Loading...
HomeMy WebLinkAbout1.05 SPCC PlanWestern Slope Materials SPCC Plan – North Hangs Mine November 2021 Prepared by: II Lewicki & Associates SPCC - North Hangs Mine November 2021 Table of Contents INTRODUCTION 1 PART 1: PLAN ADMINISTRATION 3 1.1 Management Approval and Designated Person (40 CFR 112.7) ...................................3 1.2 Professional Engineer Certification (40 CFR 112.3(d)) ..................................................4 1.3 Location of SPCC Plan (40 CFR 112.3(e)) ....................................................................5 1.4 Plan Review (40 CFR 112.3 and 112.5) ........................................................................5 1.5 Facilities, Procedures, Methods, or Equipment Not Yet Fully Operational (40 CFR 112.7) 6 1.6 Cross-Reference with SPCC Provisions (40 CFR 112.7) ..............................................6 PART 2: GENERAL FACILITY INFORMATION 9 2.1 Facility Description (40 CFR 112.7(a)(3)) ......................................................................9 2.1.1 Location and Activities ...............................................................................................9 2.2 Evaluation of Discharge Potential ...............................................................................11 PART 3: DISCHARGE PREVENTION - GENERAL SPCC PROVISIONS 12 3.1 Compliance with Applicable Requirements (40 CFR 112.7(a)(2)) ...............................12 3.2 Facility Layout Diagram (40 CFR 112.7(a)(3)) .............................................................12 3.3 Spill Reporting (40 CFR 112.7(a)(4))...........................................................................12 3.4 Potential Discharge Volumes and Direction of Flow (40 CFR 112.7(b)) ......................12 3.5 Containment and Diversionary Structures (40 CFR 112.7(c))......................................14 3.6 Practicability of Secondary Containment (40 CFR 112.7(d)) .......................................14 3.7 Inspections, Tests, and Records (40 CFR 112.7(e)) ...................................................14 3.9 Security (40 CFR 112.7(g)) .........................................................................................23 3.10 Tank Truck Loading/Unloading Rack Requirements (40 CFR 112.7(h)) ..................23 3.11 Brittle Fracture Evaluation (40 CFR 112.7(i)) ...........................................................25 3.12 Conformance with State and Local Applicable Requirements (40 CFR 112.7(j)) .....25 PART 4: DISCHARGE PREVENTION – SPCC Provisions for Onshore Facilities (Excluding Production Facilities) 26 4.1 Facility Drainage (40 CFR 112.8(b))............................................................................26 4.2 Bulk Storage Containers (40 CFR 112.8(c)) ................................................................27 4.3 Transfer Operations, Pumping, and In-Plant Processes (40 CFR 112.8(d)) ................32 II Lewicki & Associates SPCC - North Hangs Mine November 2021 PART 5: DISCHARGE RESPONSE 34 5.1 Minor Spill Response .....................................................................................................35 5.2 Response to a Major Discharge .......................................................................................36 5.3 Waste Disposal ..............................................................................................................37 5.4 Spill Notification Forms and Discharge Notification ......................................................37 5.5 Cleanup Contractors and Equipment Suppliers ...............................................................38 APPENDIX A – FIGURES 44 APPENDIX B – ULTRASONIC SHELL TEST PROTOCOL 45 II Lewicki & Associates SPCC - North Hangs Mine November 2021 1 INTRODUCTION Purpose The purpose of this Spill Prevention, Control, and Countermeasure (SPCC) Plan is to describe measures implemented by Western Slope Materials to prevent oil discharges from occurring, and to prepare Western Slope Materials to respond in a 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). 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 employees, as a guide to facility inspections, and as a resource during emergency response. Western Slope Materials management has determined that this facility does not pose a risk of substantial harm under 40 CFR part 112, as recorded in the “Substantial Harm Determination” included in this Plan. This Plan provides guidance on key actions that Western Slope Materials 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 3.7) using the inspection checklists. • 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 Spill Prevention Procedures section of this Plan (Section 3.8) and document them on the log. • If either of the following occurs, submit the SPCC Plan to the EPA Region 8 Regional Administrator (RA) and the Colorado Department of Public Health and Environment (CDPHE), along with other information as detailed in Section 5 of this Plan: o 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 o 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 on the certification page in Section 1.2 of this Plan. • Amend the SPCC Plan within six (6) months whenever where is a change in facility design, construction, operation, or maintenance that materially affects the facility’s spill potential. The revised Plan must be recertified by a Professional Engineer (PE). II Lewicki & Associates SPCC - North Hangs Mine November 2021 2 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, such as phone numbers. Administrative changes must be documented in the Plan review log, but do not have to be certified by a PE. II Lewicki & Associates SPCC - North Hangs Mine November 2021 3 PART 1: PLAN ADMINISTRATION 1.1 Management Approval and Designated Person (40 CFR 112.7) Western Slope Materials is committed to preventing discharges of oil to navigable waters and the environment, and to maintaining the highest standards for spill prevention control and countermeasures through the implementation and regular review and amendment to the Plan. This SPCC Plan has the full approval of Western Slope Materials management. Western Slope Materials has committed the necessary resources to implement the measures described in this Plan. The Facility Manager 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 (facility response coordinator): ______________________________ Signature: Title: Date: II Lewicki & Associates SPCC - North Hangs Mine November 2021 4 1.2 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 the facility. [40 CFR 112.3(d)] 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 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. 