft= 9.5 ft3 = 9.5 ft3 x 7.48 gal/ft3 = 71 gal Volume available = 1,219 gal - 71 gal = 1,148 gal Determination of volume of Tank T-4 (Using dimensions assuming shell capacity unknown), Vr.3 Tank Radius (ft) = Diameter I 2 = 2 (ft)/ 2 = 1 (ft) Vr.3 = TT x Radius2 (ft) x Tank Length (ft) = TT X 12 (ft)2 X 2.875 (ft) = 9 (ft3) MR Envlronmenlal Inc En'flltlnrne,ql,Oa:upati;)nal 1-1,,ilth&, Sm,ty !ioluuom Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 56 Appendix 4 Page 164 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 Vr.3 = 9 (ft3) x 7.48 gal/ft3 = 67 gallons Drums are filled usually 80% of the capacity, so 67 x 0.80 = 54 gallons The existing secondary containment is greater than the capacity of the tank. Freeboard precipitation is not considered into account since the tanks is located indoors. Nature Environmental and Marine Services, LLC has prepared this oil spill contingency plan and a written commitment to have manpower, equipment and materials available to the facility to respond to a release as described in 40 CFR 112.7(k)(2). Nature Environmental and Marine Services, LLC must periodically inspect the tank (as described in Sections 2.7) and ensure good housekeeping practices (including but not limited to those described in Appendix L) are used during routine maintenance activities. Nature Environmental and Marine Services, LLC must also ensure that oil from these units are managed and disposed following all regulatory requirements. MR Envlronmenti.ll fnc EnvtronrnenQJ,Oupacion.iJHl!ilth&Sifl!lySoluoons Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 57 Appendix 4 Page 165 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC - 18511 Beaumont Hwy, Houston, TX 77049 APPENDIX G: RECORDS OF TANK INTEGRITY AND PRESSURE TESTS Attach copies of official records of tank integrity and pressure tests. MR Envlronmcn,-al inc Cnvllfflment.lll,Occupalon,IIHuth&Sdl!t'fSolurioos Two Riverway Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 58 Appendix 4 Page 166 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 APPENDIX H: EMERGENCY CONTACTS Designated person responsible for spill prevention: Mr. Cornelius Zuyderwijk CEO 936-444-5079 (Facility) EMERGENCY TELEPHONE NUMBERS: Joel Curl Local Emergency Response Emergency Notifications Texas Commission on Environmental Quality (TCEQ) Texas Commission on Environmental Quality, Region 10 U.S. Environmental Protection Agency EPA, Region 6 National Response Center State Emergency Response Committee (SERC) Local Emergency Planning Committee (LEPC) 911 (800) 832-8224 409-898-3838 866-372-9378 800-424-8802 (800) 832-8224 409-832-8757 MR En,..lronmonl.tl Inc Err-llrfflmam.al, pationil He.llth&Sifet1Soltrtions Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 59 Appendix 4 Page 167 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC - 18511 Beaumont Hwy, Houston, TX 77049 APPENDIX I: DISCHARGE NOTIFICATION FORM The SPCC Coordinator is responsible for ensuring that spills of the reportable quantity or more of any of the following types of oil spills present at the facility are reported to the State Emergency Response Commission (SERC) and, if the spill reaches surface water, the National Response Center (NRC) and the Local Emergency Planning Committee (LEPC) within 24 hours of the time the spill is discovered: Oil Spill Reportable Quantities Type of Oil Diesel Used Oil Motor Oil Miscellaneous Oils Reportable Quantity Spilled on Land 25 Gallons 25 Gallons 25 Gallons 25 Gallons Reportable Quantity Spilled on Surface Water Causes Sheen Causes Sheen Causes Sheen Causes Sheen 1. Materials other than oil may require reporting, however only oil spills are addressed in this SPCC Plan. 2. Reportable quantity applies even if the spill is contained by a secondary containment structure (State of Texas requirement; Not reportable to the NRC). 3. Spills to surface water (includes offsite ditches and storm sewers that discharge offsite) must be reported to the NRC and the LEPC in addition to the SERC. MR Env(ronmen111I Inc rnm.,metQJ,O:rup,,,donil & 5dutiun Two Riverway Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 60 Appendix 4 Page 168 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 EMERGENCY TELEPHONE NUMBERS: Local Emergency Response Emergency Notifications Texas Commission on Environmental Quality (TCEQ) Texas Commission on Environmental Quality, Region 10 U.S. Environmental Protection Agency EPA, Region 6 National Response Center State Emergency Response Committee (SERC) Local Emergency Planning Committee (LEPC) 911 (800) 832-8224 409-898-3838 866-372-9378 800-424-8802 (800) 832-8224 409-832-8757 MR Envlronmenci1I In, , .,.....Wih's,...,. Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 61 Appendix 4 Page 169 of 202  Discharge Notification Form *** Notification must not be delayed if information or individuals are not available. Additional pages may be attached to supplement information contained in the form. Facility name: Nature Environmental and Marine Services, LLC 18511 Beaumont Hwy, Houston, TX 77049 Description of Discharge Date/time ReportinQ Individual Release date: Release time: Duration: Name: Discovery date: Discovery time: Tel.#: Location of discharge Latitude: LonQitude: Description: Equipment source Product Piping D FlowlineD 0 AST/UST 0 Other* Unknown Stack, flare U Crude oil D Diesel/Gasoline D AV Gas/Jet Fuel 0 Used Oil D MotorOil D Hydraulic Oil D Other* Description: Equipment ID: * Describe other: Appearance and description Environmental conditions Impacts Wind direction: Wind speed: Rainfall: Current: Quantity Receiving medium Released: 8 D water** D land air other (describe): Recovered: D Release confined to company property. 0 Release outside company property. ** If water, indicate extent and body of water: Describe circumstances of the release Assessment of impacts and remedial actions Disposal method for recovered material Action taken to prevent incident from reoccurrina Safety issues Notifications Aaencv L J Injuries Name l J Fatalities L J Evacuation Date/time reported & Comments Company Spill Response Coordinator National Response Center 1-800-424-8802 State police Local Emergency PlanninQ Committee Oil spill removal organization/Cleanup contractor Appendix 4 Page 170 of 202  Discharge Notification Form *** Notification must not be delayed if information or individuals are not available. Additional pages may be attached to supplement information contained in the form. Facility name: Nature Environmental and Marine Services, LLC 18511 Beaumont Hwy, Houston, TX 77049 Description of Discharge Date/time Reoortinq Individual Release date: Release time: Duration: Name: Discovery date: Discovery time: Tel.#: Location of discharge Equipment source Product Latitude: Longitude: 0 Piping D FlowlineD 0 AST/UST D Other* Unknown Stack, flare [:J Crude oil D Diesel/Gasoline D AV Gas/Jet Fuel 0 Used Oil D MotorOil 0 Hydraulic Oil 0 Other* Description: Description: Equipment ID: * Describe other: Appearance and description Environmental conditions Impacts Quantity Receiving medium Wihd direction: Wind speed: Released: water** air D land other (describe): Rainfall: Current: Recovered: D Release confined to company property. D Release outside company property. ** If water, indicate extent and body of water: Describe circumstances of the release Assessment of impacts and remedial actions Disposal method for recovered material Action taken to prevent incident from reoccurring Safety issues Notifications Agency L J Injuries Name L J Fatalities L J Evacuation Date/time reported & Comments Company Spill Response Coordinator National Response Center 1-800-424-8802 State police Local Emergency Planning Committee Oil spill removal organization/Cleanup contractor Appendix 4 Page 171 of 202  Discharge Notification Form *** Notification must not be delayed if information or individuals are not available. Additional pages may be attached to supplement information contained in the form. Facility name: Nature Environmental and Marine Services, LLC 18511 Beaumont Hwy, Houston, TX 77049 Description of Discharae Date/time Reoortina Individual Release date: Release time: Duration: Name: Discovery date: Discovery time: Tel.