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Resolution No. 2010-002RESOLUTION NO. 2010-02 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF VERNON GRANTING AN AMENDMENT TO THE CONDITIONAL USE PERMIT FOR LUBRICATING SPECIALTIES COMPANY FOR THE OPERATION OF A PETROLEUM RELATED USE LOCATED AT 3365 SLAUSON AVENUE IN CITY OF VERNON WHEREAS, ,Lubricating Specialties Company ("LSC") is requesting an amendment to its existing conditional use permit that was approved on March 17, 1992 for the operation of a petroleum storage, processing and distribution facility at 3365 Slauson Avenue (the "Project"); and WHEREAS, LSC is proposing to store and distribute Class I and Class II liquids, as defined by the California Fire Code, at the site; and WHEREAS, this storage and distribution was not originally contemplated when the conditional use permit was approved and therefore an amendment to the conditional use permit is required in order to permit the storage of Class I and Class II liquids at the site; and WHEREAS, the proposed site contains an exiting building of approximately 55,634 square feet.on a 4.19 acre lot and two existing tank farms, Tank Farm "A" approximately 12,540 square feet and Tank Farm "B" approximately 13,500 square feet in size; and WHEREAS, the size, shape and topography of the parcel is adequate for the proposed operation; and WHEREAS, the Class I and Class II liquids will be stored in seven of the existing aboveground tanks in Tank Farm B; and WHEREAS, the proposed site is surrounded by industrial, utility right-of-ways and warehousing uses compatible with the proposed use and no adverse effect from traffic, parking, noise, odors, smoke, light or glare are anticipated from the proposed operation; and WHEREAS, the proposed site is in the I -Zone, Industrial; and WHEREAS, pursuant to Section 26.4.1-3(e) of the Comprehensive Zoning Ordinance, a petroleum related use/pe.troleum storage facility is allowed in the I -Zone, with approval of a conditional use permit; and WHEREAS, an initial study and negative declaration was conducted and approved for the project when LSC was first granted a conditional use permit in 1992; and WHEREAS, the proposed use will not result in any environmental significant changes to LSC's operation and involves a negligible expansion of its existing use, therefore, a notice of exemption is recommended to be approved in accordance with the California Environmental Quality Act (CEQA) as provided in Section 15301, Class 1 of the State CEQA Guidelines; and WHEREAS, the proposed site will be supported by a 58 stall surface parking lot, 3 truck parking stalls and 6 truck loading stalls; and WHEREAS, the parking proposed will provide adequate on -site parking and loading facilities as required by Section 26.5.1-6 which requires 56 parking spaces, 3 truck parking spaces and 6 truck loading spaces based on the gross floor area for the proposed operation, therefore, it is anticipated that all parking activities will be maintained on -site within the premises and adequate parking and loading will be supplied on -site and will not create an impact to the neighboring properties; and -2- WHEREAS, the subject site is served by Slauson Avenue, an arterial roadway with a right-of-way of 90 feet which LSC is also in the process of obtaining a lease from Department of Water and Power ("DWP") for the installation of a secondary fire access road that will provide access to the rear of the property; and WHEREAS, the streets and highways surrounding the proposed use are adequate in width and are improved as necessary to carry the traffic expected by this proposed operation; and WHEREAS, the proposed use, as to location, operation and design is consistent with the Zoning Ordinance of the City of Vernon with approval of a conditional use permit and is consistent with the Vernon General Plan as the designation would remain unchanged and the approval of the amendment to the conditional use permit would be consistent with the policies and goals of encouraging industrial uses in the City; and WHEREAS, the City Council of the City of Vernon held a hearing on said application for a conditional use permit on January 4, 2010; and WHEREAS, the City Council has received a Staff Report dated December 22, 2009 upon which it has relied on making the foregoing recitals; and WHEREAS, the conditions imposed on the conditional use permit will adequately protect the public health, safety and general welfare and the operation is consistent with all applicable rules and laws of the City of Vernon. NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF VERNON AS FOLLOWS: SECTION 1: The City Council of the City of Vernon does -3- hereby find and determine that the recitals contained hereinabove are true and correct. SECTION 2: The City Council of the City of Vernon further finds that all persons have had the opportunity to be heard or to file written comments to the proposed project and after due consideration of all the evidence submitted at the public hearing determines that there are compelling reasons to justify granting an amendment to the conditional use permit. SECTION 3: The City Council hereby approves the conditional use permit amendment, a copy of which has been submitted to the City Council concurrently herewith, and the City Clerk is directed to receive and file them. Such documents and other materials which constitute the record of proceedings in this matter shall be maintained in the office of the City Clerk who is and shall be the custodian of thereof. SECTION 4: The City Council of the City of Vernon hereby finds that the amendment to the conditional use permit is categorically exempt from the California Environmental Quality Act pursuant to Guideline 15301, Class 1, as the new proposed use of the storage of Class I and II liquids is only a negligible expansion of use beyond the current use. The City Council of the City of Vernon directs the City Clerk, or her designee, to file a Notice of Exemption in compliance with the California Environmental Quality Act. SECTION 5: Subject to the conditions set forth below, the conditional use permit amendment is hereby granted to LSC for the operation of a petroleum storage facility including the storage and distribution of Class I and Class II flammable liquids located at 3365 Slauson Avenue, based on the following findings: a. The lot for the proposed use is adequate in size, shape, and topography for the new Class I and Class II liquid storage. b. The addition of the Class I and Class II liquids will not adversely affect the interest of the public or the interests of other residents and property owners in the vicinity of the Project. This is especially true as the City's Fire Officials have found the proposed fire protection measures will adequately protect life, health and safety. Additionally no environmental effects from this use are anticipated. c. The addition of Class I and Class II liquids will be compatible with other permitted uses of surrounding and adjacent properties in the Industrial Zone of the City as the Applicant's proposed use is allowed in this zone with a conditional use permit. d. The lot has adequate off-street parking and loading facilities for this proposed use, as the Project site contains 58 stall surface parking, 3 truck parking stalls, and 6 truck loading stalls. This meets the Vernon Zoning Code Section 26.5.1-6 requirement that requires 56 parking spaces, 3 truck parking spaces and 6 truck loading stalls. e. The use is consistent with Vernon Zoning Code and General Plan as the amendment of the CUP will ensure zoning capability. Additionally, the amendment of the CUP will be consistent with the goals and policies of the General Plan of encouraging industrial uses in the City. f. The proposed use is consistent with all applicable County, State and Federal laws, rules and regulations as conditioned Below. Additionally, the use will meet local and State Fire -5- Code requirements. g. The proposed use will not adversely affect the general welfare, as conditioned below, as a result of noise, increased traffic, interference with flow of traffic, dust, or other undesirable characteristics. Although the Project will add a small number of vehicle trips, no intersections will be impacted. Additionally, various conditions are imposed to ensure the project does not cause excess noise and impede traffic flow. h. All of the conditions imposed on the Project are necessary to protect the public health, safety and general welfare. SECTION 6: In order to adequately protect the public health and general welfare the following conditions are required: a. The Applicant shall operate the facility in accordance with, and made to conform with all current codes, rules, and regulations including any required fees adopted by the City of Vernon not otherwise addressed by this grant of a conditional use permit. b. The Applicant shall operate the facility in accordance with all federal, state and local laws and shall obtain and maintain necessary permits including, but not limited to wastewater permits from the Sanitation District of Los Angeles County, NPDES permit from the Regional Water Quality Control Board and Air Quality permits from the South Coast Air Quality Management District. c. Any hazardous substances used, handled and/or stored on the Project site shall have prior approval from the Vernon Fire and Health Departments. The Applicant shall obtain a Health Permit if there are reportable quantities of hazardous materials on the site. Only the items listed in the hazardous material report submitted shall be stored on the site. d. Servicing of vehicles, including but not limited to, washing, steam cleaning and repairing shall not be permitted on the premises. No inoperative vehicles shall be stored on -site. All vehicles operated at the facility shall be tuned and maintained in accordance with applicable emission standards. e. The Applicant shall operate the facility in a manner, which will not impede traffic on Slauson Avenue. The Applicant shall ensure all vehicles enter and exit the site in a front forward manner. No vehicle parking or staging associated with the facility shall take place on any public street within the City of Vernon. The Applicant shall ensure that trucks do not idle when parked on the subject site. The driveway to the site shall be reconstructed to conform with city standard PV693. f. The Applicant shall ensure that the facility's building is structurally maintained to exclude rodents and shall ensure the property is maintained rodent free. The Applicant shall ensure that adequate drainage on the site to eliminate potential mosquito harborage. g. A spill prevention, control and countermeasure (SPCC) plan shall be developed for the facility to the satisfaction of the Director of Environmental Health. Materials must be available for cleaning up of leaks or spills of substances associated with the Applicant operation. h. The Applicant shall implement a