1.2.1 Required Improvements The Professional Engineer’s certification of this plan is contingent on the following facility improvements being implemented for compliance with SPCC regulations 40 CFR 112: 1) Stormwater control structure must be installed along the perimeter of the processing area to separate from adjacent uses. Complete within the first six months following the start of mining. Name: State and Registration #: II Lewicki & Associates SPCC - North Hangs Mine November 2021 5 1.3 Location of SPCC Plan (40 CFR 112.3(e)) In accordance with 40 CFR 112.3(e)(2), a complete copy of this SPCC Plan is maintained at the Western Slope Materials mine in Silt, CO. 1.4 Plan Review (40 CFR 112.3 and 112.5) 1.4.1 Changes in Facility Configuration In accordance with 40 CFR 112.5(a), Western Slope Materials 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 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. Non-technical 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. Western Slope Materials must make the needed revisions to the SPCC Plan as soon as possible, but no later than six 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. 1.4.2 Scheduled Plan Reviews In accordance with 40 CFR 112.5(b), Western Slope Materials 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). This Plan is dated November 8, 2021. The next plan review is therefore scheduled to take place on or prior to Date, 202 6. 1.4.3 Record of Plan Reviews Scheduled reviews and Plan amendments are recorded in the Plan Review Log. This log must 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 must occur by October ##, 2026. II Lewicki & Associates SPCC - North Hangs Mine November 2021 6 1.5 Facilities, Procedures, Methods, or Equipment Not Yet Fully Operational (40 CFR 112.7) Bulk storage containers at this facility have never been tested for integrity since their installation. Section 4.2.6 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 must be tested. 1.6 Cross-Reference with SPCC Provisions (40 CFR 112.7) This SPCC Plan does not follow the exact order presented in 40 CFR part 112. Section headings identify, where appropriate, the relevant section(s) of the SPCC rule. Table 1-2 presents a cross- reference of Plan sections relative to applicable parts of 40 CFR part 112. II Lewicki & Associates SPCC - North Hangs Mine November 2021 7 Table 1-1: Plan Review Log By Date Activity PE certification required? Comments Ben Langenfeld MONTH ##, 2021 Writing plan Yes Initial SPCC plan II Lewicki & Associates SPCC - North Hangs Mine November 2021 8 Table 1-2: SPCC Plan Cross-Reference with CFR Provision Plan Section Page 112.3(d) Professional Engineer Certification 4 112.3(e) Location of SPCC Plan 5 112.5 Plan Review 5 112.7 Management Approval 3 112.7 Cross-Reference with SPCC Rule 8 112.7(a)(3) Site Plan and Facility Diagram 12 and Appendix A 112.7(a)(4) Spill/Discharge Notification 41 112.7(a)(5) Part 5: Discharge Response 35 112.7(b) 3.4 Potential Discharge Volumes and Direction of Flow 12 112.7(c) 3.5 Containment and Diversionary Structures 14 112.7(d) 3.6 Practicability of Secondary Containment 14 112.7(e) 3.7 Inspections, Tests, and Records 14 112.7(f) 3.8 Personnel, Training and Discharge Prevention Procedures 21 112.7(g) 3.9 Security 23 112.7(h) 3.10 Tank Truck Loading/Unloading 23 112.7(i) 3.11 Brittle Fracture Evaluation 25 112.7(j) 3.12 Conformance with Applicable State and Local Requirements 25 112.8(b) 4.1 Facility Drainage 26 112.8(c)(1) 4.2.1 Construction 28 112.8(c)(2) 4.2.2 Secondary Containment 28 112.8(c)(3) 4.2.3 Drainage of Diked Areas 28 112.8(c)(4) 4.2.4 Corrosion Protection 28 112.8(c)(6) 4.2.6 Inspection - Facility Inspection Checklists 28 112.8(c)(8) 4.2.8 Overfill Prevention System 32 112.8(c)(10) 4.2.10 Visible Discharges 32 112.8(c)(11) 4.2.11 Mobile and Portable Containers 32 112.8(d) 4.3 Transfer Operations, Pumping and In- Plant Processes 32 112.20(e) Certification of Substantial Harm Determination 42 II Lewicki & Associates SPCC - North Hangs Mine November 2021 9 PART 2: GENERAL FACILITY INFORMATION Name: Western Slope Materials – North Hangs Mine Address: 6533 346 County Rd Silt, CO 81652 Type: Concrete Batch Plant Facility Date of Initial Operations: Not yet in operation Owner/Operator: Western Slope Materials, LLC PO Box 1319 Carbondale, CO 81623 Primary contact: Sean Mello Work: 970 963-2296 Cell (24 hours): 970 379-0427 2.1 Facility Description (40 CFR 112.7(a)(3)) 2.1.1 Location and Activities The North Hangs Mine is located approximately one mile southwest of Silt, CO in Garfield County. The mine will contain a permanent concrete batch plant to process the aggregate material being mined on site. The concrete that is produced will be shipped offsite for use in construction. Concrete truck washing and waste concrete storage will also take place onsite. Oil storage consists of diesel fuel for the plant and onsite off-highway equipment. Small quantities of oil and grease is also stores onsite for equipment maintenance. II Lewicki & Associates SPCC - North Hangs Mine November 2021 10 2.1.2 Oil and Fuel Storage The capacities of oil containers present at the site are listed below and are also indicated on the facility diagram in the facility layout. All containers with a capacity of 55 gallons or more are included. Table 2-1: Oil Containers ID Content Size Location Secondary Containment DB1 Diesel 10,000 Northeast side of processing area Double walled DB2 Diesel 5,000 Northeast side of processing area Double walled DB3 Diesel 2,000 Northeast side of processing area Double walled Other Containers: 1. Various other tanks associated with mobile equipment used for the sole purpose of motive power. These tanks are not regulated under the SPCC rule. See 40 CFR 112.1(d)(2)(ii)(B) II Lewicki & Associates SPCC - North Hangs Mine November 2021 11 2.2 Evaluation of Discharge Potential 2.2.1 Distance to Navigable Waters and Adjoining Shorelines and Flow Paths The nearest navigable water is the Colorado River, which is directly to the north of the site. Stormwater discharges are made to transport to the Colorado River via existing drainage swale s on undisturbed areas of the site or the Bernudy ditch. 2.2.2 Discharge History Table 2-1 summarizes the facility’s discharge history. Table 2-2: Oil Discharge History Description of Discharge Corrective Actions Taken Plan for Preventing Recurrence No Discharges II Lewicki & Associates SPCC - North Hangs Mine November 2021 12 PART 3: DISCHARGE PREVENTION - GENERAL SPCC PROVISIONS 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. 