#: Location of discharge Equipment source Product Appearance and description Latitude: Longitude: 0 Piping Unknown D FlowlineD Stack, flare 0 AST/UST ii Other* U Crude oil D Diesel/Gasoline D AV Gas/Jet Fuel 0 Used Oil D MotorOil 0 Hydraulic Oil D Other* Description: Description: Equipment ID: * Describe other: Environmental conditions Impacts Wind direction: Wind speed: Rainfall: Current: Quantity Receiving medium Released: B water** D land air other (describe): Recovered: D Release confined to company property. D Release outside company property. ** If water, indicate extent and body of water: Describe circumstances of the release Assessment of impacts and remedial actions Disposal method for recovered material Action taken to prevent incident from reoccurrina Safetv issues Notifications Agency I I lniuries Name I I Fatalities I I Evacuation Date/time reported & Comments Company Spill Response Coordinator National Response Center 1-800-424-8802 State police Local Emergency Planning Committee Oil spill removal organization/Cleanup contractor Appendix 4 Page 172 of 202  Discharge Notification Form *** Notification must not be delayed if information or individuals are not available. Additional pages may be attached to supplement information contained in the form. Facility name: Nature Environmental and Marine Services, LLC 18511 Beaumont Hwy, Houston, TX 77049 Description of Discharge Date/time Reportinq Individual Release date: Release time: Duration: Name: Discovery date: Discovery time: Tel.#: Location of discharge Equipment source Product Latitude: Lonqitude: Piping LJ Unknown 0 FlowlineO Stack, flare 0 AST/UST 0 Other* D Crude oil 0 Diesel/Gasoline D AV Gas/Jet Fuel 0 Used Oil D MotorOil 0 Hydraulic Oil 0 Other* Description: Description: Equipment ID: * Describe other: Appearance and description Environmental conditions lmoacts Wind direction: Wind speed: Rainfall: Current: Quantity Receiving medium BReleased: ""'.ater** air D land 0 other (describe): Recovered: 0 Release confined to company property. 0 Release outside company property. ** If water, indicate extent and body of water: Describe circumstances of the release Assessment of impacts and remedial actions Disposal method for recovered material Action taken to prevent incident from reoccurring Safety issues I I Injuries I I Fatalities I I Evacuation Notifications Aaency Name Date/time reported & Comments Company Spill Response Coordinator National Response Center 1-800-424-8802 State police Local Emergency Planninq Committee Oil spill removal organization/Cleanup contractor Appendix 4 Page 173 of 202  Discharge Notification Form *** Notification must not be delayed if information or individuals are not available. Additional pages may be attached to supplement information contained in the form. Facility name: Nature Environmental and Marine Services, LLC 18511 Beaumont Hwy, Houston, TX 77049 Description of Discharge Date/time Reoortinq Individual Release date: Release time: Duration: Name: Discovery date: Discovery time: Tel.#: Location of discharge Equipment source Product Latitude: Lonaitude: 0 Piping Unknown D FlowlineO Stack, flare D AST/UST D Other* L.J Crude oil 0 Diesel/Gasoline D AV Gas/Jet Fuel 0 Used Oil D MotorOil Hydraulic Oil D Other* Description: Description: Equipment ID: Describe other: Appearance and description Environmental conditions Impacts Wind direction: Wind soeed: Rainfall: Current: Quantity Receiving medium Released: 0 water** D land Dair 0 other (describe): Recovered: 0 Release confined to company property. 0 Release outside company property. ** If water, indicate extent and body of water: Describe circumstances of the release Assessment of impacts and remedial actions Disposal method for recovered material Action taken to prevent incident from reoccurring Safetv issues I I lniuries I I Fatalities I I Evacuation Notifications Agency Name Date/time reported & Comments Company Spill Response Coordinator National Response Center 1-800-424-8802 State police Local Emergency Planninq Committee Oil spill removal organization/Cleanup contractor Appendix 4 Page 174 of 202  Discharge Notification Form *** Notification must not be delayed if information or individuals are not available. Additional pages may be attached to supplement information contained in the form. Facility name: Nature Environmental and Marine Services, LLC 18511 Beaumont Hwy, Houston, TX 77049 Descriotion of Discharge Date/time Reporting Individual Release date: Release time: Duration: Name: Discovery date: Discovery time: Tel.#: Location of discharge Equipment source Product Latitude: LDonuitude: Piping Unknown 0 Flow line O Stack, flare 0 AST/UST 0 Other* U Crude oil D Diesel/Gasoline 0 AV Gas/Jet Fuel 0 Used Oil D MotorOil 0 Hydraulic Oil D Other.. Description: Description: Equipment ID: * Describe other: Appearance and description Environmental conditions lmoacts Wind direction: Wind speed: Rainfall: Current: Quantity Receiving medium Released: 8 0 water** D land air other (describe): Recovered: D Release confined to company property. 0 Release outside company property. ... If water, indicate extent and body of water: Describe circumstances of the release Assessment of impacts and remedial actions Disposal method for recovered material Action taken to prevent incident from reoccurring Safety issues I J lnillries I I Fatalities I J Evacuation Notifications Agency Name Date/time reported & Comments Company Spill Response Coordinator National Response Center 1-800-424-8802 State police Local Emergency Plannino Committee Oil spill removal organization/Cleanup contractor Appendix 4 Page 175 of 202  Discharge Notification Form *** Notification must not be delayed if information or individuals are not available. Additional pages may be attached to supplement information contained in the form. Facility name: Nature Environmental and Marine Services, LLC 18511 Beaumont Hwy, Houston, TX 77049 Description of Discharge Date/time Reporting Individual Location of discharge Equipment source Product Appearance and description Environmental conditions Impacts Quantity Receiving medium Describe circumstances of the release Assessment of impacts and remedial actions Disposal method for recovered material Action taken to prevent incident from reoccurrina Safety issues Notifications Aaencv Company Spill Response Coordinator National Response Center 1-800-424-8802 State police Release date: Release time: Duration: Name: Latitude: LonQitude: i::::J Piping D FlowlineD 0 AST/UST D Other* Unknown Stack, flare U Crude oil D Diesel/Gasoline D AV Gas/Jet Fuel Used Oil D Motor Oil 0 Hydraulic Oil n Other* Discovery date: Discovery time: Tel.#: Description: Description: Equipment ID: * Describe other: Wind direction: Wind speed: Released: water** air D land other (describe): Rainfall: Current: Recovered: D Release confined to company property. D Release outside company property. ** If water, indicate extent and body of water: L J Injuries Name L J Fatalities l J Evacuation Date/time reported & Comments Local Emergency Planning Committee Oil spill removal organization/Cleanup contractor Appendix 4 Page 176 of 202  Discharge Notification Form *** Notification must not be delayed if information or individuals are not available. Additional pages may be attached to supplement information contained in the form. Facility name: Nature Environmental and Marine Services, LLC 18511 Beaumont Hwy, Houston, TX 77049 Descriotion of Discharae Date/time Reoorting Individual Release date: Release time: Duration: Name: Discovery date: Discovery time: Tel.#: Location of discharge Equipment source Product Appearance and description Latitude: LonQitude: LJ Piping LJ Unknown 0 FlowlineO Stack, flare 0 AST/UST 0 Other* U Crude oil 0 Diesel/Gasoline D AV Gas/Jet Fuel 0 Used Oil D Motor Oil 0 Hydraulic Oil D Other* Description: Description: Equipment ID: * Describe other: Environmental conditions Impacts Quantity Receiving medium Wind direction: Wind speed: Released: water** air D land other (describe): Rainfall: Current: Recovered: D Release confined to company property. D Release outside company property. ** If water, indicate extent and body of water: Describe circumstances of the release Assessment of impacts and remedial actions Disposal method for recovered material Action taken to prevent incident from reoccurrina Safety issues Notifications Aaencv L J Injuries Name I J Fatalities L J Evacuation Date/time reoorted & Comments Company Spill Response Coordinator National Response Center 1-800-424-8802 State police Local Emergency Planning Committee Oil spill removal organization/Cleanup contractor Appendix 4 Page 177 of 202  Discharge Notification Form *** Notification must not be delayed if information or individuals are not available. Additional pages may be attached to supplement information contained in the form. Facility name: Nature Environmental and Marine Services, LLC 18511 Beaumont Hwy, Houston, TX 77049 Description of Discharge Date/time ReoortinQ Individual Location of discharge Equipment source Product Appearance and description Environmental conditions lmoacts Quantity Receiving medium Describe circumstances of the release Assessment of impacts and remedial actions Disposal method for recovered material Action taken to prevent incident from reoccurring Safetv issues Notifications Aaencv Company Spill Response Coordinator National Response Center 1-800-424-8802 State police Release date: Release time: Duration: Name: Latitude: Lonaitude: U Piping Unknown D FlowlineO Stack, flare 0 AST/UST n Other* [.J Crude oil D Diesel/Gasoline D AV Gas/Jet Fuel D Used Oil D Motor Oil 0 Hydraulic Oil D Other* Discovery date: Discovery time: Tel.