personnel safety -training program to include personal safety, handling hazardous materials and fire protection procedures prior to any Class T -7- or Class II liquids being stored on site. The written program shall be made available for review upon the City's request. i. The project site shall be constructed and maintained substantially in compliance with the site plan submitted as part of this conditional use permit application. j. The Applicant shall ensure that all parking and loading areas are striped in a manner acceptable to the Director of Community Services & Water and are paved with a hard durable surface material and adequately drained, and kept free of dust, mud, trash and weeds. Where parking or maneuvering areas adjoin the public street, a barrier wall or landscaping shall be installed and maintained to meet City standards. k. All on -site construction of improvements shall be in compliance with the most current Building Codes (Building, Fire, Mechanical, Plumbing and Electrical) and current Health and Safety Codes and Regulations, including, but not limited to piping systems (valves, testing, corrosion protection, back flow protection, manual drainage and pipe supports), tank design (including vent lines, vent pipe outlets, manifolds, emergency venting, over flow protection and vapor recovery systems), secondary containment shall be provided for the tank farm area and loading and unloading areas, (the site shall be graded so that the loading and unloading areas drain away from buildings on the site and to an appropriate sized sump). The existing and new electrical systems shall conform with the requirements for Class Land Class II liquid storage areas and shall be upgraded to Class 1 Division 1 in accordance with Article 500 of the California Electrical Code, to the top of the tanks. In addition to any required Vernon Environmental Health Department clearance, the Applicant shall obtain all necessary building, fire, mechanical, plumbing and electrical permits from the City of Vernon Community Services Department and complete construction, prior to any Class I or Class II liquids being stored at the site. Prior to construction a fire protection engineer shall prepare a report outlining all required safety requirements of the California Building Codes and NFPA Standards and at the completion of construction inspect the site and certify that all required safety components have been installed in compliance with the appropriate standards. 1. The Applicant shall operate the facility in such a manner that noise and vibration shall not be a nuisance to neighborhood properties. At no time shall noise exceed or vibrations exceed the standards set forth in the City Zoning Ordinance. The facility shall comply with all CalOSHA noise requirements at all times. If the City in its sole discretion determines that a noise nuisance is caused by the operation, a noise study shall be prepared by the Applicant to the satisfaction of the Director of Community Services and Water to determine if the facility is in compliance with the City's Zoning Regulations. m. The Applicant shall operate the facility in such a manner that odors shall not be a nuisance to neighborhood properties. If the City in its sole discretion determines that an odor nuisance is caused by the operation, additional odor controls shall be installed to the satisfaction of the Director of Community Services and Water or the facility shall cease all operations until the odor problem is resolved. n. The Applicant shall obtain a lease from DWP for the installation of the secondary fire access road to the rear of the property. A new driveway shall be constructed where the fire roads accesses Slauson Avenue. The fire access road shall extend from Slauson Avenue to the railroad tracks just south of the westerly prolongation of the north property line of the Applicant site. One breakaway gate a minimum of 35-feet in width shall be provided at a location determined by the City of Vernon. The roadway shall be a minimum of 27-feet in width, and paved with a minimum 4-inch asphalt concrete pavement or concrete pavement over 6-inch crushed miscellaneous base. No Class I or Class II liquids shall be permitted on the site prior to the completion of the fire access road construction. o. In areas where less then 25-feet distance is provided between the flammable unloading and loading area and any aboveground tank, a 9-foot high masonry or concrete wall having a minimum two hour fire rating shall be constructed between the tank farm and the rail tank car unloading and loading area and the tank farm and the truck loading and unloading area. No Class I or Class II liquids shall be permitted on the site prior to the wall being constructed. p. A foam fire protection system shall be installed in accordance with NFPA Standard 11. At minimum, the number of fire monitors and foam storage tanks shall be provided as shown on the Eastman expansion -project drawing dated May 2009, submitted with the project application. Three fixed fire monitors shall -10- be mounted at minimum of 50-feet in height and directed into the diked area where the Class I and Class II liquids will be stored. No Class I or Class II liquids shall be permitted on the site prior to the completion of the foam fire protection system installation. q. Noncompliance with any of the conditions herein shall constitute sufficient grounds for the City Council of the City of Vernon to void this conditional use permit pursuant to Section 26.6.3-9 of the Comprehensive Zoning Ordinance. SECTION 7: LSC and any successors in interest shall indemnify, hold harmless, and defend the City of Vernon, its officers, agents and employees from and against any and all claims, complaints, or petitions for: (1) damages, losses, expenses resulting 'from bodily injury, sickness, disease, disability or death arising from the operation of the facility excluding there from any such claim resulting from the gross negligence or intentional wrongdoing of the City of Vernon, its officers, agents or employees; (2) a peremptory writ or other relief by way of injunction, mandamus, or administrative mandamus; or (3) legal expenses and attorney's fees incurred by the City of Vernon on behalf of any party in such actions or proceedings. The City of Vernon does not waive its right to participate in the defense of any such action. SECTION 8: Not later than sixty (60) days from the date of this Resolution, LSC shall indicate, in writing, its acceptance of and agreement with the conditions contained in Section 6 of this Resolution and the indemnification provision contained in Section 7 of the Resolution. -11- SECTION 9: The City Clerk of the City of Vernon shall certify to the passage, approval and adoption of this resolution, and the City Clerk of the City of Vernon shall cause this resolution and the City Clerk's certification to be entered in the File of Resolutions of the Council of this City. APPROVED AND ADOPTED this 4th day of January, 2010. , yTTEST : MANUELA GIR City Clerk Name: Hilario Gonzales Title: Mayor / 'T4ay-e-r--P-r-o:' -M -12- STATE OF CALIFORNIA ) ) ss COUNTY OF LOS ANGELES ) I, MANUELA GIRON, City Clerk of the City of Vernon, do hereby certify that the foregoing Resolution, being Resolution No. 2010-02, was duly passed, approved and adopted by the City Council of the City of Vernon at a regular meeting of the City Council duly held on Monday, January 4, 2010, and thereafter was duly signed by the Mayor or Mayor Pro-Tem of the City of Vernon. Executed this Z;A day of January, 2010, at Vernon, California. MANUELA GIRON, City Clerk (SEAL) -13- CITY CLERK'S OFFICE INTEROFFICE MEMORANDUM DATE: January 7, 2010 TO: S. Kevin Wilson, Director of Community Services & Water FR Nelly Giron, City Clerk RE: Resolution No. 2010-02 — A Resolution of the City Council of the City of Vernon Granting an Amendment to the Conditional Use Permit for Lubricating Specialties Company for the Operation of a Petroleum Related Use Located at 3365 Slauson Avenue in City of Vernon Transmitted herewith is a copy of Resolution No. 2010-02, referenced above, which was approved by City Council on January 4, 2010. Thank you. NG:dj c: Resolution No. 2010-02 FA City of Vernon NOTICE OF PUBLIC HEARING 4305 Santa Fe Avenue Vernon, CA 90058 (323)583-8811 The City of Vernon will conduct a Public Hearing, which you may attend. PLACE: Vernon City Hall City Council Chambers 4305 Santa Fe Avenue Vernon, CA 90058 DATE & Monday, January 4, 2010 at 9:00 a.m. TIME: (or as soon thereafter as the matter can be heard) APPLICANT: Lubricating Specialties Company (LSC) The purpose of the hearing is to obtain testimony from affected and/or interested persons regarding this application. The public is also invited to submit written comments regarding the request prior to the Hearing. REQUEST: LSC is requesting an amendment to their existing conditional use permit to allow them to store and distribute Class I and Class II liquids. PROPERTY 3365 Slauson Avenue INVOLVED: REVIEW OF: The application, maps, and supporting information are available for THE FILE: public review during normal business hours in the Vernon Community Services & Water Department, located at 4305 Santa Fe Avenue, Vernon, California, between the hours of 7:15 a.m. and 5:15 p.m. Monday through Thursday. If you challenge the granting of this conditional use permit or any provisions thereof in court, you may be limited to raising only those issues you or someone else raised at the hearing described in this notice or in written correspondence delivered to the City of Vernon at, or prior to, the meeting. The hearing may be continued or adjourned to a stated time and place without further notice of a public hearing. Dated: l l 0' Manuela Giron, ity Clerk con, filuO,0 SON -Ice COMMUNITY SERVICES & WATER DEPARTMENT OFFICE MEMORANDUM TO: Donal O'Callaghan, City Administrator FROM: Samuel Kevin Wilson, Director of Community Services & Water DATE: December 17, 2009 SUBJECT: Conditional Use Permit — Lubricating Specialties Company located at 3365 Slauson Avenue Lubricating Specialties Company (the "Applicant") has submitted an application to amend their existing conditional use permit that was previously approved on March 17, 1992 for the property located at 3365 Slauson Avenue in the Industrial 1-Zone of the city, in order to operate a petroleum related facility (the "Project"). This conditional use permit limited the Applicant to the storage, processing and transferring of only Class III liquids and other combustible products. They now wish to store, blend and distribute Class I, II and III liquids, as defined in the California Fire Code, in their existing tank farm (Tank Farm `B") located at 3365 Slauson Avenue. Tank Farm B is divided in two sections; the east section is 7,925 sq. ft., and west section is 5,575 sq. ft. the Applicant proposes to utilize four 50,000 gallon tanks and two 14,000 gallon tanks to store the Class I and Class II liquids on the west