3.1 Compliance with Applicable Requirements (40 CFR 112.7(a)(2)) Diesel tank (DB1) has double walls have leak detection equipment. All other chemical tanks are stored within a building where leaks can be inspected for visually at any time. 3.2 Facility Layout Diagram (40 CFR 112.7(a)(3)) The Facility Layout presents a layout of the facility and the location of storage tanks and drums. As required under 40 CFR 112.7(a)(3), the facility diagram indicates the location and content of AST. 3.3 Spill Reporting (40 CFR 112.7(a)(4)) The discharge notification form will be completed upon detection of a discharge by the Environmental Manager and prior to reporting a spill to the proper notification contacts. 3.4 Potential Discharge Volumes and Direction of Flow (40 CFR 112.7(b)) Table 3-1 presents expected volume, discharge rate, general direction of flow in the event of equipment failure and means of secondary containment for different parts of the facility where oil is stored, used, or handled. The Facility Layout shows the tank locations in plan view. II Lewicki & Associates SPCC - North Hangs Mine November 2021 13 Table 3-1: Potential Discharge Volumes and Direction of Flow Potential Event Maximum volume released (gallons) Maximum discharge rate Direction of Flow Secondary Containment Failure of aboveground tank (collapse or puncture below product level) 10,000 Gradual to instantaneous Southwest Tank double wall Tank overfill 1 to 120 60 gal/min Varies Concrete berm around DB1 Pipe failure 100 50 gal/min Varies Land-based spill response capability (spill kit) Leaking pipe or valve packing 100 1 gal/min Varies Land-based spill response capability (spill kit) Diesel dispenser hose/ connections leak 1 to 150 30 gal/minute Varies Land-based spill response capability (spill kit) Leak or failure of drum 1 to 55 Gradual to instantaneous Varies Storage building walls II Lewicki & Associates SPCC - North Hangs Mine November 2021 14 3.5 Containment and Diversionary Structures (40 CFR 112.7(c)) Methods of secondary containment at this facility include a combination of structures (e.g., concrete berm, building walls) and land-based spill response (e.g., sorbents) to prevent oil from reaching the nearest drainage. The capacities of the containment are shown in Table 2-1. • For bulk storage containers (refer to Section 4.2.2 of this Plan): o Diesel tank DB1 • In transfer areas and other parts of the facility where a discharge could occur: o Drip pans. Fill ports for all ASTs are equipped with drip pans to contain small leaks from the piping/hose connections. o Sorbent material. a Spill cleanup kit of at least 90 gallons or more that include absorbent material, booms, and other portable barriers is located in the Storage Building as shown on the Facility Layout. The spill kit is located within close proximity of the chemical storage and handling areas for rapid deployment should a spill occur. 3.6 Practicability of Secondary Containment (40 CFR 112.7(d)) Western Slope Materials management has determined that secondary containment is practicable at this facility. 3.7 Inspections, Tests, and Records (40 CFR 112.7(e)) As required by the SPCC rules, Western Slope Materials performs the inspections, tests, and evaluations listed in the following Table 3-2. The table summarizes the various types of inspections and tests performed at the facility. The inspections and tests are described later in this section, and in the respective sections that describe different parts of the facility (e.g., Section 4.2.6 for bulk storage containers). II Lewicki & Associates SPCC - North Hangs Mine November 2021 15 Table 3-2: Inspection and Testing Program Facility Component Action Frequency/Circumstances Aboveground container with all sides visible Test container integrity by conducting visual inspection. Inspect outside of container for signs of deterioration and discharges. Following a regular schedule (monthly, annual, and during scheduled inspections) and whenever material repairs are made. Container supports and foundation Inspect container’s supports and foundations. Following a regular schedule (monthly, annual, and during scheduled inspections) and whenever material repairs are made. Liquid level sensing devices (overfill) Test for proper operation. Monthly Diked area, lined berms and site berms Inspect for signs of deterioration, discharges, or accumulation of oil inside diked areas. Visually inspect content for presence of oil. Monthly Prior to draining All aboveground valves, piping, and appurtenances 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. Monthly Buried piping Inspect for deterioration. Integrity and leak testing. Whenever a section of buried line is exposed for any reason. At the time of installation, modification, construction, relocation, or replacement. Note: If any above ground container is added to the site at a later date, where all sides are not visible, alternative testing requirements will be needed and the plan will need to be modified. II Lewicki & Associates SPCC - North Hangs Mine November 2021 16 3.7.1 Daily Inspection A Western Slope Materials employee performs a complete walk-through of the facility each day during normal operation. This daily visual inspection involves: looking for tank/piping damage or leakage, stained or discolored soils, or excessive accumulation of water in the containment. All types of secondary containment should be visually checked for damage. 3.7.2 Monthly Inspection The checklist provided is used for monthly inspections by Western Slope Materials personnel. The monthly inspections cover the following key elements: • Observing the exterior of aboveground storage tanks, 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 tank foundations and supports for signs of instability or excessive settlement. • Observing the tank fill and discharge pipes for signs of poor connection that could cause a discharge, and tank vent for obstructions and proper operation. • Verifying the proper functioning of overfill prevention systems. • Checking the inventory of discharge response equipment and restocking as needed. • Check all types of secondary containment on site for damage. All problems regarding tanks, piping, containment, or response equipment must immediately be reported to the Facility Manager. Visible oil leaks from tank walls, piping, or other components must be repaired as soon as possible to prevent a larger spill or a discharge to navigable waters or adjoining shorelines. Pooled oil is removed immediately upon discovery. The Monthly Inspection Checklist is included in this section and the inspection will be conducted during normal operation of the site. Written monthly inspection records are signed by the Facility Manager and maintained with this SPCC Plan for a period of five years. Monthly Inspection Checklist This inspection record must be completed each month except the month in which an annual inspection is performed or during normal site closure. Provide further description and comments, if necessary, on a