#: Description: Description: Equipment ID: * Describe other: Wind direction: Wind speed: Released: 0 water** D land Dair D other (describe): Rainfall: Current: Recovered: D Release confined to company property. DRelease outside company property. ** If water, indicate extent and body of water: I I Injuries Name I I Fatalities L I Evacuation Date/time reported & Comments Local Emergency Planninq Committee Oil spill removal organization/Cleanup contractor Appendix 4 Page 178 of 202  Discharge Notification Form *** Notification must not be delayed if information or individuals are not available. Additional pages may be attached to supplement information contained in the form. Facility name: Nature Environmental and Marine Services, LLC 18511 Beaumont Hwy, Houston, TX 77049 Description of Discharge Date/time Reoortinq Individual Location of discharge Equipment source Product Appearance and description Environmental conditions Impacts Quantity Receiving medium Describe circumstances of the release Assessment of impacts and remedial actions Disposal method for recovered material Action taken to prevent incident from reoccurring Safety issues Notifications Aaencv Company Spill Response Coordinator National Response Center 1-800-424-8802 State police Release date: Release time: Duration: Name: Latitude: Lonaitude: U Piping Unknown D FlowlineO Stack, flare D AST/UST D Other* U Crude oil 0 Diesel/Gasoline D AV Gas/Jet Fuel 0 Used Oil D MotorOil D Hydraulic Oil D Other* Discovery date: Discovery time: Tel.#: Description: Description: Equipment ID: * Describe other: Wind direction: Wind speed: Released: D water** D land Dair D other (describe): Rainfall: Current: Recovered: D Release confined to company property. D Release outside company property. ** If water, indicate extent and body of water: I I Injuries Name I I Fatalities I J Evacuation Date/time reported & Comments Local Emergency Planninq Committee Oil spill removal organization/Cleanup contractor Appendix 4 Page 179 of 202  NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 APPENDIX J: DISCHARGE RESPONSE EQUIPMENT INVENTORY The facility is recommended to maintain various 95 - Gallon Spill Kit and will have the following inventory. The equipment inventory is verified during the monthly inspection and must be replenished as needed. Item Pads 18"x 18" Pillows, 17.5"x 17.5" Dikes/Socks, 3" -cp and x 4'-long Dikes/Socks, 3"-cp and 8'-long Silver Shield Gloves, Size L Nitrile Gloves, Size 10 Goggles Tychem QC Coveralls.XL Floor-Stand Spill Sign Haz-Mat Disposal Bags 33"x 60" Spill Response Pocket Guide Safety and Compliance Directory DOT Emergency Response Guidebook DOT Label Pkg. Quantity 100 25 15 10 2 Pair 2 Pair 2 Pair 2 1 6 1 1 1 1 MR En,y(ronm@nlal Inc .Oaupaloni)Hulh&!iifay'iollllDl1 Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 62 Appendix 4 Page 180 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 APPENDIX K: SDS MR Envlronmental Inc t-.i: 1...........,..,,gl,il,r1 Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 63 Appendix 4 Page 181 of 202 Safety Data Sheet: Produced Water, Sweet or Sour 1. Identification Product Name: Produced Water, Sweet or Sour Synonyms: Fomiation Water, Salt Water, H2O, Oily Water; Sweet and Sour Product Use: Water extracted from oil or natural gas well production, process stream, waste EP Energy 1001 Louisiana Street Houston, Texas 77002 lnfomiation: O'BRIEN'S: (713) 997-1000 or 855-269-0826 (985) 781-0804 24/7 EP 2. Hazard(s) Identification Note: This material has not been tested by EP Energy to determine its specific health hazards. Therefore, the infomiation provided in this section includes health hazard information on the product components. GHS Classifications H226: Flammable liquid & vapour H350: Carcinogenicity, Category 1 H320: Eye Irritant, Category 2B H315: Skin Irritant, Category 2 GHS Label Elements Signal Word: Danger GHS Hazard Statements May contain or release poisonous hydrogen sulfide gas H226: Flammable liquid & vapour H350: May cause cancer. H320: Causes eye irritation. H315: Causes skin irritation. Hazards Not Otherwise Classified PrecautionaryStatement(s) Prevention: P201: Obtain special instructions before use. P202: Do not handle until all safety precautions have been read and understood. P210: Keep away from heat/sparks/open flames/hot surfaces - no smoking. P270: Do not eat, drink or smoke when using this product. P281: Use personal protective equipment as required. P264: Wash thoroughly after handling. P280: Wear protective gloves/protective clothing/eye protection/face protection. Response: P308+P313: IF exposed or concerned: Get medical advice/attention. P305+P351+P338: IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses if present and easy to do. Continue rinsing. P337+P313: If eye irritation persists: Get medical advice/attention. P302+P352: IF ON SKIN: Wash with plenty of soap and water. P332+P313: If skin irritation occurs: Get medical advice/attention. P362: Take off contaminated clothing and wash before reuse. P370: In case offire: Usedry chemical, carbon dioxide, or foam for extinguishing. Storage: P405: Store locked up. Date Prepared 06/01/2015 Page 1 of 7 Appendix 4 Page 182 of 202 Safety Data Sheet: Produced Water, Sweet or Sour Disposal: P501: Dispose of contents/container in accordance with local/regional/national/international regulations. EP 3. Composition/Information on Ingredients Note: Composition will vary with geographic location, geologic formation, temperature and pressure. Components Water Mineral Varietyl,i Crude Oil (Petroleum} Benzene Hydrogen Sulfide CAS No. Mixture Varies 8002-05-9 71-43-2 7783-06-4 >68 <32 <1 <1 Varies Wt%('! ('!Normal composition ranges are shown. Exceptions may occur depending upon the source of the produced water. ( 2lActual composition is unknown, but may contain Sodium Chloride (CAS No. 7647-14-5), Potassium Chloride (CAS No. 7447-40-7) and/or Calcium Chloride (CAS No. 10043-52-4) 4. First-Aid Measures Inhalation: If respiratory symptoms develop, move victim to fresh air. Seek immediate medical attention if symptoms persist. If breathing has stopped and airway is clear, provide artificial respiration. Do not use mouth-to-mouth method if victim ingested the substance. Provide artificial respiration with the aid of a pocket mask equipped with a one-way valve or other proper respiratory medical device. Administer oxygen if breathing is difficult, if qualified. Seek immediate medical attention. Skin Contact: Remove and isolate contaminated clothing and shoes. Wash affected areas with soap and water. If irritation persists, seek medical attention. Decontaminate clothing before reuse. Eye Contact: Flush eyes with large amounts of water for at least 15 minutes, occasionally lifting the eyelids. Seek medical attention. Ingestion: DO NOT INDUCE VOMITING. If spontaneous vomiting occurs, place on the left side with head down to prevent aspiration of liquid into the lungs. Have exposed individual rinse mouth thoroughly with water. Never give anything by mouth to an unconscious person. Do not leave victim unattended. Monitor for breathing difficulties. Seek immediate medical attention. Notes to Physician: This material may contain or liberate hydrogen sulfide. In high doses, hydrogen sulfide may produce pulmonary edema and respiratory depression or paralysis. 