sections of Tank Farm B. The environmental analysis performed for the City of Vernon's issuance of the prior conditional use permit indicated that the oils and greases that the Applicant processed were limited to low to moderate fire hazards with flash points of the materials above 200°. The Applicant now proposes to distribute liquids with much lower flash points. Thus, in order to allow the storage of these liquids, the Applicant's Conditional Use Permit must be amended. Therefore, the Applicant is requesting an amendment to their existing conditional use permit to allow them to store Class I and Class II liquids at the subject site. The project is categorically exempt under Section 15301, Class 1, of the California Environmental Quality Act ("CEQX ). A Notice of Exemption will be prepared and filed with the County Clerk. It is requested that you schedule a public hearing regarding this subject be held on January 4, 2010. Enclosed herewith is a Notice of Public Hearing. Please forward notice to the City Clerk to be executed. My Department will ensure that the notice is published. Please do not hesitate to contact Sergio Canales of my staff at extension 219 if you need more information ' SKW/sc V11 UIU 1AUJGGI. C E1 DEC 1 7 2009 CITY ATTORNEY'S OFFICE MEMORANDUM TO: Donal O'Callaghan, City Administrator FROM: Christopher J. Diaz, Assistant City Attorney CC: Laurence S. Wiener, City Attorney Gena M. Stinnett, Assistant City Attorney Samuel Kevin Wilson, Director of Community Services DATE: December 15, 2009 SUBJECT: Conditional Use Permit — Lubricating Specialties Company located at 3365 Slauson Avenue The City Attorney's office has reviewed and revised the staff report and resolution for approval of the Conditional Use Permit for Lubricating Specialties Company located at 3365 Slauson Avenue and has approved both the staff report and resolution as to form. Please let me know if you should have any remaining questions or concerns. CJD 12720-0001\1193790v1.doc hl IA" � }:.0 JU CIL DEC 2 3 2009 Ciro CLERK'S OFFICE STAFF REPORT COMMUNITY SERVICES & WATER DEPARTMENT DATE: December 21, 2009 �Q v' \ TO: Honorable Mayor and City Council `Z� APPROVED JAN 04 '10 C[TYcomu, FROM: Samuel Kevin Wilson, Director of Community Services & Water RE: Conditional Use Permit — Lubricating Specialties Company located at 3365 Slauson Avenue BACKGROUND Lubricating Specialties Company (the "Applicant") has submitted an application to amend their existing conditional use permit that was previously approved on March 17, 1992 for the property located at 3365 Slauson Avenue in the Industrial I -Zone of the city, in order to operate a petroleum related facility (the "Project"). This conditional use permit limited the Applicant to the storage, processing and transferring of only Class III liquids and other combustible products. They now wish to store, blend and distribute Class I, II and III liquids, as defined in the California Fire Code, in their existing tank farm (Tank Farm "B") located at 3365 Slauson Avenue. Tank Farm B is divided in two sections; the east section is 7,925 sq. ft., and west section is 5,575 sq. ft. the Applicant proposes to utilize four 50,000 gallon tanks and two 14,000 gallon tanks to store the Class I and Class II liquids on the west sections of Tank Farm B. The environmental analysis performed for the City of Vernon's issuance of the prior conditional use permit indicated that the oils and greases that the Applicant processed were limited to low to moderate fire hazards with flash points of the materials above 200°. The Applicant now proposes to distribute liquids with much lower flash points. Thus, in order to allow the storage of these liquids, the Applicant's Conditional Use Permit must be amended. Therefore, the Applicant is requesting an amendment to their existing conditional use permit to allow them to store Class I and Class II liquids at the subject site. 1_1 DEC 2 2 2009 THE PROJECT The Applicant is a manufacturer of lubricating oils and greases which consist of Automotive Engine Oils, Heavy Duty Diesel Engine Oils, Transmission Fluids, Gear Lubricants, Aviation Engine Oils, Hydraulic and Turbine Oils, Industrial Oils, etc. the Applicant receives most of its product by common carrier via tanker trucks or rail cars, which is then loaded into one of their above -ground tanks located on their tank farms. The existing facility has been in operation since 1989. As previously mentioned the Applicant is seeking permission to store and distribute of Class I and Class II liquids. The product would come in on rail tanker -cars and will be directly off-loaded into pre -determined tanks by the Applicant trained employees. The product, at a later time, is then pumped from the holding tanks to trucks, which is then delivered to its scheduled destination. All of the unloading and loading will be preformed by one of the Applicant employees. The facility's hours of operation will be from 7:00 a.m. to 3:00 p.m. with extended hours up to 11:30 p.m. Monday through Friday and as needed on weekends. Personnel will be onsite 24-hours a day to ensure the site remains secure. The Applicant intends to utilize seven tanks located in Tank Farm "B", for storage of the following materials: • Butyl Acetate — tank #77 (50,000 gallons — Class I B Flammable) • Ethyl Acetate — tank #78 (50,000 gallons — Class I B Flammable) • Glacial Acetic Acid — tank 479 (50,000 gallons— Class II Flammable) • NPG 90 — tank #83 (40,000 gallons— Class III B Combustible) • Propanol Alcohol — tank #84 (14,000 gallons — Class I B Flammable) • Propanol Alcohol — tank #87 (14,000 gallons — Class I B Flammable) • Propyl Acetate — tank #86 (50,000 gallons — Class I B Flammable) The proposed site currently has one driveway that fronts Slauson Avenue located on the south side of the building, which provides vehicle ingress and egress from Slauson Avenue. The streets and highways surrounding the proposed site are adequate in width and are improved as necessary to carry the traffic expected by this proposed operation. The subject site is served by Slauson Avenue, an arterial roadway with a right-of-way of 90 feet. The Applicant is also in the process of obtaining a lease from Department of Water and Power (DWP) for the installation of a secondary fire access road that will provide access to the rear of the property from Slauson Avenue. The fire access road will be a minimum of 27 feet in width and will be paved with either concrete or asphalt concrete. -2- ZONING AND GENERAL PLAN CONSISTENCY The Project site is located in the (I) Zone, Industrial, and is designated "industrial" by the City of Vernon General Plan. The proposed Project would be consistent with all applicable regulations of the City of Vernon Code upon amendment of the Conditional Use Permit. In accordance with section 26.4.1-3 (e) of the Comprehensive Zoning Ordinance, the Applicant is categorized as a "petroleum -related use and/or uses primarily engaged in the storage of petroleum products". A petroleum storage facility is defined as an establishment including a tank farm for keeping and storing gasoline, kerosene, distillate fuel oils, residual fuel oils, lubricants, and other petroleum products, but not including storage ancillary to an industrial use such as fuel on the premises or storage as part of a hazardous waste treatment facility. A petroleum storage facility use is an allowed use in the (I) -Zone with the approval of a conditional use permit. The proposed Project would be consistent with the City of Vernon General Plan as the general plan designation would remain unchanged and the amendment to the conditional use permit would be consistent with the policies and goals of encouraging industrial uses in the City. PROJECT SITE The proposed site contains an existing building of approximately 55,634 square feet on a 4.19 acre lot and is surrounded by industrial, retail, and warehousing uses compatible with the proposed use. The site also contains two existing tank farms, Tank Farm "A" approximately 12,540 square feet, and Tank Farm `B" approximately 13,500 square feet in size. The site is adequate in size, shape, and topography for the proposed use. The applicant has not proposed any changes to the size, shape or topography of the existing site. In addition, the proposed Project site is supported by a 58 stall surface parking lot, 3 truck parking stalls, and 6 truck loading stalls. The parking proposed will provide adequate on -site parking and loading facilities for the proposed operation as Vernon Zoning Code Section 26.5.1-6 requires 56 parking spaces, 3 truck parking spaces, and 6 truck loading spaces based on the gross floor area of the building on -site. Therefore, it is anticipated that all parking activities will be maintained on -site within the premises and adequate parking and loading will be supplied on -site. CONSISTENCY WITH CITY OF VERNON FIRE REGULATIONS The proposed storage tanks and associated piping/equipment will be required to be designed to meet all applicable codes, including Chapter 7 of the City of Vernon Code containing the City's Fire Regulations, the 2007 California Fire Code, 2007 California Building Code and the 2007 National Electrical Code as amended by the City of Vernon. The -3- tanks are constructed of low -carbon steel and will have an integral secondary wall containment system for maximum safety. The Fire Code as amended by the City of Vernon limits the size of tank utilized for the storage of Class I and Class II flammable liquids to 10,000 gallons. The Applicant has requested to utilize six tanks in excess of 10,000 gallons for Class I and Class II liquid storage. The Applicant retained the services of a fire protection engineer to determine an alternative means and method to permit the Applicant to store in tanks in excess of 10,000 gallons. - Pursuant to Appendix 1 of the Fire Code Section 104.8, whenever there are practical difficulties involved in carrying out the provisions of this Code, the City's fire code official has the authority to grant modifications for individual cases so long as the City's fire code official fmds that modifications are in compliance with the intent and purpose of the Code and that the modifications do not lessen health, life, and fire safety requirements. The applicant would have practical difficulties in meeting the 10,000 gallon tank size requirement due to the fact that there is insufficient space within the tank farm to maintain the current volume of liquids utilizing smaller tanks. Based on this practical difficulty, the City's fire official finds that the tanks in excess of 10,000 gallons can be used at the Project site. Section 3404.2.9.1 of the Fire Code sets forth the fire protection systems for aboveground tanks. Since the tanks used to store Class I and Class II liquids have a surface liquid area of less then 1,500 square feet no fire protection system is required. However, the City's fire code official is imposing the fire protection