separate sheet of paper and attach to this sheet. *Any item that receives “yes” as an answer must be described and addressed immediately. II Lewicki & Associates SPCC - North Hangs Mine November 2021 17 Monthly Inspection Checklist Y* N Description & Comments Storage tanks Tank surfaces show signs of leakage Tanks are damaged, rusted or deteriorated Tank supports are deteriorated or buckled Tank foundations have eroded or settled Level gauges or alarms are inoperative Vents are obstructed Precipitation present in secondary containment Secondary containment is damaged or stained Site berms are Damaged Piping Valve seals, gaskets, or other appurtenances are leaking Pipelines or supports are damaged or deteriorated Joints, valves and other appurtenances are leaking Buried piping is exposed Loading/unloading and transfer equipment Connections are not capped or blank-flanged Security Fencing, gates, or lighting is non-functional Pumps and valves are locked if not in use Response Equipment Response equipment inventory is complete Date: ____________ Signature: _________________________ II Lewicki & Associates SPCC - North Hangs Mine November 2021 18 3.7.3 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 is performed in March of each year using the checklist provided. The Annual Inspection Checklist is included in this section. The annual inspection is preferably performed after a large storm event in order to verify the imperviousness and/or proper functioning of drainage control systems such as the site berms, concrete lined dikes, lined berms and control valves. Written annual inspection records are signed by the Facility Manager and maintained with this SPCC Plan for a period of five years. Annual Inspection Checklist This inspection record must be completed each year. Provide further description and comments, if necessary, on a separate sheet of paper and attach to this sheet. *Any item that receives “yes” as an answer must be described and addressed immediately. II Lewicki & Associates SPCC - North Hangs Mine November 2021 19 Annual Inspection Checklist Y* N Description & Comments Storage tanks Tank surfaces show signs of leakage Tanks are damaged, rusted or deteriorated Tank supports are deteriorated or buckled Tank foundations have eroded or settled Level gauges or alarms are inoperative Vents are obstructed Precipitation present in secondary containment Secondary containment is damaged or stained Piping Valve seals, gaskets, or other appurtenances are leaking Pipelines or supports are damaged or deteriorated Joints, valves and other appurtenances are leaking Buried piping is exposed Loading/unloading and transfer equipment Connections are not capped or blank-flanged Secondary Containment Site berm is not preventing dischage Concrete Bunker is damaged or stained Security Fencing, gates, or lighting is non-functional Pumps and valves are locked if not in use II Lewicki & Associates SPCC - North Hangs Mine November 2021 20 Y* N Description & Comments Response Equipment Response equipment inventory is complete Date: ____________ Yr: _________ Signature: _________________________ Annual reminders: * Hold SPCC Briefing for all oil-handling personnel (and update briefing log in the Plan); * Check contact information for key employees and response/cleanup contractors and update them in the Plan as needed; II Lewicki & Associates SPCC - North Hangs Mine November 2021 21 3.7.4 Periodic Integrity Testing In addition to the above monthly and annual inspections by facility personnel, Tank integrity is verified with the leak detection system. 3.8 Personnel, Training, and Discharge Prevention Procedures (40 CFR 112.7(f)) The Facility Manager is the facility designee and is responsible for oil discharge prevention, control, and response preparedness activities at this facility. Western Slope Materials management has instructed 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. Annual discharge prevention briefings are held by the Facility Manager 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 Training Form and maintained with this SPCC Plan for a period of five years. Record of Annual Discharge Prevention Training Form 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. II Lewicki & Associates SPCC - North Hangs Mine November 2021 22 Briefings and Training Date Subjects Covered Employees in Attendance Instructor(s) II Lewicki & Associates SPCC - North Hangs Mine November 2021 23 3.9 Security (40 CFR 112.7(g)) Since this is a portable plant, the site security cannot be outlined, however, Western Slope Materials takes steps at each site to ensure they are safe and secure. 3.10 Tank Truck Loading/Unloading Rack Requirements (40 CFR 112.7(h)) The potential for discharges during tank truck loading and unloading operations is addressed at each facility using site berms. Western Slope Materials management is committed to ensuring the safe transfer of material to and from storage tanks. The following measures are implemented to prevent oil discharges during tank truck loading and unloading operations. 3.10.1 Secondary Containment (40 CFR 112.7(h)(1)) All drums and tanks have secondary containment. The containment consists of structures directly around the tanks and the site berm which is the end of the flow path. The plant has sufficient capacity to collect all tank capacity plus precipitation. All loading areas have drip pans to be used during the disconnection of transfer hoses. 3.10.2 Loading/Unloading Procedures (40 CFR 112.7(h)(2) and (3)) All suppliers must meet the minimum requirements and regulations for tank truck loading/unloading established by the U.S. Department of Transportation. Western Slope Materials ensures that the vendor understands the site layout, knows the protocol for entering the facility and unloading product, and has the necessary equipment to respond to a discharge from the vehicle or fuel delivery hose. The Facility Manager or his/her designee supervises oil deliveries for all new suppliers, and periodically observes deliveries for existing, approved suppliers. Vehicle filling operations are performed by facility personnel trained in proper discharge prevention procedures. The truck driver or facility personnel remain with the vehicle at all times while fuel is being transferred. Transfer operations are performed according to the minimum procedures outlined in Table 3-3. This table is also posted next to the loading/unloading point. II Lewicki & Associates SPCC - North Hangs Mine November 2021 24 Table 3-3: Fuel Transfer Procedures Stage Tasks Prior to loading/ unloading Visually check all hoses for leaks and wet spots. Verify that sufficient volume (ullage) is available in the storage tank or truck. Secure the tank vehicle with wheel chocks