5. Fire-Fighting Measures NFPA Ratings: Health: 1 Flammability: 1 Reactivity: 0 General Fire Hazards: Flammable. Fire is associated with crude oil and natural gas liquids floating on surface of produced water and their vapors. May be ignited by heat, sparks or flames or other sources of ignition. Vapors may reach an ignition source, and flashback. Runoff to sewer may create fire or explosion hazard downstream from the source. Gases may form explosive mixtures with air. BLEVE'S (Boiling Liquid Expanding Vapor Explosions) can occur when a liquid in a pressurized container is heated to temperatures beyond its boiling point. This can lead to failure of the container and damage to the surrounding area. May react with strong oxidizing materials and a wide variety of chemicals. Hazardous combustion/decomposition products may include carbon monoxide, carbon dioxide, hydrocarbons, nitrogen oxides and sulfur oxides. Hydrogen sulfide may be present. Downwind personnel must be evacuated. Extinguishing Media: Dry chemical, foam, carbon dioxide or water spray. Carbon dioxide can displace oxygen. Use caution when applying carbon dioxide in confined spaces. Unsuitable extinguishing media: Do not use a solid water stream. Water and foam should not be used together on the same surface as water destroys the foam. Water should be used as a spray to keep surrounding areas cool. Fire Fighting Instructions: Move containers from fire area if you can do it without risk. Use a smothering technique for extinguishing fire. Do not use a forced- water stream as this will scatter the fire. Use a water spray to cool fire-exposed containers and surrounding areas until well after fire is out. Do not direct water at source of leak or safety devices as icing may occur. Dike fire-control water for later disposal; do not scatter the material. Firefighters Date Prepared 06/01/2015 Page 2 of 7 Appendix 4 Page 183 of 202 Safety Data Sheet: Produced Water, Sweet or Sour EP should wear self-contained breathing apparatus and full protective clothing. Refer to Section 8 for appropriate PPE selection. Precautions for Fire Involving Tanks or Car/Trailer Loads: Always stay away from tanks engulfed in flame. Fight fire from maximum distance or use unmanned hose holders or monitor nozzles. Cool containers with flooding quantities of water until well after fire is out. Withdraw immediately in case of rising sound from venting safety devices or discoloration of tank. If unmanned hose holders or monitor nozzles cannot be used, withdraw from area and let fire burn. 6. Accidental Release Measures Personal Precautions: Extremely Flammable. Spillage of liquid product will create a fire hazard and may fom, an explosive atmosphere. Keep all sources of ignition and hot metal surfaces away from spill/release. The use of explosion-proof electrical equipment is recommended. Product may contain or release poisonous hydrogen sulfide gas. Provide sufficient ventilation in the affected area(s) and wear appropriate personal protective equipment as indicated in Section 8 when handling spill material. Environmental Precautions: Stop the leak if it can be done without risk. Prevent spilled material from entering waterways, sewers, basements or confined areas. Contain release to prevent further contamination of soils, surface water or groundwater. Clean up spill as soon as possible using appropriate techniques such as applying non-combustible absorbent materials or vacuuming. All equipment used when handling the product must be grounded. A vapor suppressing foam may be used to reduce vapors. Use clean nonsparking tools to collect absorbed material. Where feasible and appropriate, remove contaminated soil. Methods for Containment and Clean Up: Immediate cleanup of any spill is recommended. Build dike or use other appropriate spill response methods far ahead of spill for containment and later recovery or disposal of spilled material. Absorb spill with inert material and place in suitable container for disposal. If spilled on water, remove with appropriate equipment such as skimmers, booms or absorbents. In case of soil contamination, remove contaminated soil for remediation or disposal in accordance with applicable regulations. Reporting: Report spills/releases as required, to appropriate local, state and federal authorities. US Coast Guard and Environmental Protection Agency regulations require immediate reporting of spills/release that could reach any waterway. Report spill/release to the National Response Center at (800) 424-8802. In case of accident or road spill, notify Chemtrec at (800) 424-9300. 7. Handling and Storage Handle in accordance with good industrial hygiene and safety practices. These practices include, but are not limited to, avoiding unnecessary exposure and prompt removal of material from eyes, skin, and clothing. If needed, take first aid actions as indicated in Section 4. Precautions for Safe Handling: Handle as a flammable liquid. Keep away from heat, sparks and open flame. No smoking. Use only with adequate ventilation. May release or contain dangerous levels of H2S. Use only with adequate ventilation. Wear appropriate personal protective equipment and use exposure controls as indicated in Section 8. Vent slowly to the atmosphere when opening. Avoid all contact with skin and eyes. Avoid breathing product dust or vapors. Use explosion-proof electrical (ventilating, lighting and material handling) equipment. Non-sparking tools should be used. Ground and bond all transfer and storage equipment to prevent static sparks and equip with self-closing valves, pressure vacuum bungs and flame arrestors. Review all operations which have the potential of generating and accumulating electrostatic charge and/or flammable atmosphere. Use appropriate mitigating procedures. Do not enter confined spaces without following proper entry procedures. Remove contaminated clothing immediately. Wash with soap and water after working with this product. Scales, deposits and sludge from equipment associated with this product may have accumulation of Naturally Occurring Radioactive Materials (NORM). Equipment should be assessed for external gamma radiation. Conditions for Safe Storage: Keep away from flame, sparks, excessive temperatures and open flame. No smoking. Maintain vessels closed and clearly labeled. Empty vessels may contain explosive vapors. Do not pressurize, cut, heat, weld or expose these vessels to sources of ignition. This material may contain or release H2S. In a tank or other closed container, the vapor space above this material may accumulate hazardous concentrations of H2S. Do not enter confined spaces without following proper entry procedures. Use appropriate containment to avoid environmental contamination. Incompatibilities: Keep away from strong oxidizers, ignition sources and heat. Date Prepared 06/01/2015 Appendix 4 Page 184 of 202 Page 3 of 7 Safety Data Sheet: Produced Water, Sweet or Sour 8. Exposure Controls/Personal Protection EP Components Crude Oil (Petroleum) Benzene Hydrogen Sulfide CAS No. 8002-05-9 71-43-2 7783-06-4 Wt%(') <1 <1 <1 Occupational Exposure Limits OSHA<11 ACGIH<1J NIOSH(Zj 500 ppm N/A 350 mg/m3 1 5srEL 2ot.,;e111ng 0.5'J1 2.5sTEL 5 11::L 0.1 1 STEL 10<.;eilmg Units - ppm ppm (1)8-hour TWA unless otherwise specified. (2)10-hour TWA unless otherwise specified. ( 3 ) ACGIH has established a Biological Exposure Index (BEi) for this substance. N/A: Not Applicable STEL: 15-minute Short Temi Exposure Limit Ceiling: Concentration not to be exceeded at any time Engineering Controls: Provide adequate general and local exhaust ventilation to: (1) Maintain airborne chemical concentrations below applicable exposure limits, (2) Prevent accumulation of flammable vapors and fomiation of explosive atmospheres, and (3) Prevent formation of oxygen deficient atmospheres, especially in confined spaces. Eye Protection: Safety glasses are required standard PPE. Face shields are required when working with pressurized lines. Wear chemical goggles when working with liquid natural gas. Skin Protection: Fire Resistant Clothing (FRC) is required standard PPE. Insulated clothing and/or gloves should be worn where liquid or expanding gas may be generated. Respiratory Protection: A NIOSH-approved respirator must be worn where controls do not maintain airborne concentrations below occupational exposure limits. Positive-pressure, Full-face, self-contained breathing apparatus (SCBA) should be available for emergency use. H2S MAY BE PRESENT OR RELEASED. NIOSH-approved respiratory protection should be used when handling crude of high or unknown hydrogen sulfide content and to reduce airborne concentrations to allowable occupational exposure levels. Work/Hygiene Practices: Always observe good personal hygiene measures, such as washing after handling the material and before eating, drinking, and/or smoking. Routinely wash work clothing and protective equipment to remove contaminants. 