engineer's recommendation that foam fire protection be installed in accordance with NFPA 11, a secondary fire access road be provided, and the facility be required to be manned 24- hours a day to ensure that the tanks in excess of 10,000 gallons do not lessen health, life and fire safety requirements and that the intent and purpose of the Code is met. This is because a flammable liquid fire is essentially two dimensional, and is dependent on the surface area of the fuel. The dike boundaries make this surface constant, so the dike area will determine the size of the fire regardless of the amount of liquid stored beneath the surface. Therefore if a 10,000 gallon tank or 50,000 gallon were to leak the surface area of the product would be the same. What is affected by the depth of the liquid is the duration of the fire. A foam fire protection .is designed to place a blanket of foam over the entire surface area extinguishing the fire. The Applicant has advised the city that the facility will be manned 24-hours a day allowing for the protection system to be activated immediately upon a fire being detected. The Applicant will also be providing a secondary fire access road to the site within the LADWP right-of-way. Additionally, the Fire Code Section 3406.5.1.1 requires that the unloading or loading valve of the truck or railroad tanker must be a minimum of 25-feet from a tank storing a Class I liquid. The existing distance between the tank and the unloading valve is only 15-feet which -4- is permissible for Class II and III liquids as also specified in Section 3406.5.1.1. Pursuant to Fire Code Section 104.8, a fire protection engineer performed an analysis and determined that a 9-foot high concrete or masonry wall having a 2-hour rating would provide protection that would not lessen health, safety and fire requirements. Lastly, Section 3404.2.9.5.2 of the California Fire Code requires tanks be separated from each other in accordance with the values stated in NFPA 30, Table 4.3.2.2. L The intent of this section is to maintain access for firefighters and provide a separation between tanks to minimize the spread of fire. NFPA 30, Table 4.3.2.2.1 requires the tanks to be spaced at 1/6 the sum of the adjacent tank diameters, but not less then three feet. NFPA was contacted for its interpretation on this code section. They stated that the meaning of the sum of tank diameters was any two pair of tanks which are adjacent to each other not the sum of all of the adjacent tanks. In the applicant's case all tanks exceed a minimum distance of 3-feet, but in most cases are less then 4-feet. The worst case scenario is where a 15-foot diameter tank is adjacent to a 9-foot diameter tank. In this condition the separation requirement would be 4- feet. Therefore in the worse case scenario the applicants tanks would be non compliant by 1- foot. Pursuant to Section 111.2.4 and Appendix Chapterl, Section 104.8 of the California Fire Code, modification, whenever there is practical difficulties involved in carryout the provisions of the code, the City Fire Official has the authority to grant modification so long as the Fire Code Official fords that modifications are in compliance with the intent of the code and that the modifications do not lessen health, life, and fire safety requirements of the code. In this case, there are practical difficulties in conforming with the code since we are dealing with an existing tank farm that does not meet the spacing requirements. The subject tanks are provided with a venting mechanism to keep the tank pressure below 2.5 psig. They are not of floating or weaken roof type, which are a much greater hazard. The tanks storing a Class I and II liquids will be located near the edge of the diked area allowing easier accessibility. In addition the applicant will be providing three fixed fire foam monitors mounted 50-feet high and capable of providing protection in the diked area. This height will allow the monitors to penetrate deep into the storage tank area assuring foam will be spread throughout the diked area. In addition LSC will be upgrading the electrical protection to Class 1 Division 1 in accordance with Article 500 of the California Electrical Code, to the top of the tank to reduce potential ignition sources. With these added protections the health, safety and fire requirements will not be lessened. Finally, the City's Director of Community Services and Fire Marshall have reviewed the three proposed modifications from the requirements of the Fire Code and have found that in their opinion the modifications will not lessen health, safety and fire requirements and the intent and purpose of the Fire Code will be met. -5- CEOA DETERMINATION AND ENVIRONMENTAL CONSIDERATIONS The existing facility does not produce any potentially significant impacts from noise, odor, dust, smoke, light or glare from the project. The introduction of Class I and Class II liquids is not anticipated to create any additional concerns and will only be a negligible expansion of the applicant's existing use of storing Class III liquids on the project site. In fact, the applicant is proposing to use existing tanks on the project site, and the only change will be the addition of Class I and II liquids in addition to the already existing Class III liquids on the project site. Therefore, the project is categorically exempt under Section 15301, Class 1, of the California Environmental Quality Act ("CEQA") because the new proposed use is only a negligible expansion of an existing use. A Notice of Exemption will be prepared and filed with the County Clerk. Although the project is exempt from CEQA, an air quality analysis was performed for the project. It was determined through the analysis that the emissions from the operation will be below the threshold of significance as establish by the South Coast Air Quality Management District (AQMD). Additionally, a traffic analysis was conducted and concluded that most of the vehicular traffic from the existing facility will continue as before which includes employee ingress/egress, trucks that deliver/pick-up product and supplies. Approximately five new employees and 4 to 6 more truck trips per day will be added due to the new Class I and Class II liquid storage operation. The number of truck trips for the purpose of ingress/egress combined with existing traffic volumes will consist of 8 to 12 entering the premises during a typical 18-hour period. The number of personal vehicle trips will consist of 3 8 to 42 employees spread over the normal and extended hours of operation. Vehicles traveling to the site will generally exit the I-710 and travel southbound on Atlantic Boulevard to Slauson Avenue then west to the site. Vehicles exiting the site will utilize the same streets in the opposite direction. Based on the slight increase in the vehicular trips generated by proposed use the level of service of the surrounding intersections will not be significantly impacted and are below the thresholds established by the Los Angeles Metropolitan Transportation Authority. STATE OR FEDERAL CONDITIONS All Federal, State, and local regulatory permits shall be obtained as required for the operation. STAFF FINDING AND CONDITIONS The amendment to the existing conditional use permit shall be granted based on the following findings and conditions as required by Section 26.6.3-4 of the Vernon Zoning Code: -6- a. The lot for the proposed use is adequate in size, shape, and topography for the new Class I and Class II liquid storage. b. The addition of the Class I and Class II liquids will not adversely affect the interest of the public or the interests of other residents and property owners in the vicinity of the Project. This is especially true as the City's Fire Officials have found the proposed fire protection measures will adequately protect life, health and safety. Additionally no environmental effects from this use are anticipated. C. The addition of Class I and Class II liquids will be compatible with other permitted uses of surrounding and adjacent properties in the Industrial Zone of the City as the Applicant's proposed use is allowed in this zone with a conditional use permit. d. The lot has adequate off-street parking and loading facilities for this proposed use, as the Project site contains 58 stall surface parking, 3 truck parking stalls, and 6 truck loading stalls. This meets the Vernon Zoning Code Section 26.5.1-6 requirement that requires 56 parking spaces, 3 truck parking spaces, and 6 truck loading stalls. C. The use is consistent with Vernon Zoning Code and General Plan as the amendment of the CUP will ensure zoning capability. Additionally, the amendment of the CUP will be consistent with the goals and policies of the General Plan of encouraging industrial uses in the City. f The proposed use is consistent with all applicable County, State and Federal laws, rules and regulations as conditioned below. Additionally, the use will meet local and State Fire Code requirements. g. The proposed use will not adversely affect the general welfare, as conditioned below, as a result of noise, increased traffic, interference with flow of traffic, dust, or other undesirable characteristics. Although the Project will add a small number of vehicle trips, no intersections will be impacted. Additionally, various conditions are imposed to ensure the project does not cause excess noise and impede traffic flow. h. All of the conditions imposed on the Project are necessary to protect the public health, safety and general welfare. It is recommended that the following conditions be imposed to adequately protect the public health, safety and general welfare: a. The Applicant shall operate the facility in accordance with, and made to conform with all current codes, rules, and regulations including any required fees adopted by the City of Vernon not otherwise addressed by this grant of a conditional use permit. -7- b. The Applicant shall operate the facility in accordance with all federal, state and local laws and shall obtain and maintain necessary permits including, but not limited to wastewater permits from the Sanitation District of Los Angeles County, NPDES permit from the Regional Water Quality Control Board and Air Quality permits from the South Coast Air Quality ManagementDistrict. C. Any hazardous substances used, handled and/or stored on the Project site shall have prior approval from the Vernon Fire and Health Departments. The Applicant shall obtain a Health Permit if there are reportable quantities of hazardous materials on the site. Only the items listed in the hazardous material report submitted shall be stored on the site. d. Servicing of vehicles, including but not limited to, washing, steam cleaning and repairing shall not be permitted on the premises. No inoperative vehicles shall be stored on -site. All vehicles operated at the facility shall be tuned and maintained in accordance with applicable emission standards. e. The Applicant shall operate