and interlocks. Ensure that the vehicle’s parking brakes are set. Verify proper alignment of valves and proper functioning of the pumping system. During loading/ unloading Driver must stay with the vehicle at all times during loading/unloading activities. Periodically inspect all systems, hoses and connections. When loading, keep internal and external valves on the receiving tank open along with the pressure relief valves. When making a connection, shut off the vehicle engine. When transferring Class 3 materials, shut off the vehicle engine unless it is used to operate a pump. Monitor the liquid level in the receiving tank to prevent overflow. Monitor flow meters to determine rate of flow. When topping off the tank, reduce flow rate to prevent overflow. After loading/ unloading Make sure the transfer operation is completed. Close all tank and loading valves before disconnecting. Securely close all vehicle internal, external, and dome cover valves before disconnecting. Make sure the hoses are drained to remove the remaining oil before moving them away from the connection. Use a drip pan. Cap the end of the hose and other connecting devices before moving them to prevent uncontrolled leakage. II Lewicki & Associates SPCC - North Hangs Mine November 2021 25 3.11 Brittle Fracture Evaluation (40 CFR 112.7(i)) There are no field constructed tanks on site. 3.12 Conformance with State and Local Applicable Requirements (40 CFR 112.7(j)) All bulk storage tanks at this facility are registered with the state and local authorities if required and have current certificates of registration and special use permits required by the local fire code. All above ground tanks are strictly for the concrete processing operation. No off-site trucks are loaded from these tanks. For this reason, the above ground tanks do not fall under the rules of the Colorado Division of Oil and Public Safety. II Lewicki & Associates SPCC - North Hangs Mine November 2021 26 PART 4: DISCHARGE PREVENTION – SPCC Provisions for Onshore Facilities (Excluding Production Facilities) 4.1 Facility Drainage (40 CFR 112.8(b)) All secondary containment structures do not drain offsite. The facility drainage paths are outlined on the Facility Plan. Record of Containment Stormwater Pumping This record must be completed when rainwater from containment areas is pumped out of the containment. Discharge of water which is free of an oil sheen, can be to the pit floor. Any contaminated stormwater needs to be disposed of in a safe way such as blending into the hot plant feed material. Date Diked Area Oil Sheen Time Signature II Lewicki & Associates SPCC - North Hangs Mine November 2021 27 4.2 Bulk Storage Containers (40 CFR 112.8(c)) Table 4-1 summarizes the construction, volume, and content of bulk storage containers at the site. Table 4-1: List of Bulk Containers Tank Location Type (Construction Standard) Capacity (gallons) Content Discharge Prevention & Containment DB1 Northeast side of processing area Steel tank (above ground) 10,000 Off-highway diesel Double-walled; Concrete berm DB2 Northeast side of processing area Steel tank (above ground) 5,000 Off-highway diesel Double-walled; Concrete berm DB3 Northeast side of processing area Steel tank (above ground) 2,000 Off-highway diesel Double-walled; Concrete berm II Lewicki & Associates SPCC - North Hangs Mine November 2021 28 4.2.1 Construction (40 CFR 112.8 (c)(1)) All oil tanks used at this facility are constructed of steel, in accordance with industry specifications as described above. The design and construction of all bulk storage containers are compatible with the characteristics of the oil product they contain, and with temperature and pressure conditions. 4.2.2 Secondary Containment (40 CFR 112.8(c)(2)) The full complement of tanks and their respective secondary containment is shown in Table 2-1. Precipitation is not a concern for double walled tanks, or the berms and bins as they are well above the 110% volume requirement. Containers stored within a structure are protected from the elements. These containments must be maintained in good condition and evaluated monthly, as shown on the monthly inspection sheet. 4.2.3 Drainage of Diked Areas (40 CFR 112.8(c)(3)) No uncontaminated stormwater can discharge from the site without first passing through control structures. At these control structures, all stormwater is inspected and recorded prior to discharge. 4.2.4 Corrosion Protection (40 CFR 112.8(c)(4)) There are no underground storage tanks on site and all above ground tanks are elevated therefore, no cathodic protection is required on all above ground tanks. 4.2.5 Partially Buried and Bunkered Storage Tanks (40 CFR 112.8(c)(5)) This section is not applicable since there are no partially buried or bunkered storage tanks at this facility. 4.2.6 Inspections and Tests (40 CFR 112.8(c)(6)) Visual inspections of ASTs by facility personnel are performed according to the procedure described in this SPCC Plan. Leaks from tank 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. The scope and schedule of certified inspections and tests performed on the facility’s ASTs are specified in STI Standard SP-001. The external inspection includes ultrasonic testing of the shell, as specified in the standard, or if recommended by the certified tank inspector to assess the integrity of the tank for continued oil storage. Records of certified tank inspections are kept at the facility for at least five years. Shell test comparison records are retained for the life of the tanks. Table 4-2 summarizes inspections and tests performed on bulk storage containers (“EE” indicates that an environmentally equivalent measure is implemented in place of the inspection/test, as discussed in Section 3.1 of this Plan). II Lewicki & Associates SPCC - North Hangs Mine November 2021 29 The recommendations for integrity testing are based on a) the knowledge of the tank history, b) the fact that all tanks are shop constructed, c) past tank performance, d) the visible condition of the tanks, and e) the quality and volume of secondary containment. II Lewicki & Associates SPCC - North Hangs Mine November 2021 30 Table 4-2: Scope and Frequency of Bulk Storage Containers Inspections and Tests Tank ID Inspection/Test DB1 DB2 DB3 Visual inspection by facility personnel (as per checklist of Section 3.7) M M M External inspection by inspector (as per STI Standard SP-001) A A A Internal inspection by certified inspector (as per STI Standard SP-001) EE EE EE Tank tightness test meeting requirements of 40 CFR 280 EE EE EE Legend: M: Monthly A: Annual EE: Inspection not required until 2026, given use of environmentally equivalent measure (refer to Section 3.1 of this Plan and Table 4-3). * Or earlier, as recommended by the