9. Physical and chemical properties Flammable Properties: Flash Point: Varies widely depending on hydrocarbon content Flammable Limits in Air, % by Volume: Lower (LFL): 4.0 % Upper(UFL): 46.0 % Auto-ignition Temperature: Not available Values given are typical of similar products. There are no test results for this mixture. Appearance: Odor: Boiling Point: Freezing Point: Vapor Pressure: Solubility in H20: Specific Gravity@ 68 F & 1 atm: Clear or opaque liquid Slightly hydrocarbon/rotten eggs Varies widely depending on hydrocarbon < 32 F Not available Not available > 1 content % Volatile by Volume: Viscosity: Melting Point: Vapor Density (Air= 1): pH: Evaporation Rate: Molecular Wt.: Negligible Not available Not available > 1 Not available Not available Not available 10. Stability and Reactivity Chemical Stability: Stable under anticipated conditions of use and nomial temperature conditions. Date Prepared 06/01/2015 Page 4 of 7 Appendix 4 Page 185 of 202 Safety Data Sheet: Produced Water, Sweet or Sour EP Conditions to Avoid/Incompatibilities: Strong oxidizing agents, strong reducing agents, chlorine, fluorine, bromine and metal catalysts, heat, sparks, flame and build-up of static electricity, Hazardous Decomposition Products: Not anticipated under normal conditions of use. Combustion of H2S creates sulfur dioxide. Hazardous Polymerization: Not known to occur. 11. Toxicological Information Tox1co omcaI data does not exist Acute Toxicity Inhalation Skin Absorption Ingestion (Swallowing) or this mixture. Hazard Unlikely to be harmful poisonous hvdroaen sulfide qas Unlikely to be harmful Unlikely to be harmful Additional Information May contain or release LC50/LD50 Data >5 mg/L (mist.estimated) > 2 g/kg (estimated} > 5 g/kg (estimated) Aspiration Hazard: Not expected to be an aspiration hazard. Skin Corrosion/Irritation: Not expected to be irritating, Serious Eye Damage/Irritation: Not expected to be irritating. Signs and Symptoms: No known effects of overexposure. Skin Sensitization: Not expected to be a skin sensitizer. Respiratory Sensitization: No information available on the mixture, however none of the components have been classified for respiratory sensitization (or are below the concentration threshold for classification). Specific Target Organ Toxicity (Single Exposure): Not expected to cause organ effects from single exposure. Specific Target Organ Toxicity (Repeated Exposure): Not expected to cause organ effects from repeated exposure. Carcinogenicity: May cause cancer. Germ Cell Mutagenicity: Not expected to cause heritable genetic effects. Reproductive Toxicity: Not expected to cause reproductive toxicity. Other Comments: This material may contain or liberate hydrogen sulfide, a poisonous gas with the smell of rotten eggs. The smell disappears rapidly because of olfactory fatigue so odor may not be a reliable indicator of exposure. Effects of overexposure include irritation of the eyes, nose, throat and respiratory tract, blurred vision, photophobia (sensitivity to light), and pulmonary edema (fluid accumulation in the lungs). Severe exposures can result in nausea, vomiting, muscle weakness or cramps, headache, disorientation and other signs of nervous system depression, irregular heartbeats, convulsions, respiratory failure, and death. Information on Toxicological Effects of Components Crude Oil (Petroleum) Carcinogenicity: Chronic application of crude oil to mouse skin resulted in an increased incidence of skin tumors. IARC concluded in its Crude Oil Monograph that there is limited evidence of carcinogenicity in animals, and that crude oil is not classifiable as to its carcinogenicity in humans (Group 3). It has not been listed as a carcinogen by NTP or OSHA. Target Organs: Laboratory animal studies of crude oil by the dermal and inhalation exposure routes have demonstrated toxicity to the liver, blood, spleen and thymus. Reproductive Toxicity: Dermal exposure to crude oil during pregnancy resulted in limited evidence of developmental toxicity in laboratory animals. Decreased fetal weight and increased resorptions were noted at maternally toxic doses. No significant effects on pup growth or other developmental landmarks were observed postnatally. BENZENE: This product may contain benzene, which can cause degeneration in blood forming bone marrow leading to anemia which may further degrade to leukemia, a type of cancer. Acute benzene poisoning causes central nervous system depression. Chronic exposure affects the hematopoietic system causing blood disorders including anemia and pancytopenia. Mutagenic and clastogenic in mammalian and nonmammalian test systems. Reproductive or developmental toxicant only at doses that are maternally toxic, based on tests with animals. Date Prepared 06/01/2015 Page 5 of 7 Appendix 4 Page 186 of 202 Safety Data Sheet: Produced Water, Sweet or Sour EP HYDROGEN SULFIDE: This product may contain or release hydrogen sulfide, which may be fatal if inhaled. Greater than 15-20 ppm continuous exposure can cause mucous membrane and respiratory tract irritation. 50-500 ppm can cause headache, nausea, dizziness, loss of reasoning and balance, difficulty breathing, fluid in the lungs and possible loss of consciousness. Greater than 500 ppm can cause rapid or immediate unconsciousness due to respiratory paralysis and death by suffocation unless removed from exposure and successfully resuscitated. Inhalation of a single breath at a concentration of 1000 ppm (0.1%) can cause immediate unconsciousness and death. Hydrogen sulfide is corrosive when moist. Skin contact may cause bums. There is a rapid loss of sense of smell on exposure to gas concentrations above 50 ppm. At high concentrations, individuals may not even recognize the odor before becoming unconscious. Carcinogenicity: Component (CAS No.) Benzene (71-43-2) ACGIH1'1 A1 IARC Monographs121 1 US NTP Yes OSHA Regulated Yes ('1ACGIH Carcinogens: A1 = Confirmed human carcinogen, A2 = Suspected human carcinogen, A3 = Confirmed animal carcinogen with unknown relevance to humans, A4 = Not classifiable as a human carcinogen, A5 = Not suspected as a human carcinogen 121IARC Monographs: 1 = Carcinogenic to humans, 2A = Probably carcinogenic to humans, 2B = Possibly carcinogenic to humans, 3 = Not classifiable as to carcinogenicity to humans, 4 = Probably not carcinogenic to humans 12. Ecological Information Keep out of sewers, drainage areas, and waterways. Report spills and releases, as applicable, under Federal and State regulations. May be hazardous to waterways/wildlife. 13. Disposal Information Do not dispose of waste into sewer. Do not allow this material to drain into sewers/water supplies. If discarded, this material may meet the criteria of being an "ignitable" waste. If hydrogen sulfide and/or benzene are present in the waste, the waste may be considered a hazardous Ulisted waste. Under RCRA, it is the responsibility of the user to determine, at the time of disposal, if the material meets federal, state, or local criteria to be defined as a hazardous waste. 14. Transport Information UN/Identification No: UN 1993 Proper Shipping Name: Flammable Liquid, n.o.s Hazard Class: 3 Packing Group: II ERG#: 128 15. Regulatory Information Section 302 EPCRA Extremely Haza,rdous Substances (EHS): Product Component GAS No. Wt% RQ, lb None TPQ, lb Section 304 CERCLA Hazardous Substances: Product Component GAS No. Benzene 71-43-2 Hydrogen Sulfide 7783-06-4 WI% <1 <1 RQ, lb 10 100 Section 3111312 Hazard Categorization: Acute: Chronic: Fire: Yes Yes Yes Pressure: Yes Reactive: No Section 313 EPCRA Toxic Substanc1 s: Ingredient GAS No. Wt.% Benzene 71-43-2 <1 Hydrogen Sulfide 7783-06-4 <1 EPATSCA All components are either on the U.S. EPA TSCA Inventory List, or are not regulated under TSCA. Date Prepared 06/01/2015 Page 6 of 7 Appendix 4 Page 187 of 202 Safety Data Sheet: Produced Water, Sweet or Sour Key RQ = Reportable Quantity TPQ = Threshold Planning Quantity of EHS EP CALIFORNIA PROPOSITION 65 WARNING Chemicals known to the State of California to cause cancer, birth defects, or other reproductive harm may be found in crude oil and petroleum products. Although it is possible to sufficiently refine a crude oil or its end products to remove the potential for cancer, we are advising that one or more of the listed chemicals may be present in some detectable quantities. Read and follow directions and use care when handling crude oil and petroleum products. 