the facility in a manner, which will not impede traffic on Slauson Avenue. The Applicant shall ensure all vehicles enter and exit the site in a front forward manner. No vehicle parking or staging associated with the facility shall take place on any public street within the City of Vernon. The Applicant shall ensure that trucks do not idle when parked on the subject site. The driveway to the site shall be reconstructed to conform with city standard PV693. f. The Applicant shall ensure that the facility's building is structurally maintained to exclude rodents and shall ensure the property is maintained rodent free. The Applicant shall ensure that adequate drainage on the site to eliminate potential mosquito harborage. g. A spill prevention, control and countermeasure (SPCC) plan shall be developed for the facility to the satisfaction of the Director of Environmental Health. Materials must be available for cleaning up of leaks or spills of substances associated with the Applicant operation. h. The Applicant shall implement a personnel safety -training program to include personal safety, handling hazardous materials and fire protection procedures prior to any Class I or Class II liquids being stored on site. The written program shall be made available for review upon the City's request. i. The project site shall be constructed and maintained substantially in compliance with the site plan submitted as part of this conditional use permit application. -8- j. The Applicant shall ensure that all parking and loading areas are striped in a manner acceptable to the Director of Community Services & Water and are paved with a hard durable surface material and adequately drained, and kept free of dust, mud, trash and weeds. Where parking or maneuvering areas adjoin the public street, a barrier wall or landscaping shall be installed and maintained to meet City standards. k. All on -site construction of improvements shall be in compliance with the most current Building Codes (Building, Fire, Mechanical, Plumbing and Electrical) and current Health and Safety Codes and Regulations, including, but not limited to piping systems (valves, testing, corrosion protection, back flow protection, manual drainage and pipe supports), tank design (including vent lines, vent pipe outlets, manifolds, emergency venting, over flow protection, and vapor recovery systems), secondary containment shall be provided for the tank farm area and loading and unloading areas, (the site shall be graded so that the loading and unloading areas drain away from buildings on the site and to an appropriate sized sump). The existing and new electrical systems shall conform with the requirements for Class I and Class II liquid storage areas and shall be upgraded to Class 1 Division 1 in accordance with Article 500 of the California Electrical Code, to the top of the tanks. In addition to any required Vernon Environmental Health Department clearance, the Applicant shall obtain all necessary building, fire, mechanical, plumbing, and electrical permits from the City of Vernon Community Services Department and complete construction, prior to any Class I or Class II liquids being stored at the site. Prior to construction a fire protection engineer shall prepare a report outlining all required safety requirements of the California Building Codes and NFPA Standards and at the completion of construction inspect the site and certify that all required safety components have been installed in compliance with the appropriate standards. 1. The Applicant shall operate the facility in such a manner that noise and vibration shall not be a nuisance to neighborhood properties. At no time shall noise exceed or vibrations exceed the standards set forth in the City Zoning Ordinance. The facility shall comply with all CalOSHA noise requirements at all times. If the City in its sole discretion determines that a noise nuisance is caused by the operation, a noise study shall be prepared by the Applicant to the satisfaction of the Director of Community Services and Water to determine if the facility is in compliance with the City's Zoning Regulations. M. The Applicant shall operate the facility in such a manner that odors shall not be a nuisance to neighborhood properties. If the City in its sole discretion determines that an odor nuisance is caused by the operation, additional odor controls shall be installed to the satisfaction of the Director of Community Services and Water or the facility shall cease all operations until the odor problem is resolved. -9- n. The Applicant shall obtain a lease from DWP for the installation of the secondary fire access road to the rear of the property. A new driveway shall be constructed where the fire roads accesses Slauson Avenue. The fire access road shall extend from Slauson Avenue to the railroad tracks just south of the westerly prolongation of the north property line of the Applicant site. One breakaway gate a minimum of 35- feet in width shall be provided at a location determined by the City of Vernon. The roadway shall be a minimum of 27-feet in width, and paved with a minimum 4-inch asphalt concrete pavement or concrete pavement over 6-inch crushed miscellaneous base. No Class I or Class 11 liquids shall be permitted on the site prior to the completion of the fire access road construction. o. In areas where less then 25-feet distance is provided between the flammable unloading and loading area and any aboveground tank, a 9-foot high masonry or concrete wall having a minimum two hour fire rating shall be constructed between the tank farm and the rail tank car unloading and loading area and the tank farm and the truck loading and unloading area. No Class I or Class II liquids shall be permitted on the site prior to the wall being constructed. P. A foam fire protection system shall be installed in accordance with NFPA Standard 11. At minimum, the number of fire monitors and foam storage tanks shall be provided as shown on the Eastman expansion project drawing dated May 2009, submitted with the project application. Three fixed fire monitors shall be mounted at minimum of 50-feet in height and directed into the diked area where the Class I and Class II liquids will be stored. No Class I or Class II liquids shall be permitted on the site prior to the completion of the foam fire protection system installation. q. Noncompliance with any of the conditions herein shall constitute sufficient grounds for the City Council of the City of Vernon to void this conditional use permit pursuant to Section 26.6.3-9 of the Comprehensive Zoning Ordinance. -10- Vy DEC 2 3 "M9 Cliff CLERK'S OFFICE COMMUNITY SERVICES & WATER DEPARTMENT DATE: December 22, 2009 01W TO: Donal O'Callaghan, City Administrator � FROM: Samuel Kevin Wilson Director of Community Services & Water RE: Conditional Use Permit — Lubricating Specialties Company located at 3365 Slauson Avenue Lubricating Specialties Company (the "Applicant") has submitted an application to amend their existing conditional use permit that was previously approved on March 17, 1992 for the property located at 3365 Slauson Avenue in the Industrial I -Zone of the city, in order to operate a petroleum related facility (the "Project"). This conditional use permit limited the Applicant to the storage, processing and transferring of only Class III liquids and other combustible products. They now wish to store, blend and distribute Class I,1I and III liquids, as defined in the California Fire Code, in their existing tank farm (Tank Farm "B") located at 3365 Slauson Avenue. Tank Farm B is divided in two sections; the east section is 7,925 sq. ft., and west section is 5,575 sq. ft. the Applicant proposes to utilize four 50,000 gallon tanks and two 14,000 gallon tanks to store the Class I and Class 11 liquids on the west sections of Tank Farm B. The environmental analysis performed for the City of Vernon's issuance of the prior conditional use permit indicated that the oils and greases that the Applicant processed were limited to low to moderate fire hazards with flash points of the materials above 200°. The Applicant now proposes to distribute liquids with much lower flash points. Thus, in order to allow the storage of these liquids, the Applicant's Conditional Use Permit must be amended. Therefore, the Applicant is requesting an amendment to their existing conditional use permit to allow them to store Class I and Class II liquids at the subject site. After review of the application by the Community Services Department, it is recommended that the conditional use permit be granted. Enclosed herewith for your consideration are the following supporting documents: 1. Staff Report. 2. Request for conditional use permit and information supporting the application. 3. Notice of Public Hearing and affidavit of mailing. I-5,E4 c!V DEC 2 2 2009 BY : 6,_k It ', a 0 The project is categorically exempt under Section 15301, Class 1, of the California Environmental Quality Act ("CEQA"). A Notice of Exemption will be prepared and filed with the County Clerk. Therefore, it is recommended that the conditional use permit be approved subject to the following conditions set forth below: a. The Applicant shall operate the facility in accordance with, and made to conform with all current codes, rules, and regulations including any required fees adopted by the City of Vernon not otherwise addressed by this grant of a conditional use permit. b. The Applicant shall operate the facility in accordance with all federal, state and local laws and shall obtain and maintain necessary permits including, but not limited to wastewater permits from the Sanitation District of Los Angeles County, NPDES permit from the Regional Water Quality Control Board and Air Quality permits from the South Coast Air Quality Management District. C. Any hazardous substances used, handled and/or stored on the Project site shall have prior approval from the Vernon Fire and Health Departments. The Applicant shall obtain a Health Permit if there are reportable quantities of hazardous materials on the site. Only the items listed in the hazardous material report submitted shall be stored on the site. d. Servicing of vehicles, including but not limited to, washing, steam cleaning and repairing shall not be permitted on the premises. No inoperative vehicles shall be stored on -site. All vehicles operated at the facility shall be tuned and maintained in accordance with applicable emission standards. e. The Applicant shall operate the facility in a manner, which will not impede traffic on Slauson Avenue. The Applicant shall ensure all vehicles enter and exit the site in a front forward manner. No vehicle parking or staging associated with the facility shall take place on any public street within the City of Vernon. The Applicant shall ensure that trucks do not idle when parked on the subject site. The driveway to the site shall be reconstructed to conform with city standard PV693. f. The Applicant shall ensure that the