certified inspector based on findings from an external inspection. † Internal inspection may be recommended by the certified inspector based on findings from the external inspection. Rationale for the initial external shell testing of tanks is demonstrated in Table 4-3 below. Initial ultrasonic shell testing will be performed by a qualified person according to the protocol included in Appendix B. The report of the testing will be attached to this plan and will be available on site. Based on the results of this testing, the tanks will either be placed out of service or a new test period will be established. II Lewicki & Associates SPCC - North Hangs Mine November 2021 31 Table 4-3 Rationale for Determination of Tank Shell testing per SP-001 Tank ID DB1 DB2 DB3 Tank Size (gallons) 10,000 5,000 2,000 Liquid Diesel Diesel Diesel Shop Constructed Yes Yes Yes Year Placed in Service 2021 2021 2021 Years used in plant 0 0 0 Past leaks or other problems No No No All Sides Visible Yes Yes Yes Bottom Visible Yes Yes Yes Visible Condition Excellent Excellent Excellent Type of Secondary Containment Double walled Double Walled Double Walled Secondary Containment Volume 11,000 5,500 2,200 Containment % of Tank Size 110 110 110 Leak Detection Yes Yes Yes Visual Inspection Frequency M M M Required Shell Test Inspection date By Spring 2026 By Spring 2026 By Spring 2026 Note: DB1, DB2, and DB3 will be installed in 2022 as a brand-new tank. Ultrasonic shell testing must be conducted once every five years. II Lewicki & Associates SPCC - North Hangs Mine November 2021 32 4.2.7 Heating Coils (40 CFR 112.8(c)(7)) No heating coils exist on any tank at this site. 4.2.8 Overfill Prevention Systems (40 CFR 112.8(c)(8)) General secondary containment is provided in the event of overfills, as described in this Plan. Storage drums are not refilled, and therefore overfill prevention systems do not apply. 4.2.9 Effluent Treatment Facilities (40 CFR 112.8(c)(9)) Stormwater detention ponds are located onsite to trap effluent. These are inspected monthly and discharges from them are documented as part of the site’s Stormwater Management Plan (SWMP). 4.2.10 Visible Discharges (40 CFR 112.8(c)(10)) Visible discharges from any container or appurtenance – including seams, gaskets, piping, pumps, valves, rivets, and bolts – are quickly corrected upon discovery. 4.2.11 Mobile and Portable Containers (40 CFR 112.8(c)(11)) All small and portable containers are kept in the Storage Building 4.3 Transfer Operations, Pumping, and In-Plant Processes (40 CFR 112.8(d)) Transfer operations at this facility include: • The filling of mobile equipment. All buried piping at this facility is cathodically protected against corrosion and is provided with a protective wrapping and coating. When a section of buried line is exposed, it is carefully examined for deterioration. If corrosion damage is found, additional examination and corrective action must be taken as deemed appropriate considering the magnitude of the damage. Additionally, Western Slope Materials conducts integrity and leak testing of buried piping at the time of installation, modification, construction, relocation, or replacement. Records of all tests are kept at the facility for at least three years. Lines that are not in service or are on standby for an extended period of time are capped or blank- flanged and marked as to their origin. All pipe supports are designed to minimize abrasion and corrosion and to allow for expansion and contraction. Pipe supports are visually inspected during the monthly inspection of the facility. All aboveground piping and valves are examined monthly to assess their condition. Inspection includes aboveground valves, piping, appurtenances, expansion joints, valve glands and bodies, catch pans, pipeline supports, locking of valves, and metal surfaces. Observations are noted on the monthly inspection checklist provided in this Plan. II Lewicki & Associates SPCC - North Hangs Mine November 2021 33 Warning signs are posted at appropriate locations throughout the facility to prevent vehicles from damaging aboveground piping and appurtenances. Most of the aboveground piping is located within areas that are not accessible to vehicular traffic (e.g., inside diked area). Brightly painted bollards are placed where needed to prevent vehicular collisions with equipment. II Lewicki & Associates SPCC - North Hangs Mine November 2021 34 PART 5: 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 is prohibited by state and federal laws. Immediate action must be taken to control, contain, and recover discharged product. This section describes the cleanup response and protocols to follow in the event of an oil or diesel spill. The uncontrolled discharge of oil or diesel to groundwater, surface water or soil is prohibited by State or Federal laws. It is imperative that action be taken to respond to a spill once it has occurred. In the event of an oil spill, depending on the volume and characteristics of the material released, the operator has defined spill response as either a “Minor Spill Response” or “Major Spill Response” (“Spill Emergency”). A list of Emergency Contacts is included. II Lewicki & Associates SPCC - North Hangs Mine November 2021 35 5.1 Minor Spill Response A spill is encountered. Locate the source of the spill. Can the source be stopped safely? Prevent further material from being spilled. Can the on site employees contain the spilled material safely? Once the spill is contained, notify the Facility Manager. The Facility Manager will document the spill. Take pictures of the spill and how it was contained. Did the spill reach groundwater or surface water? Was the spill greater than 25 gallons? The Environmental Manager will fill out the Spill Notification Form. The Environmental Manager or upper management of Western Slope Materials will notify the required governmental agencies listed on the Spill Notification Form (Not Including the EPA). The Environmental Manager or upper management of Western Slope Materials will notify the required governmental agencies listed on the Spill Notification Form (Including the EPA). Facility Manager will evaluate safety hazard of spill and Call 911 if there is risk of fire or explosion and evacuate the area. Yes No Yes The Facility Manager will notify the Environmental Manager. Yes No The Environmental Manager will document the spill. No Yes The Environmental Manager will fill out the Spill Notification Form. The Environmental Manager will document the spill. No II Lewicki & Associates SPCC - North Hangs Mine November 2021 36 5.2 Response to a Major Discharge Due to the secondary containment of the oil and fuel tanks on site, and the 3rd level of containment, which is the site berm, the possibility of a major discharge to any River is very unlikely. However, the possibility is addressed below. 