16. Other Information Date Prepared: 03/07/2006, Last Revision: 06/01/2015 THIS INFORMATION RELATES ONLY TO THE SPECIFIC MATERIAL DESIGNATED AND MAY NOT BE VALID FOR SUCH MATERIAL USED IN COMBINATION WITH ANY OTHER MATERIALS OR IN ANY PROCESS. SUCH INFORMATION IS TO THE BEST OF THIS COMPANY'S KNOWLEDGE AND BELIEVED ACCURATE AND RELIABLE AS OF THE DATE INDICATED. HOWEVER, NO REPRESENTATION, WARRANTY OR GUARANTEE IS MADE AS TO THE ACCURACY, RELIABILITY OR COMPLETENESS. IT IS THE USER'S RESPONSIBILITY TO SATISFY THEMSELVES AS TO THE SUITABILITY AND COMPLETENESS OF SUCH INFORMATION FOR THEIR OWN PARTICULAR USE. Key/Legend: ACGIH -American Conference of Governmental Industrial Hygienists ADR - Agreement on Dangerous Goods by Road CAA - Clean Air Act GAS - Chemical Abstracts Service Registry Number CDG - Carriage of Dangerous Goods By Road and Rail Manual CERCLA - Comprehensive Environmental Response, Compensation, and Liability Act CFR - Code of Federal Regulations CNS - Central Nervous System EINECS - European Inventory of Existing Chemical Substances Registry Number ERG - Emergency Response Guidebook EPCRA - Emergency Planning and Community Right-to-Know Act GHS - Globally Harmonized System of Classification and Labeling of Chemicals IARC - International Agency for Research on Cancer IATA - International Air Transport Association ICAO - International Civil Aviation Organization IMDG - International Maritime Dangerous Goods Code IMO - International Maritime Organization MSDS - Material Safety Data Sheet N/E - Not Established NTP - National Toxicology Program OSHA - Occupational Safety and Health Administration PEL - Permissible Exposure Limit PPE - Personal Protective Equipment RCRA - Resource Conversation and Recovery Act RID - Regulations Concerning the International Transport of Dangerous Goods by Rail RQ - Reportable Quantities SARA - Superfund Amendments and Reauthorization Act of 1986 SDS - Safety Data Sheet TCC -Tag Closed Cup TDG - Transportation of Dangerous Goods TLV - Threshold Limit Value TSCA - Toxic Substance Control Act UN/NA - United Nations I North American Number UNECE - United Nations Economic Commission for Europe US DOT - United States Department of Transportation US EPA - United States Environmental Protection Agency Vol. -Volume WHMIS - Workplace Hazardous Materials Information System This is the end of MSDS A0133.sds Date Prepared 06/01/2015 Page 7 of 7 Appendix 4 Page 188 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 APPENDIX L: OIL TRANSFER GUIDANCE Transferring any oil to/from a tank presents the highest level of interaction between the oil storage tanks and facility or contractor personnel. Since there is a higher probability for spills to occur during oil transfers, the following spill prevention procedures are recommended: Prior to transferring any oil into a tank, the person transferring the oil will make sure that the available volume of the tank is greater than the amount of oil that will be transferred to the tank. [Best Management Practice] During the entire time that oil is being transferred to a tank, the person transferring the oil must be a qualified person who is alert and continually monitors the transfer process with an unobstructed view at a maximum of 25 feet from the cargo tank. [49 CFR 177.834 (i)(3)] A person is qualified if he has been made aware of the hazardous material which is to be loaded or unloaded; he has been instructed on the procedures to be followed in emergencies; he is authorized to move the cargo tank; and he has the means to do so. [49 CFR 177.834 (i)(4)] Tank level gauges, if present, will be continuously monitored during oil transfers. [Best Management Practice] No smoking is allowed within 25 feet of an oil storage or transfer area during transfers. [49 CFR 177.834 (c)] No fire, open flames or welding is allowed within 25 feet of an oil storage and transfer area during transfers. [49 CFR 177.834 (d)] The hand brake must be engaged and the wheels chocked on any vehicle that is transferring oil or receiving oil. [49 CFR 177.834 (e)] Do not use tools that are likely to damage the ability of a valve on an oil storage tank to close. [49 CFR 177.834 (f)] MR Envlronmental Inc r.Mrontntilml,Ouu &SafflySnlution, Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 64 Appendix 4 Page 189 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 After transferring oil, any manholes and valves associated with an oil storage tank and a cargo tank motor vehicle will be closed, secured and free from leaks. [49 CFR 177.834 (j)] Warning signs will be in-place that warn personnel not to move oil transfer vehicles until all transfer lines have been completely disconnected. (40 CFR 1122.7 (e)(I)] Prior to the departure of an oil transfer vehicle, the lower most outlets of the vehicle will be examined for leakage and, if necessary, tightened, adjusted or replaced to prevent leakage of oil. [40 CFR 1122.7 (h)(3)] During oil transfer, all associated equipment will be properly grounded to prevent sparking from the discharge of static electricity built up within the oil transfer line. (49 CFR 177.837 (b)] Contractors retained to transfer oil at this facility will be apprised of their responsibility for oil spill prevention and, if necessary, oil spill response during such transfers. [Best Management Practice] MR Envtronmon,al Inc &Mrnnmtntll, Qcc I-IMl!h& !imiy Solut!on Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 65 Appendix 4 Page 190 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 APPENDIX M: DEFINITIONS Aboveground Storage Tank (AST) - A tank or container designed to operate at pressures ranging from atmospheric pressure through a gauge pressure of one psig measured at the top of the tank. The tank may be sitting on the ground or set on supports such as saddles, skids or legs, etc., and may be installed in a vault. Included are shopfabricated tanks, field-erected tanks, and portable containers. Bulk Storage Container: 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. From 112.1(d)(2)(ii) "only containers of oil with a capacity of 55 gallons or greater are counted" toward the 1,320-gallon threshold. The threshold applies to storage capacity contained in operating equipment as well as to storage capacity in containers (see page 47044 of the July 17, 2002 Federal Register). Capacity- The amount of liquid that the AST is capable of holding. The capacity of a compartment in a multi-compartmented AST shall be considered a separate and distinct capacity, provided that the bulkhead between compartments is fully welded around its perimeter and compartments are not manifolded. The capacity of an AST shall be determined by one of the following sources: A label on the AST that indicates its capacity; AST documentation, such as drawings or packing lists; Consulting the tank manufacturer, if known; OR Measuring the AST to determine its capacity. In the case of double-wall tanks, the dimensions of the inner tank will determine the capacity. Completed Buried Tank: any container completely below grade and covered with earth, sand, gravel, asphalt or other material. Containers in vaults, bunkered tanks, or partially buried tanks are considered above ground storage containers. MR Envlronment;til Irie Envl<a, ,Ottu Health&SatetySolutloo, Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 66 Appendix 4 Page 191 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 Discharge: includes, but is not limited to, any spilling, leaking, pumping, pouring, emitting, emptying, or dumping of oil into or upon the navigable waters of the United States or adjoining shorelines, or into or upon the waters of the contiguous zone, or in connection with activities under the Outer Continental Shelf Lands Act or the Deep water Port Act of 1974, or that may affect natural resources belonging to, appertaining to, or under the exclusive management authority of the United States (including resources under the Magnuson Fishery Conservation and Management Act) OW: Double walled. Facility: any mobile or fixed onshore or offshore building, structure, installation, equipment, pipe, or pipeline (other than a vessel or a public vessel) used in oil well drilling operations ... oil storage, oil gathering, oil processing, oil transfer, oil distribution, and waste treatment, or in which oil is used. The boundaries of a facility depend on several site-specific factors, including, but not limited to, the ownership or operation of buildings, structures, and equipment on the same site and the types of activity at the site. MPC: motive power containers means any onboard bulk storage container used primarily to power the movement of a motor vehicle, or ancillary onboard oil-filled operational equipment. An onboard bulk storage container which is used to store or transfer oil for further distribution is not a motive power container. The definition of motive power container does not include oil drilling or workover equipment, including rigs. OFOE: 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. Oilfilled 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 MR 6nvlranme:ntat Inc Envi .Ocru Health&Safl!fySdu!Jon1 Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 67 Appendix 4 Page 192 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 pump jack 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. Oil: oil of any kind or in any form, including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with wastes other than dredged spoil. Onshore Facility: any facility of any kind located in, on, or under any land within the United States, other than submerged lands. Owner or Operator: any person owning or operating an onshore facility. Permanently closed: any container or facility for which: 1. All the liquid and sludge has been removed from the container and connecting line; and 2. All connecting pipes and lines have been disconnected from the container and blanked off, all valves (except for ventilation valves) have been closed and locked, and conspicuous signs have been posted on each container stated that it is a permanently closed container and noting the date of such closure. SPCC Plan: the document required by 40 CFR 112.3 that details the equipment, workforce, procedures, and steps to prevent, control, and provide adequate countermeasures to a discharge. MR Envtronrn,nc.al lnc fmtronrn.