facility's building is structurally maintained to exclude rodents and shall ensure the property is maintained rodent free. The Applicant shall ensure that adequate drainage on the site to eliminate potential mosquito harborage. g. A spill prevention, control and countermeasure (SPCC) plan shall be developed for the facility to the satisfaction of the Director of Environmental Health. Materials must be available for cleaning up of leaks or spills of substances associated with the Applicant operation. h. The Applicant shall implement a personnel safety -training program to include . personal safety, handling hazardous materials and fire protection procedures prior to any Class I or Class II liquids being stored on site. The written program shall be made available for review upon the City's request. i. The project site shall be constructed and maintained substantially in compliance with the site plan submitted as part of this conditional use permit application. j. The Applicant shall ensure that all parking and loading areas are striped in a manner acceptable to the Director of Community Services & Water and are paved with a hard durable surface material and adequately drained, and kept free of dust, mud, trash and weeds. Where parking or maneuvering areas adjoin the public street, a barrier wall or landscaping shall be installed and maintained to meet City standards. k. All on -site construction of improvements shall be in compliance with the most current Building Codes (Building, Fire, Mechanical, Plumbing and Electrical) and current Health and Safety Codes and Regulations, including, but not limited to piping systems (valves, testing, corrosion protection, back flow protection, manual drainage and pipe supports), tank design (including vent lines, vent pipe outlets, manifolds, emergency venting, over flow protection, and vapor recovery systems), secondary containment shall be provided for the tank farm area and loading and unloading areas, (the site shall be graded so that the loading and unloading areas drain away from buildings on the site and to an appropriate sized sump). The existing and new electrical systems shall conform with the requirements for Class I and Class II liquid storage areas and shall be upgraded to Class 1 Division 1 in accordance with Article 500 of the California Electrical Code, to the top of the tanks. In addition to any required Vernon Environmental Health Department clearance, the Applicant shall obtain all necessary building, fire, mechanical, plumbing, and electrical permits from the City of Vernon Community Services Department and complete construction, prior to any Class I or Class II liquids being stored at the site. Prior to construction a fire protection engineer shall prepare a report outlining all required safety requirements of the California Building Codes and NFPA Standards and at the completion of construction inspect the site and certify that all required safety components have been installed in compliance with the appropriate standards. 1. The Applicant shall operate the facility in such a manner that noise and vibration. shall not be a nuisance to neighborhood properties. At no time shall noise exceed or vibrations exceed the standards set forth in the City Zoning Ordinance. The facility shall comply with all CalOSHA noise requirements at all times. If the City in its sole discretion determines that a noise nuisance is caused by the operation, a noise study shall be prepared by the Applicant to the satisfaction of the Director of Community Services and Water to determine if the facility is in compliance with the City's Zoning Regulations. M. The Applicant shall operate the facility in such a manner that odors shall not be a nuisance to neighborhood properties. If the City in its sole discretion determines that an odor nuisance is caused by the operation, additional odor controls shall be installed to the satisfaction of the Director of Community Services and Water or the facility shall cease all operations until the odor problem is resolved. n. The Applicant shall obtain a lease from DWP for the installation of the secondary fire access road to the rear of the property. A new driveway shall be constructed where the fire roads accesses Slauson Avenue. The fire access road shall extend from Slauson Avenue to the railroad tracks just south of the westerly prolongation of the north property line of the Applicant site. One breakaway gate a minimum of 35-feet in width shall be provided at a location determined by the City of Vernon. The roadway shall be a minimum of 27-feet in width, and paved with a minimum 4-inch asphalt concrete pavement or concrete pavement over 6-inch crushed miscellaneous base. No Class I or Class II liquids shall be permitted on the site prior to the completion of the fire access road construction. o. In areas where less then 25-feet distance is provided between the flammable unloading and loading area and any aboveground tank, a 9-foot high masonry or concrete wall having a minimum two hour fire rating shall be constructed between the tank farm and the rail tank car unloading and loading area and the tank farm and the truck loading and unloading area. No Class I or Class II liquids shall be permitted on the site prior to the wall being constructed. P. A foam fire protection system shall be installed in accordance with NFPA Standard 11. At minimum, the number of fire monitors and foam storage tanks shall be provided as shown on the Eastman expansion project drawing dated May 2009, submitted with the project application. Three fixed fire monitors shall be mounted at minimum of 50-feet in height and directed into the diked area where the Class I and Class II liquids will be stored. No Class I or Class II liquids shall be permitted on the site prior to the completion of the foam fire protection system installation. q. Noncompliance with any of the conditions herein shall constitute sufficient grounds for the City Council of the City of Vernon to void this conditional use permit pursuant to Section 26.6.3-9 of the Comprehensive Zoning Ordinance. SKW/sc Enclosures c: City Attorney AFFIDAVIT OF MAILING STATE OF CALIFORNIA ) COUNTY OF LOS ANGELES ) ss CITY OF VERNON ) I, SERGIO CANALES, Planning Assistant of the City of Vernon, do hereby certify that on Tuesday, December 22, 2009, mailed a copy of Notice of Public Hearing to be held on January 4, 2010, regarding a Conditional Use Permit for Lubricating Specialties Company (LSC) located at 3365 Slauson Avenue, to the interested parties and owners on the attached list, by United States Mail with postage. Date: / 0� 'm- 0 J ergio Ca es, Planning Assistant State of California ) ) ss County of Los Angeles ) On -""vv 7 2-1 2a q before me, Nc a"e 4 e lde�1 , notary public, personally appeared Sergio Canales who proved to me on the basis of satisfactory evidence to be the person(s) whose name{) is/afe subscribed to the within instrument and acknowledged to me that he/she/the y executed the same in hiss/their authorized capacity(ies), and that by his�her hei signature(s) on the instrument the person(s), or the entity upon behalf of which the person(-s) acted, executed the instrument. I certify under PENALTY OF PERJURY under the laws of the State of California that the foregoing paragraph is true and correct. WITNESS my hand and official seal. MANUELA GIAON Commission #t 1667448 • Notary Public - California Los Angeles County MY Comm. Expires Nov 4, 2013 Easy Peel Labels See' Instruction Sheet 1 �A �AViERY051600 Use Avery`D TEMPLATE 51600 jFeed Paper ® for Easy Peel Feature City of Huntington Park Lucille Roybal-Allard John Kinas Planning Department Congresswoman United States Aluminum 6550 Miles Avenue 255 E. Temple St., Ste 1860 3663 Bandini Boulevard Huntington Park, CA 90255 Los Angeles, CA 90012 Vernon, CA 90023 L.A. County Board of Supervisors Director of Planning Gloria Molina James Hertl — Room 1390 Board of Supervisors 320 W. Temple Street 500 W. Temple St., Ste 856 Los Angeles, CA 90012 Los Angeles, CA 90012 South Coast Air Quality Mgmt District (AQMD) 21865 E. Copley Drive Diamond Bar, CA 91765 Brian Scanlon L.A. County Public Works Mapping & Property Mgmt. 900 S. Fremont Avenue, 10th Floor Alhambra, CA 91803 City of Commerce Planning Department 2535 Commerce Way Commerce, CA 90040 City of Bell Planning Department 6330 Pine Street Bell, CA 90201 City of Long Beach Office of the City Manager 333 W. Ocean Blvd., 13th floor Long Beach, CA 90802 01- ■ . _ _ .... California Water Service Comp 3316 West Beverly Boulevard Montebello, CA 90640 Marisa Olguin Chamber of Commerce 3801 Santa Fe Avenue Vernon, CA 90058 L.A. Unified School District Ms. Gutierrez 924 S. Mott Street Los Angeles, CA 90023 E.J. Contreras Owens -Brockway 2901 Fruitland Avenue Vernon, CA 90058 James H. Hillands Heger Realty Corp. 5657 E. Washington Blvd. Los Angeles, CA 90040 Joseph R. Garruba California Portland Cement Co. 2025 E. Financial Way Glendora, CA 91740 City of Cudahy Office of Environmental Health & Safety Dave Karrker Los Angeles, Planning Department 333 South s, CA 90017 y Ave., 20 Floor California Water Service Attention: Glenn 5220 Santa Ana Street Glenn 5243 E. Sheila Street Cudahy, CA 90201 Striegler Commerce, CA 90022 L.A. County Sanitation District P.O. Box 4998 Whittier, CA 90607 City of Maywood Planning Department 4319 Slauson Avenue Maywood, CA 90270 L.A. County Flood Control District 900 S. Fremont Avenue, 8th Floor Alhambra, CA 91803 City of Los Angeles Planning Department 200 North Spring St. Los Angeles, CA 90012 Suk Chon County of Los Angeles Department of Public Works Land Development Division P.O. Box 1460 Alhambra, CA 91802-1460 J.J. Little J.J. Little Company, Inc. 9945 Malgar Drive Whittier, CA 90603 L.R. Luppen Metal Products Engineering 3050 Leonis Boulevard Vernon, CA 90058 Ellen Orlando Karen Lehrer 2300 E. 11 th Street Los Angeles, CA 90021 Etiquettes faciles a peter A Consultez la feuille www.avery.com UtiI I o-b-,,!t AVEPYrl"'R> Sene, do chargement d'instruction Easy Peel Labels i A See Instruction Sheet ' A!