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Connell Resources Timnath Pit Terracon <br />Project No. 20077005 <br />June 25, 2009 <br />results. If the tanks are less than ten years old, Terracon recommends that Connell <br />develop a schedule for future integrity testing of the tanks based on manufacturer's <br />recommendations and/or the American Petroleum Institute's (API) Standard 653 - Tank <br />Inspection, Repair, Alteration, and Reconstruction and/or the Steel Tank Institute's (STI) <br />SP001-03 inspection standard. <br />SPCC Procedures <br />In addition to the concerns listed above, Terracon has developed several required <br />procedures that must be implemented by the facility. During the preparation of the <br />SPCC Plan, Terracon did not identify the following requisite procedures: <br />• A visual assessment program of oil storage tanks. Terracon has included visual <br />tank assessment procedures (i.e., a monthly visual tank assessment form and <br />guidelines for periodic integrity testing) in Section 8.0 of this SPCC Plan. The <br />monthly visual tank assessment form should be filled out each month after the <br />tanks are visually assessed for corrosion, wear, leaks and spills. <br />• An SPCC training program. A brief description of what should be included in an <br />SPCC training program has been added to Section 9.0 of this SPCC Plan. <br />Personnel whose duties include or involve oil storage, processing or use should <br />be trained annually or more frequently to assure an understanding of the <br />procedures and requirements of the SPCC Plan. <br />The Emergency Response Action Plan contains emergency phone numbers for Connell, <br />local emergency responders (e.g., fire department) and hospitals that can be referenced <br />in the event of an oil spill. Please verify that the emergency phone numbers are correct. <br />Signature Requirement <br />The SPCC Plan requires the approval of a manager with the authority necessary to <br />implement the SPCC Plan. Section 2.4 of the SPCC Plan contains a signature block for <br />certifying management approval. When the plan is finalized, please have the <br />appropriate manager sign and date the Management Approval signature block. <br />Terracon has assessed that the Timnath Pit Facility would not be expected to cause <br />substantial harm to the environment by discharging oil into or on the navigable waters or <br />adjoining shorelines. The SPCC Plan includes the 'Certification of the Applicability of the <br />Substantial Harm Criteria Checklist' in Appendix D. When the SPCC plan is finalized, <br />please have the appropriate manager sign and date the 'Certification of the Applicability <br />of the Substantial Harm Criteria Checklist' signature block on the last page of in <br />Appendix D.