-QJ,Cka,pajonalHallh&s.fiKV5alUtlOIH Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 68 Appendix 4 Page 193 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 DEFINITIONS PER STI/SPFA SP001 STANDARD (INSPECTION OF ABOVEGROUND STORAGE TANKS) CERTIFIED INSPECTOR -A tank inspector who meets the certification requirements identified in Section 4.2 of the STI/SPFA Standard. COATING FAILURE - Significant peeling, cracking, spalling, blistering, pitting, chipping, etc. of the coating, paint or lining on an AST, resulting in the exposure of the metal surface and corrosion of the tank shell. CONCRETE EXTERIOR ABOVEGROUND STORAGE TANK (CE-AST) - A shopfabricated aboveground storage tank that includes a concrete exterior. A CE-AST with a UL 2085 label has integral secondary containment that allows monitoring for leakage in the interstice between the primary tank and the secondary containment. CONTINUOUS RELEASE DETECTION METHOD (CRDM): A means of detecting a release of liquid through inherent design. CROM is passive because it does not require sensors or power to operate. Liquid releases are visually detected by facility operators (See Appendix A of the STI/SPFA Standard for additional information). The system shall be designed in accordance with good engineering practice. Several acceptable and commonly used CROM systems are: Release prevention barrier (RPB) (described in definition of "Release prevention barrier'') Double-wall AST or double-bottom AST Elevated AST, with or without release prevention barrier Steel diked AST, open or closed top Concrete exterior AST (CE-AST) with an integral secondary containment and interstitial monitoring opening MR Envl,onm nu11 In, fnwoornaiUl,Ckcupatluf>llHullh4,Satfly5<,lutlun1 Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 69 Appendix 4 Page 194 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 CONNECTION - A method or fitting for fastening a pipe to the AST or an appurtenance. Examples are flanges, pipe threads, pipe welds, expansion joints, and flexible fittings. CORROSION RATE - The rate of degradation of a material due to a chemical reaction with its environment. DOUBLE-BOTTOM AST - An AST with a bottom plate integral to the primary container and a second bottom plate designed to provide an interstice. The interstice allows testing of both bottoms for tightness, or monitoring for leakage into the space. DOUBLE-WALL AST - An AST manufactured as a tank-within-a-tank. The second tank provides integral secondary containment. An interstitial space between the two tanks is formed, which allows testing of both tanks for tightness, as well as monitoring for leakage into the space. DYE PENETRANT TESTING (DT) - a method for nondestructively testing the surface of a material. A liquid dye is applied to the surface and excess is removed. A developing solution is then applied which indicates cracks in the material. ELEVATED AST-An AST, which is not in contact with the ground, and which is raised above the surface of the ground or bottom of a vault using tank supports. An elevated AST allows for a visual, external inspection of the bottom of the tank. FIELD-ERECTED AST: a welded metal AST erected on-site where it will be used. For the purpose of this standard, ASTs meeting either of the following descriptions are to be inspected as field-erected ASTs: a. The AST's nameplate (or other identifying means, such as accurate drawings) indicates that it is a field-erected AST with a maximum shell height of 50 feet (15.24 meters) and a maximum diameter of 30 feet (9.14 meters). MR Envlronmental 1nc Emirm,menul,Oro.J H&llh& Soluoon1 Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 70 Appendix 4 Page 195 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 b. The AST has no nameplate (or other identifying means such as accurate drawings), and is more than 75,000 U.S. gallons (283,906 liters) with a maximum shell height of 50 feet (15.24 meters) and a maximum diameter of 30 feet (9.14 meters). FORMAL EXTERNAL INSPECTION (FEI): a documented external inspection conducted by a certified inspector to assess the condition of the AST and determine its suitability for continued service without entry into the AST interior. FORMAL INTERNAL INSPECTION (FIi): a documented internal inspection conducted by a Certified Inspector to assess the internal and external condition of the AST and determine its suitability for continued service. A FIi includes the inspection requirements of a FEI, therefore, a FIi satisfies the requirements of a FEI and shall be considered equivalent to or better than a FEI for the purposes of inspection scheduling. Requires entry into the AST interior following emptying and cleaning. See Section 3 for guidance on cleaning and entry safety considerations. INSPECTION PLAN - A written plan developed by the owner/operator, Certified Inspector or a Professional Engineer that details the inspection requirements for a facility. INTERSTICE - In a double-wall AST, the space between the primary tank and secondary tank; in a double-bottom AST, the space or void between the two bottoms. This space may be open or closed to the atmosphere and may be monitored or tested by vacuum or leak detection equipment or by visual inspection. INITIAL SERVICE DATE - The date on which liquid was first placed in the AST. LEAK TESTING METHOD (LTM): a point-in-time test method to determine if an AST is liquid-tight. Leak testing is not preventive: it provides an indication only of whether the AST's integrity has already been breached. Therefore, it may only be used as a tank MR Env1ronm1e:n1ra.l Inc .OcnlpatmNIHMlth&SimySnlullont Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 71 Appendix 4 Page 196 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 integrity measure or as a supplement to other inspection procedures. LTMs may include the following technologies: 1. Gas pressure decay (includes vacuum decay) 2. Gas pressure soap bubble testing 3. Gas tracers (e.g., helium tracer) 4. Soil tracers (chemical marker) 5. Mass measurement 6. Level measurement 7. Hydrostatic test LOCKOUTITAGOUT - A procedure for affixing lockout or tagout devices to energyisolating equipment and otherwise disabling machines or equipment to prevent unexpected energization, startup, or release of stored energy. The intent of the procedure is to prevent injury to employees and to comply with the following Occupational Safety & Health Administration (OSHA) regulations or their equivalent: 29 CFR Part 1910.147, The Control of Hazardous Energy (Lockout/Tagout) 29 CFR Part 1910.333, Electrical Lockout/Tagout 1926.1200 Subpart AA Confined Space in Construction MAGNETIC FLUX LEAKAGE (MFL) - A method used to nondestructively inspect ferromagnetic materials, such as a carbon steel floor plate. A magnetic field is applied to steel to near-saturation, so that it cannot hold any additional field. In the presence of a flaw (wall thinning), some of the magnetic flux escapes or "leaks" into the surrounding environment, where magnetic sensors detect it and qualitatively report a flaw signal. This method is commonly used on AST floors (MFL floor scan) to determine the underside condition of the tank floor. MAGNETIC PARTICLE TESTING {MT)-A method used to nondestructively inspect ferromagnetic materials, such as a carbon steel. It is used for detecting surface and MR Envlronmental Inc CIMn)llrntl'IUl,OuuPitioNllwlth&Sm!y50h<tioni Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 72 Appendix 4 Page 197 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 subsurface linear discontinuities by inducing a magnetic field into the material and applying iron oxide particles. MANWAY -An opening designed to allow personnel entry into an AST. MICROBIAL-INFLUENCED/INDUCED CORROSION (MIC) - Corrosion caused or accelerated by certain microbes. Depending on the type of bacteria, the degree of microbial activity, and the