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 material enters water; • The discharge requires special equipment or training to clean up; • The discharged material poses a hazard to human health or safety; or • There is a danger of fire or explosion. In the event of a major discharge from the site, the following guidelines apply: • If there is a chance of an ignition or any other condition that would put the site personnel at risk, all workers must immediately evacuate the discharge site via the designated access road. • If the Facility Manager is not present at the facility, the senior on-site person notifies the Facility Manager of the discharge and has authority to initiate notification and response. Certain notifications are dependent on the circumstances and type of discharge. For example, if oil reaches a sanitary sewer, the publicly owned treatment works (POTW) should be notified immediately. A discharge that threatens the Eagle River may require immediate notification to downstream users. The Facility Manager (or senior on-site person) must call for medical assistance if workers are injured. • The Facility Manager (or senior on-site person) must notify the Fire Department or Police Department. • The Facility Manager (or senior on-site person) must call the spill response and cleanup contractors listed in the Emergency Contacts list in this section. • The Facility Manager (or senior on-site person) must immediately contact the CDPHE Colorado Office of Emergency Management: 303-273-1778 and the National Response Center (888-424-8802). • The Facility Manager (or senior on-site person) must record the call on the Discharge Notification form in this section and attach a copy to this SPCC Plan. • The Facility Manager (or senior on-site person) coordinates cleanup and obtains assistance from a cleanup contractor or other response organization as necessary. If the Facility Manager is not available at the time of the discharge, then the next highest person in seniority assumes responsibility for coordinating response activities. II Lewicki & Associates SPCC - North Hangs Mine November 2021 37 5.3 Waste Disposal Wastes resulting from a minor spill response will be containerized in impervious bags, drums or buckets. The waste will be removed from the site by a licensed waste hauler within two weeks. Wastes resulting from a major spill response will be removed and disposed of by a cleanup contractor. Waste that is safe to mix with asphalt plant feed material can be conducted as well. 5.4 Spill Notification Forms and Discharge Notification If a minor spill exists and the can be contained by site personnel, after the appropriate phone calls are made and the spill is contained, a Spill Notification Form shall be completed and submitted to the Facility Manager. This form is included in the following pages. The Spill Notification Form includes a checklist to document the proper notification of state and federal agencies. The form shall be filed and maintained for 3 years. Any size discharge occurs, (i.e., one that creates a sheen, emulsion, or sludge) that affects or threatens to affect navigable waters or adjoining shorelines must be reported immediately to the National Response Center (1-800-424-8802). The Center is staffed 24 hours a day. A summary sheet is included in this section to facilitate reporting. The person reporting the discharge must 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 II Lewicki & Associates SPCC - North Hangs Mine November 2021 38 5.5 Cleanup Contractors and Equipment Suppliers Contact information for specialized spill response and cleanup contractors are provided in this section. These contractors have the necessary equipment to respond to a discharge of oil that affects the River, including floating booms and oil skimmers. The 90+ Gallon Spill kit is located in the Storage Building as shown on the Facility Layout. The inventory of response supplies and equipment is typical of a large spill cut, which includes booms, pillow, socks, pads, overpack container with screw lid, bags, gloves and instructions. The inventory is verified on a monthly basis. Additional supplies and equipment may be ordered from the following sources: Spill 911 (800) 474 5911 Creative Safety Supply (866) 754-0160 Contractors for Significant Spills and/or Significant Discharges Custom Environmental Services, Inc. Arvada, CO 80002 Tel+1 (303) 423-9949 Tel+1 (800) 310-7445 Fax+1 (303) 423-1854 Environmental contractor incl. oil spill, HAZMAT and asbestos. Custom Environmental Services, Inc. Colorado Springs, CO 80907 Tel+1 (719) 598-1557 Tel+1 (800) 310-7445 Fax+1 (719) 598-2687 Environmental Restoration LLC Commerce City, CO 80022 Tel +1 (303) 382-1258 Tel +1 (888) 814-7477 Fax +1 (303) 382-1285 Veolia ES Special Services Henderson, CO 80640 Tel +1 (303) 371-7600 Tel +1 (800) 688-4005 Fax +1 (303) 371-7678 D Lewicki & Associates SPCC - North Hangs Mine November 2021 39 Emergency Contacts Spill Reporting Telephone # EPA (800) 424-8802 Colorado Dept. of Health and Environment (877) 518-5608 Colorado DRMS (303) 866-3567 Local Health Department (970) 629-5102 MSHA (303) 231-5465 Local Emergency Agencies Telephone # Fire Department 911 Sheriff/Police 911 Spill Response Contractors Telephone # Lewicki and Associates (303) 346-5196 Adequate Heavy Equipment Kept Onsite for Rapid Spill Response Owner/Operator Telephone # Western Slope Materials (970) 524-2520 Sean Mello (970) 379-0427 D Lewicki & Associates SPCC - North Hangs Mine November 2021 40 Spill Notification/Documentation Form Part A: Basic Spill Data Spill Type: Major / Minor [ ] Major [ ] Minor Spill Date: Type of Spilled Substance: Spill Time: Quantity Spilled: Spill Duration: Facility Name: Location of Spill: Owner / Company Name: Release to : [ ] Containment [ ] River [ ] Pond [ ] Soil [ ] Air [ ] Ground water [ ] Other Nature of spill and any environmental or health effects: [ ] Injuries [ ] Fatality *Complete Part B if the spill is geater than 25 gallons Part B: Notification Checklist Spill of greater than 25 gallons of petroleum product: Notification Date and Time Name of Person the Received Call Colorado Department of Public Health and Environment (877) 518-5608 Local Health Department Unknown Location Colorado Division of Reclamation, Mining and Safety (303) 866-3567 MSHA (303) 231-5465 Spill reaches ground water or surface water: EPA National Response Center (800) 424-8802 Form Completed By (Print Name): Sign and Date: D Lewicki & Associates SPCC - North Hangs Mine November 2021 41 The spill notification form must be submitted to the Facility Manager. A copy must be retained on -site and included with the