/EIZI(®51600 Use Avery® TEMPLATE 51600 iFeed Paper for Easy Peel Featured � AT&T The Gas Company (So. Cal Gas Co.) 100 W. Alondra Blvd., Rm 202A So. Cal Edison 1924 Cashdan Street P.O. Box 3150 Gardena, CA 90248 Attn: Leslie Donaldson Compton, CA 90220 San Dimas, CA 91773 Attn: Mike Frazier Burlington Northern Santa Fe Railroad L.A. Junction Railroad 3770 E. Washington Blvd. 4433 Exchange Avenue Maywood Mutual Water Co. 3 Los Angeles, CA 90023 Vernon, CA 90058 6151 Heliotrope Avenue Attn: Dick Ebel Attn: Marion Alexander Maywood, CA 90270 ftiquettes faciles a peler A Consultez la feuille Utilisez le gabarit AVI RY@ 51600 Sens de chargernent d'instruction www.avery.com 1-800-60-AVERY 300' Radius Public Notification Boundary APN 6310-004-008 October 17, 2008 3365 E. Slauson Ave. Page 1 of 2 Vernon CA 90058 JN 8354 6310-004-008 1 6310-004-001 3 6310-004-014 4 First Industrial Lp 'Ramsey Development Co Karla G Cook �898 N Sepulveda #750 P.O. BOX 21408 5899 S Downey El Segundo CA 90245 Los Angeles CA 90021 Vernon CA 90058 1*6310-004-015 5 6310-004-010 G 6310-004-009 7 :Vernon Electro Llc Cal York Real Estate Holdings Llc ;Jose M Gonzalez 2825 Temple 3355 E Slauson 601 W Kenneth ',Signal Hill CA 90755 Vernon CA 90058 Glendale CA 91202 '6310-006-007 8 6310-006-013 9 6310-006-016 10 ;5801 Alcoa Avenue Llc Sandberg Furniture Manufacturing Co Abbey Tung 1737 Riverside 3251 E Slauson 134 W Rincon #P Glendale CA 91201 Los Angeles CA 90058 Campbell CA 95008 6310-006-014 11 6310-008-009 12 6310-002-027 13 :Sandberg Furniture Manufacturing Co Sandberg Family Llc Jed M & Rod G Kagan 15705 Alcoa P.O. BOX 58291 5524 Alcoa 'Los Angeles CA 90058 Los Angeles CA 90058 Vernon CA 90058 6310-002-026 14 6310-002-032 15 6310-002-033 16 'Peikar Family Llc Yin H Chang F And D Properties Inc 211 S Beverly #214 5501 S Downey P.O. Box 91594 .Beverly Hills CA 90212 Vernon CA 90058 City Of Industry CA 91715 6310-002-031 17 6310-004-012 18 6310-027-028 19 .Same As #16 Downey 26 Llc 'Welch's Overall Cleaning Co Inc 5681 S Downey 147 S 9th Vernon CA 90058 Minneapolis MN 55402 :(6310-027-047 20 :Lba Realty Fund Iii Company Iv G Llc 6310-027-048 21 12235 Faraday #O Same As #20 ''Carlsbad CA 92008 The addresses below are provided for the 6310-002-009 X23 optional use of staff to meet any Kenneth D & Julia Z Uslan minimum notification requirements 1301 Carla Beverly Hills CA 90210 6310-002-010 X24 6310-002-011 X25 6310-002-012 X26 ,Jcj Family Ltd Ptnshp Steven Supowitz Julius L & Anita Zelman 5207 S Downey 5496 Lindbergh 1301 Carla Vernon CA 90058 Bell CA 90201 Beverly Hills CA 90210 6310-002-013 X27 6310-002-014 X28 Fruitland Frieds Llc D And E Investment Properties Llc 21201 Victory #225 ! 5201 S Downey Canoga Park CA 91303 !Vernon CA 90058 6310-002-016 X30 6310-002-022 X31 j Stephen S Sobul John Cardenas 12100 Wilshire #1150 339 W Norman Los Angeles CA 90025 Arcadia CA 91007 6310-002-024 X33 Kudenoff Kroener Family Ptnshp P.O. BOX 2010 Paso Robles CA 93447 6310-002-029 5353 Downey Assoc 9595 Wilshire #401 Beverly Hills CA 90212 6310-008-002 Karguval Properties Ltd 12011 San Vicente #700 Los Angeles CA 90049 '; 6310-008-007 Anwar & Yasmeen Gajiani 4741 E Copa De Oro Anaheim CA 92807 6310-027-022 Boyle Ave Llc 1400 E Olympic #200 Los Angeles CA 90021 6310-027-027 Vest Inc 6023 Alcoa Vernon CA 90058 6310-027-036 Mfc Realty Partnership 6180 Alcoa Vernon CA 90058 6310-002-025 X34 Ben Friend 10717 Wilshire #801 Los Angeles CA 90024 X36 6310-002-035 X37 Vernon Investors Llc P.O. BOX 58368 Los Angeles CA 900.58 X39 6310-008-005 X40 Rrr Real Estate Co Llc 5151 Alcoa Vernon CA 90058 X42 6310-008-008 X43 Joel Friedman 3675 Locksley Pasadena CA 91107 X45 6310-027-023 X46 Imperial Real Estate Holdings Lp 1525 S Broadway Los Angeles CA 90015 X48 6310-027-030 X49 6062 Alcoa Realty Lp 6062 Alcoa Vernon CA 90058 X51 6310-027-037 X52 Slauson Distribution Center Ltd 11400 W Olympic #860 Los Angeles CA 90064 6310-027-041 X54 ' Lba Realty Fund Iii Company Iv G Llc 2235 Faraday #O Carlsbad CA 92008 6310-002-015 X29 Fruitland Assoc 3336 Fruitland Los Angeles CA 90058 6310-002-023 X32 Ernest C & Suzanna Kroener P.O. BOX 2010 Paso Robles CA 93447 ' 6310-002-028 X35 Onnie Benchetrit 5496 Lindbergh Bell CA 90201 6310-002-270 X38 L A City Dept Of Water And Power P.O. BOX 51111 Rm 633 Los Angeles CA 90051 6310-008-006 Xa Partners Llc 2500 Michelson #200 Irvine CA 92612 6310-008-010 Century Cast Plate Inc 3200 Fruitland Vernon CA 90058 6310-027-026 5991 Alcoa Assoc Llc 601 W Olympic Montebello CA 90640 6310-027-031 Pt X Llc 5657 E Washington Los Angeles CA 90040 6310-027-039 RCCI 5970 Alcoa Vernon CA 90058 X41 X44 X47 X50 X53 r x RPRIVED G�4pFYL^ O� h JUN 0 3 2�09 7 ahBX.T I _ + Vernon, Department of Community Services 4305 Santa Fe Avenue, Vernon, CA 90058 Phone (323) 583-8811 Fax (323) 826-1435 CONDITIONAL USE PERMIT APPLICATION PLEASE PRINT OR TYPE SECTION 1- Project Information. Project Title: LUBRICATING SPECIALTIES COMPANY - EASTMAN EXPANSION Project Site Address: 3365 E. SLAUSON AVE. VERNON. CALIFORNIA. ZIP: 90058 Assessor Parcel Number (APN): 6310-004-008 Zoning Designation: I - ZONE Purpose of Conditional Use Permit Application: TANK EXPANSION TO HOUSE CLASS 11 AND CLASS III MATERIALS. w SECTION 2 — Applicant Information. I hereby certify that all the information contained herein and in the accompanying exhibits are true and correct to the best of my knowledge and belief. Applicant: (Applicant shall either be the Property Owner or Owner's Representative) Applicant Name: LUBRICATING SPECIALTIES COMPANY ❑Sole Proprietor []Partnership (Corporation Contact Name: REGULO ROJAS Contact Address: 8015 PARAMOUNT BLVD. City: PICO RIVERA Zip Code: 90660 Phone: (562) 776-4032 Fax: (562) 776-4149 E-mail: rrojas@lubespecialties.com Page 1 of 2 (Two officer's signatures are required for Corporation and Limited Liability Companies (LLC)) Print Name: Title: Signature (Applicant signatures must be notarized): Print Name: Title: Signature (Applicant signatures must be notarized): SECTION 3 — Contact Information (if different from applicant). Name: Address: Company Name: Date: Date: City: Zip Code: Phone: Fax: Relation to Applicant: ❑Engineer ❑Architect ❑Attorney ❑Realtor El Representative SECTION 4 — Property Owner Information. I am the property owner of record, of the property, which is the subject of this application. I have reviewed this application and authorize/approve of the action requested. Property Owner Name: LUBRICATING SPECIALTIES COMPANY El Sole Proprietor Address: 3365 E. SLAUSON AVE Phone: (562) 776-4000 ❑Partnership lCorporation City: VERNON Zip Code: 90058 : (562) 776-4149 0 YES,. I hereby certify that the above named applicant is authorized to act as the property owner representative for this conditional use permit application. ❑ NO, I DON'T certify that the above named applicant is. authorized to act as the property owner representative for this conditional use permit application. (Two officer's signatures are required for Corporation and Limited Liability Companies (LLC)) Print Name: Title: Date: Signature (Applicant signatures must be notarized): Print Name: Title: Date: Signature (Applicant signatures must be notarized): Page 2.of 2 PROJECT DESCRIPTION (Attach additional sheets:a's necessary) TOTAL LOT: 4,19 ACRES 1. Site size (Lot size). WAREHOUSE BLDG: 42,931 SQ. FT. OFFICES: 3,560 SQ. FT. & MANUFACTURING: 9,143 SQ. FT. 2. Square footage of building(s) on the premises (including any covered structures or canopies). NO ADDITIONAL BUILDINGS IN THIS PROJECT. 3. Number of floors of construction. N/A 4. Amount of off-street parking and loading provided: a. Number of automobile parking spaces 58 SPACES: 56 STANDARD + 2 HANDICAPPED b. Number of truck parking spaces 2 TRUCK PARKING SPACES c. Number of truck loading spaces 6 TRUCK LOADING SPACES 5. Proposed scheduling. TERMINAL OPERATION START UP DATE: APRIL-1st-2009 6. Associated projects (additional projects). * CONCRETE PADS FOR VCU AND DEIONIZED WATER SYSTEM. * VAPOR COMBUSTION UNIT. * WHITE OIL TANK. * ON-LINE LEVEL MONITOR SYSTEM. * FIRE PROTECTION. ALL THESE PROJECTS ARE ASSOCIATED WITH THE TANK EXPANSION PROJECT. 7. Anticipated incremental development (additional phases). N/A 8. If retail or commercial, indicate the type, whether neighborhood, city o r regionally oriented, square footage of sales area, and loading facilities (on attached sheet). N/A 9. If industrial, indicate type, estimated employment per shift, and loading facilities (on attached sheet),INDUSTRY: LUBRICANT MANUFACTURING AND TERMINAL OPERATION. EMPLOYMENT PER SHIFT: 35 WORKERS FOR EXISTING MANUFACTURING OPERATIONS AND ADDITIONAL EMPLOYMENT OF 5 WORKERS ONLY FOR PROJECTED TERMINAL EXPANSION. WORKING HOURS: ONE SHIFT OPERATION FROM 7:OOAM TO 15:00 PM WITH EXTENDED HOURS UP TO 23:30PM. MONDAY TO FRIDAY. EXTENDED OPERATION ON SATURDAY AND SUNDAYS FROM 7:OOAM TO 15:OOPM, UPON PRODUCTION AND MAINTENANCE NEED. THIS SCHEDULE APPLIES FOR BOTH, ACTUAL AND ADDITIONAL WORKERS. LOADING FACILITIES: SUFFICIENT NUMBER OF LOADING SPACES ARE AVAILABLE ONSITE FOR LSC ACTUAL AND PROJECTED NEED. Page 1 of 1 BURDEN OF PROOF The applicant is required to establish the following before submitting a Conditional Use Permit application: (Attach additional sheets if necessary:) A) The site for the proposed use is adequate in size, shape and topography, including drainage and landscaping. THE SITE IS ADEQUATE IN SIZE, SHAPE AND TOPOGRAPHY, INCLUDING DRAINAGE FOR THE OPERATION PROPOSED. B) The proposed use will not have an adverse effect upon adjacent or abutting properties in terms of traffic, parking noise, odors, and dust, smoke, light or glare, or risk of fire, infection or explosion. THE OPERATION PROPOSED WILL NOT HAVE AN ADVERSE EFFECT UPON ADJACENT OR ABUTTING PROPERTIES IN TERMS OF TRAFFIC, PARKING NOISE, ODORS, DUST, SMOKE, LIGHT OR GLARE, RISK OF FIRE, INFECTION OR EXPLOSION. Q The proposed use will be compatible with the permitted uses of surrounding and adjacent properties. THE PROPOSED USE WILL BE COMPATIBLE WITH THE PERMITTED USES OF SURROUNDING AND ADJACENT PROPERTIES. D) The site has sufficient access to streets and highways, which are adequate in width and pavement type to carry the quantity of traffic generated by the proposed use, and that the routes which vehicles will have to follow to reach the site are adequate in width and pavement type to carry the volume of traffic generated by the proposed use. THE SITE HAS SUFFICIENT ACCESS TO STREETS. THE ROUTES WHICH VEHICLES WILL HAVE TO FOLLOW TO REACH THE SITE ARE ADECUATE IN WIDTH AND PAVEMENT TYPE TO CARRY THE VOLUME OF TRAFFIC GENERATED BY THE PROPOSED OPERATION. E) The site has adequate off-street parking and loading facilities. THE SITE HAS ADEQUATE_ OFF-STREET PARKING AND LOADING FACILITIES ON SITE FOR LSC's ACTUAL AND PROJECTED NEED, AND INCLUDING BOTH EMPLOYEE AND VISITOR PARKING. F) The use, as to location, operation and design, is consistent with the general plan, any applicable specific plan and the zoning regulations.of the City of Vernon and all applicable County, State and federal law, rules and regulations. THE OPERATION IS CONSISTENT WITH FEDERAL LAW, RULES AND REGULATIONS APPLICABLE. 6 Signed 0', A:Z) (Applicant) r"Al 2��``zQ09 Page 1 of 1 ENVIRONMENTAL CHECKLIST Date Filed: (0 -1- 0 I General Information: I Name, address, and telephone number of developer or project sponsor: STEVE MILLER - VP MANUFACTURING LUBRICATING SPECIALTIES COMPANY 8015 PARAMOUNT BLVD., PICO RIVERA, CA. 90660 PHONE: (562) 776-4025 FAX: (562) 776-4149 2. Address of project (location): LUBRICATING SPECIALTIES COMPANY 3365 SLAUSON AVE., VERNON, CA. 90058 Assessor's Block and Lot Number (APN#): 6310-004-008 3. Name, address, and telephone number of person to be contracted concerning this project: REGULO ROJAS LUBRICATING SPECIALTIES COMPANY 8015 PARAMOUNT BLVD., PICO RIVERA, CA. 90660 PHONE: (562) 776-4025 FAX: (562) 776-4149 4. Indicate number of the permit applications for the project to which this form pertains: CITY OF VERNON: 5. List and describe any other related permits and other public approvals required for this project, including those required by city, regional, state and federal agencies:_ SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT: F98746, F98748, F98744, F98747, F98745, F98743 AND F97972. 