thickness and type of AST material, MIC is characterized by a high rate of corrosion. It sometimes penetrates tank walls and bottoms in two years or less. It is typically characterized by a ring-like pattern of crater-shaped or channel-like penetrations. NONDESTRUCTIVE TESTING (NDT) - The development and application of technical methods to examine materials and/or components in ways that do not impair future usefulness and serviceability, in order to detect, locate, measure, interpret, and evaluate flaws. OVERFILL PREVENTION - Systems, procedures or devices used to prevent liquid in ASTs from running over or spilling out of the AST during the filling process. A person who is physically present and in control of a shutoff device during the entire tank filling process is an acceptable procedure to achieve overfill prevention. OWNER - The legal entity having control and responsibility for the operation of the existing AST and storage facilities. OWNER'S INSPECTOR - The owner or owner's designee responsible for conducting owner's periodic AST inspections. A,O IEnvlron,nen,rat Inc nvlrn-,ment.al .Ckcupmmal lifllllh&!i.ifnv 'ialu!lont Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 73 Appendix 4 Page 198 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 PERIODIC AST INSPECTION - A visual, documented inspection conducted by an owner's inspector to assess the AST's general condition without suspending AST operations or removing the AST from service. PORTABLE CONTAINER - A closed AST having a liquid capacity equal to or greater than 55 U.S. gallons and not intended for fixed installation. This definition does not include a mobile storage container on a vehicle, or one being towed, that is used to store and transport liquids for transfer into or from vehicles, mobile equipment, or another storage container. This definition also does not include storage containers used for onboard propulsion of a vehicle. PRIMARY TANK- The tank in direct contact with the liquid stored. PROFESSIONAL ENGINEER (PE) - A person who has fulfilled specific education and/or experience requirements under state licensure laws and has received a license to practice engineering. RELEASE PREVENTION BARRIER (RPB) - A liquid containment barrier that is installed under the AST. Its purpose is to divert leaks toward the perimeter of the AST where they can be easily detected, as well as to prevent liquid from contaminating the environment. RPBs are composed of materials compatible with the liquid stored in the AST and meet appropriate engineering standards. Examples are steel (as in steel double-bottom tanks), concrete, elastomeric liners, or other suitable materials, provided the above criteria are met. REMOTE IMPOUNDING - A spill control system that uses a sloped spillway or drainage system to channel liquid releases away from an AST to a contained collection area that is remote from important facilities, adjoining property, or waterways. The containment area is sized for the capacity of the largest AST, plus sufficient freeboard to allow for MR E11v1ronrnentJ.I In( Envlmnrntnl.il,Ottu nalHeahh&SR!ySdutloll1 Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 74 Appendix 4 Page 199 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 precipitation. For the purposes of this Standard, remote impounding is equivalent to secondary containment. Remote impounding is further defined in NFPA 30. SECONDARY CONTAINMENT DIKE/BERM -A spill control system consisting of walls and a floor completely surrounding single or multiple ASTs. It provides a secondary means of containment for the entire capacity of the largest single AST, plus sufficient freeboard to contain precipitation and the displacement volume present below the dike wall of other ASTs in the containment area. The secondary containment dike/berm is to be constructed according to accepted good engineering practices. (Note: See NFPA 30, 40 CFR Part 112, and/or other local requirements for additional requirements.) SECONDARY CONTAINMENT SYSTEM - Provides a secondary means of containment for the entire volumetric capacity of the largest single AST within a dike/berm plus sufficient freeboard to contain precipitation. The secondary containment system is to be designed to contain a spill until it can be discovered and cleaned up. It must be constructed according to accepted good engineering practices. (Note: See NFPA 30 and/or 40 CFR Part 112, and/or other local requirements for additional requirements.) STEEL DIKED AST - An AST with an integral steel secondary containment dike. These dikes may be pans, boxes, or containers, and are designed to contain the contents of the primary tank if it fails. A steel diked AST may be open or closed to the atmosphere. Closed-top steel dike ASTs have welded covers or movable rain shields to keep precipitation from collecting in the dike, but open-top dike ASTs do not have such covers. The secondary containment of steel diked ASTs must be sized to contain the primary tank volume, plus sufficient freeboard to contain precipitation as necessary. SECONDARY TANK -The outer wall of a double-wall AST. MR E n v l r on r n t n t a l , Inc .... Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 75 Appendix 4 Page 200 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 SHELL - For the purposes of this Standard, the AST shell includes the roof, bottom, head, and wall of the AST. Refer to Appendix A of the STI/SPFA Standard for more information. SHOP-FABRICATED AST-A welded carbon steel or stainless steel AST fabricated in a manufacturing facility or an AST not otherwise identified as field-erected, with a volume less than or equal to 75,000 U.S. gallons (283,906 liters). SINGLE-WALL AST - An AST with only one wall or shell. SPILL CONTROL - A means of preventing a release of liquid to the environment, including adjoining property and waterways. Spill control methods include: Remote impounding Secondary containment system Secondary containment dike/berm Open top steel diked AST Closed top steel diked AST with overfill prevention Double-wall AST with overfill prevention CE-AST with overfill prevention SUITABILITY FOR CONTINUED SERVICE - The determination that an AST's condition is adequate for continued use, based on the criteria presented in this Standard. TANK SUPPORTS - Structures designed to elevate an AST above the ground. These include saddles, skids, beams, legs, and similar structures. TELLTALE HOLE OR OPENING- An opening in a reinforcing plate that allows for leak monitoring where a tank penetration hole in the shell has been reinforced with a welded reinforcing plate. MR Envlrorimen,11.I Inc &MrllnrnonuJ, Ocrupajooll Huth &Slfl!ty'duuunl Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 76 Appendix 4 Page 201 of 202 NATURE ENVIRONMENTAL AND MARINE SERVICES, LLC, 18511 Beaumont Hwy, Houston, TX 77049 THERMOPLASTIC - substances, such as asphalt cement, that are solid at ambient temperature and become molten upon heating. The application of this Standard is for thermoplastics stored in a liquid form. ULTRASONIC TESTING SCAN (UTS) - An ultrasonic scan to evaluate the corrosion on the opposite side of the inspection surface using an ultrasonic flaw detector. This inspection is to be performed by an NOT examiner certified in accordance with ASNT-TC1A (or equivalent), per paragraph 4.3.2 of the STI/SPFA Standard. ULTRASONIC THICKNESS TESTING (UTT) - A point thickness reading taken by a competent person, per paragraph 4.3.3 of the STI/SPFA Standard, utilizing a digital ultrasonic thickness meter. VACUUM BOX EXAMINATION (VB)-A weld-testing method used to check for leaks in the welds of the shell of an AST. MR EnvlroJ1m@:ntal Inc o.n.: .1,.....aw,,,w.i... Two Riverway, Suite 1780 Houston, TX 77056 Toll Free: Tel: (833) 493-AARC Fax: (833) 771-AARC 1994-2018 Page 77 Appendix 4 Page 202 of 202 APPENDIX 5. NATURE ENVIRONMENTAL CONTINGENCY PLAN Appendix 5 Page 1 of 8 Appendix 5 Page 2 of 8 Appendix 5 Page 3 of 8 Appendix 5 Page 4 of 8 Appendix 5 Page 5 of 8 Appendix 5 Page 6 of 8 Appendix 5 Page 7 of 8 Appendix 5 Page 8 of 8 APPENDIX 6. NATURE ENVIRONMENTAL OIL HANDLER ANALYSIS PLAN Appendix 6 Page 1 of 12 Appendix 6 Page 2 of 12 Appendix 6 Page 3 of 12 Appendix 6 Page 4 of 12 Appendix 6 Page 5 of 12 Appendix 6 Page 6 of 12 Appendix 6 Page 7 of 12 Appendix 6 Page 8 of 12 Appendix 6 Page 9 of 12 Appendix 6 Page 10 of 12 Appendix 6 Page 11 of 12 Appendix 6 Page 12 of 12 APPENDIX 7. NATURE ENVIRONMENTAL OIL TESTING FROM APRIL 2024 Appendix 7 Page 1 of 9 Appendix 7 Page 2 of 9 Appendix 7 Page 3 of 9 Appendix 7 Page 4 of 9 Appendix 7 Page 5 of 9 Appendix 7 Page 6 of 9 Appendix 7 Page 7 of 9 Appendix 7 Page 8 of 9 Appendix 7 Page 9 of 9