SPCC Plan. II Lewicki & Associates SPCC - North Hangs Mine November 2021 42 Substantial Harm Determination Facility Name: Western Slope Materials – North Hangs Mine Facility Address: 6533 346 County Rd Silt, CO 81652 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 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 storage tank area? Yes No 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 appropriate formula in 40 CFR part 112 Appendix C, Attachment C-III or a comparable formula) such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments? Yes No 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 in 40 CFR part 112 Appendix C, Attachment C-III or a comparable formula) such that a discharge from the facility would shut down a public drinking water intake? Yes No 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 than or equal to 10,000 gallons within the last 5 years? Yes No D Lewicki & Associates SPCC - North Hangs Mine November 2021 43 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. Signature: Title: EHS Manager Name:________________________ Date: D Lewicki & Associates SPCC - North Hangs Mine November 2021 APPENDIX A – FIGURES Map C-2 Phase 1 Mining Plan Map C-3 Phase 2 Mining Plan II Lewicki & Associates SPCC - North Hangs Mine November 2021 APPENDIX B – ULTRASONIC SHELL TEST PROTOCOL II Lewicki & Associates SPCC - North Hangs Mine November 2021 Western Slope Materials Tank Thickness Testing Protocol In addition to physical inspections conducted at intervals specified in Spill Prevention Countermeasure and Control Plans, external ultrasonic thickness (UT) measurements of the above ground storage tank (AST) shells shall be performed. External UT measurements of the tank shell are a form of non-destructive testing used to locate potential flaws or areas of localized corrosive attack and establish a general rate of shell corrosion on the interior surface of the tank shell. To insure that primary containment is satisfactory to contain petroleum products, integrity testing shall be conducted on each vessel designated for testing in the SPCC Plan. The following protocol shall be followed in determining the wall thickness of those individual tanks specified for testing: Field UT measurements are taken with a Hitachi HT300 Ultrasonic Digital ThicknessMeter. The Ultrasonic Meter shall be set per manufacturer recommendations for the type of metal being tested. Field calibrations shall be performed prior to and during testing using the Zero Adjustment test piece attached to the meter at increments not to exceed 1 hour. It is expected that the surface of the tanks will have a painted surface to prevent corrosion. The gage shall be adjusted to account for the painted surface. If the gage does not have an adjustment for paint, the gage shall be calibrated by measuring the known thickness of plate steel with and without paint coating. The gage shall be adjusted, if possible to account for the painted surface. If no adjustment can be made to the meter, adjustment to the reading shall be noted on the field test form. UT measurements shall be concentrated in areas of the shell where corrosion is most likely to be present. The areas of the shell for UT testing are divided into grid lines at approximate arc lengths of 2 feet apart, starting at the bottom of the tank. Where possible, measurements shall be along the longitudinal “A” grid or bottom of the tank. Additional measurements shall be taken along the “B” and “C-C” longitudinal grid line, which are 2 feet from the longitudinal “A” grid and on both sides of the “A” grid. In cases where the “A” grid is not accessible, measurements shall be taken as close to the “A” grid as possible on both sides of the “A” grid. Additional measurements shall be taken on the longitudinal grid line 2-feet away from the first grid line. By example only, grid “C” is the closest a measurement is taken to the preferred grid “A”. The next measurement shall be taken along grid “E”. See attached sketch of the grid lines. The number of measurements taken along any longitudinal grid line is in part determined by the total length of the tank and the number of suspected areas which exhibit signs of corrosion. Normally, these measurements are no greater than 3 feet apart. In addition to II Lewicki & Associates SPCC - North Hangs Mine November 2021 measurements taken along the longitudinal axis of the tank shell, two measurements shall be taken on both end plates of the tanks and the top of the tank. Once test grid points are determined, the tester shall take four measurements within two inches of the specified grid point and record on the field test form. An average of these four measurements shall also be calculated and recorded on the field test form. The tester must be qualified and experienced in the use of the Hitachi HT300 Ultrasonic Digital Thickness Meter. If the tester encounters areas of thin wall thickness, additional readings may be taken to better identify the thin area. The test results will be passed on to the P.E. and the tester will work with the P.E. to determine if the tank should be removed from service, should be repaired, or can continue in service with a designated shell test interval. The SPCC Plan will be then modified accordingly. For double walled tanks, all liquid will need to be removed from the tank and the testing II Lewicki & Associates SPCC - North Hangs Mine November 2021 Tank Shell Test Grid Lines "L" grid is slightly more than 2' arc due to this tank size required Tank of ' Radius Other t nk sizes will have more o less grid lines "B'fac between grid lines "A" Grid Line Note: Longitudinal measurements along each grid line are no further than 3 feet apart. Note: Grid lines H, I, J, and K are to be measured if visual inspection shows cause for the mesurement. D Lewicki & Associates SPCC - North Hangs Mine November 2021 ULTRASONIC TANK TESTING FIELD FORM Company: Location: Tank Assignment: Western Slope Materials Inspector: Tank Contents: Shape/Orientation: Date: Equipment Make/Model: Calibration Hitachi HT300 Ultrasonic Digital Thickness Meter TANK SPECIFICATIONS Manufacturer: Model/Description: Manufactur Date: Length Diameter Capacity Tank Sketch: Tank ID: Material/Surface Coating: Notes: Stationing for 1 foot square grids used during tank UT testing was established with letter designations (A thru CC) around the circumference of the tank and number designations (1-22 or the actual length of the tank) along the horizontal axis of the tank. D Lewicki & Associates SPCC - North Hangs Mine November 2021 TANK THICKNESS MEASUREMENTS GRID T1 T2 T3 T4 AVG GRID T1 T2 T3 T4 AVG DATA SUMMARY SHELL WALL THICKNESS Overall Average Thickness Minimum Average Thickness Minimum Thickness Reading D Lewicki & Associates