6. Existing zoning district: 7. Proposed use of site (Project for which this form is filed): LUBRICATING SPECIALTIES COMPANY - EASTMAN EXPANSION TANK EXPANSION TO HOUSE FLAMMABLE MATERIALS. Page 1 of 3 Proiect Description: 8. Site Size (Lot Size): TOTAL LOT: 4,19 ACRES MANUFACTURING & WAREHOUSE BLDG: 52,074 SQ. FT. 9. Square footage of Building(s): OFFICES & LABORATORY: 3,560 SQ. FT. 10. Number of floors of construction: WAREHOUSE A: 1 STORAGE FLOOR AND 1 OFFICE FLOOR. WAREHOUSE B: 1 STORAGE FLOOR AND 2 MEZZANINES. NO ADDITIONAL BUILDING IN THIS PROJECT. 11. Amount of off-street parking provided:56 STANDARD PLUS 2 HANDICAPPED, TOTAL 58. 2 TRUCK PARKING SPACES. 6 TRUCK LOADING SPACES. 12. Attach plans: PLOT PLAN ATTACHED. 13. Proposed scheduling: STARTUP DATE: JUNE-1 st-2009 14. Associated projects: * CONCRETE PADS FOR VCU AND DEIONIZED WATER SYSTEM. * VAPOR COMBUSTION UNIT. * WHITE OIL TANK. * ON-LINE LEVEL MONITOR SYSTEM. * FIRE / FOAM PROTECTION. 15. Anticipated incremental development: N/A 16. If retail or commercial, indicate the type, whether neighboring, city or regionally oriented square footage of sales area, and loading facilities. N/A 17. If industrial, indicate type, estimated employment per shift, and loading facilities._ INDUSTRY: LUBRICANT MANUFACTURING AND TERMINAL OPERATION. EMPLOYMENT PER SHIFT: 35 WORKERS FOR EXISTING MANUFACTURING OPERATIONS, AND continues down 18. If the project involves a variance, conditional use permit application, state this and indicate clearly why the application is required. CONDITIONAL USE PERMIT IN ORDER TO HOUSE FLAMMABLE MATERIALS. THIS APPLICATION IS REQUIRED BY THE CITY OF VERNON. 17. Cont. WORKING HOURS: ONE SHIFT OPERATION FROM 7:OOAM TO 03:00 PM WITH EXTENDED HOURS UP TO 11:30PM. MONDAY TO FRIDAY. EXTENDED OPERATION ON SATURDAY AND SUNDAYS FROM 7:OOAM TO 3:OOPM, UPON PRODUCTION OR MAINTENANCE NEEDS. THIS SCHEDULE APPLIES FOR BOTH, ACTUAL AND ADDITIONAL WORKERS., LOADING FACILITIES: SUFFICIENT NUMBER OF LOADING SPACES ARE PROVIDED ONSITE FOR LSC ACTUAL AND PROJECTED NEED. Page 2 of 3 Are any of the following items applicable to the projects or its effects? Discuss on an attached sheet all items checked yes (attach additional sheets if necessary). YES NO ❑ M 19. Change in pattern, scale or character of general area of project. ❑ X 20. Significant amounts of solid waste or litter. ❑ 0 21. Change in dust, ash, smoke, fumes or odors in vicinity. ❑ 0 22. Substantial change in existing noise or vibration levels in the vicinity. ❑ M 23. Site on filled land or on slope of 10 percent or more. ❑ a 24. Use of disposal of potentially hazardous materials, such as toxic substances, flammables or explosives. ❑ M 25. Substantial change in demand for municipal services (police, fire, water, sewage, etc.) ❑ a 26. Substantially increase fossil fuel consumption (electricity, oil, natural gas, etc.) ❑ M 27. Relationship to a larger project or series of projects. Environmental Setting 28. On an attached sheet, describe the project site as it exists before the project, including information on topography, soil stability, plants and animals, and any cultural, historic or scenic aspects. Describe any existing structures on the site and the use of the structures. Attach photographs of the site. Snapshots or Polaroid photos will be acceptable. 29. On an attached sheet, describe the surrounding properties, including information on plants and animals and any cultural, historical or scenic aspects. Indicate the type of land use (residential, commercial, etc.), and scale of development (height, frontage, set -back, rear yard, etc.). Attach photographs of the vicinity. Snapshots or Polaroid photos will be acceptable. Certification: I hereby certify that the statements furnished above and in the attached exhibits present the data and information required for this initial evaluation to the best of my ability, and that the facts, statements, and information presented are true and correct to the best of my knowledge and belief. (Si Date Page 3 of 3 Lubricating Specialties Company, LSC. OPERATION REPORT Conditional Use Permit Case General Faeflity Information Name: Address: Type: Date of Initial Operations: Owner/Operator: Primary Contact: Actual Plant Operations: Lubricating Specialties Company 3365 E. Slauson Ave Vernon, CA 90058 (562) 776-4000 Compounder and packaging facility 1968 Lubricating Specialties Company 8015 Paramount Blvd Pico Rivera, CA 90660 John Alexander, Compliance Manager Work: (562) 776-4090 Cell: (213) 792-2265 Lubricating Specialties company is a lubricating oil compounder and packager. The facility at 3365 E. Slauson Ave, Vernon, CA contains a manufacturing and warehouse building, two outside contained bulk storage tank farms, tank car and truck loading and unloading areas, and drums storage of petroleum chemical and finished product. The present site is approximately four and a half acres with tank farms and buildings that occupy about two acres. Approximately 98% of the site has an impervious surface. The facility has been in operation since 1989. Since operations began, there has been one spill that has contributed significantly to storm runoff pollution. The site stores lubricating oils and petroleum chemicals. These items are the actual major pollution concern of the facility. The sites' vulnerability and sources for pollution potential are listed in the "Vulnerability Analysis" and "Spill Sources and Containment". The facility handles, stores, uses, and distributes petroleum products in the form of motor oil additives, automatic transmission oil, greases, and specialty products. LSC receives products by common carrier via tanker truck and rail cars. The products are stored in several aboveground storage tanks (ASTs). They are delivered to customers by common carrier and independent contractors. The attached Site Plan shows the location and layout of the facility. It also shows the location of oil containers, buildings, loading/unloading and transfer areas, and critical spill control structures. This facility (ISO 9001:2000 certified) is a unique and flexible plant in that there are actually five separate unrelated manufacturing areas, where batch blending and storage of hydraulic oils, motor oils, and grease take place. The Plant has the responsibility for: 1) additive toll processing; 2) white oil processing; 3) grease and fiber optic cable gel manufacturing; 4) military specification lubricants; 5) marine deep draft blending. Batch blending at LSC can involve volumes from 220 to 50,000 gallons for oils, or from 5,000 to 18,000 pounds for greases; and requires adding individual raw materials in a prescribed orderly fashion, one ingredient at a time, according to the product recipe. Specific procedures and processes must be followed for each ingredient that is added, and testing may be required between steps, as well. A sample of each batch is submitted to the quality laboratory before it's released. The plant operates on an extended one -shift operation. • Toll Processing: Involves to terminal, process and quality control check upon receipt and shipment, of products for some of the major chemical and additive companies. Most receipts are by rail with trucks outbound. • White Oil Processing: This operation takes virgin RLOP (Chevron's Richmond Lube Oil Plant) base oils and converts them into technical and USP (US Pharmacopeia) grade materials. In this process also, the plant blends food -grade performance lubricants. • Grease Manufacturing: The plant produces lithium -based products, also manufactures fiber optic cable gel, clay -based and aluminum -based greases. • Military Specification Lubricants: These are PAO (polyalphaolefin synthetic base oil) based and mineral oil fluid materials that are super clean. They are used in military equipment applications. • Marine Deep Draft Blending: The plant blends both regular and zinc -free fluids, including heavy marine engine oils and greases. Different types of greases are manufactured in grease kettles on mezzanine level one, with soap component being blended in soap kettles located in mezzanine level two and three. The finished greases are packaged into 400, 120 and 35 pound metal containers by filling equipment located under mezzanine one. In addition, grease filling of 14-ounce plastic and fiber tubes are filled on the warehouse floor, to be later packaged into cardboard boxes and stored on pallets until shipment is made. Packaged and drum raw materials required for manufacturing and blending of white and hydraulic oils, lubricants and greases are stored in pallets in the warehouses A and B until required and used in production process. Projected Expanded Operations: This expansion project is aimed to store finished product, in a toll processing service fashion for one of our biggest customer, Eastman Chemical. LSC will place an additional set of fixed roof tanks in existing Tank Farm B, including all required process and fire protection equipment to store Eastman products. LSC's operators will upload the product from rail cars to specific product storage tanks. Afterward and according Eastman's distribution schedule, LSC's operators will download the products to truck tank (third party truck companies) in order to serve Eastman's customers in the Los Angeles basin. These products are listed as Class 1 and 2 flammables. The attached table gives an idea about flash and boiling points, OSHA status, liquid average and maximum height, maximum and working volume per product. In addition, the table indicates use of steam, nitrogen (top internal tank blanketing) and vapor recovery. There is one full-scale laboratory on site, able to test and check all products currently manufactured or processed. This laboratory will also test Eastman products. Logistics Department counts with two truck weight scales for incoming and outgoing shipments of our products (no scale service is provided to third parties). LSC employs a total of 35 workers for actual operations. Normal working hours of operations are from 7:00am to 15:00pm, with extended hours up to 23:30pm for selected employees under special request, from Monday to Friday. Some logistics, production and maintenance employees could start at 4:00am, 10:00am or 14:00pm, upon production need. Extended operation on Saturday and Sundays from 7:00am to 15:00pm, upon production and maintenance need. Sufficient number of parking spaces is available for both LSO's employees and visitors (56 standard, plus 2 handicapped). Also, for truck loading and unloading spaces are provided onsite for actual and projected need. Lubricating Specialties Company, LSC. General Facility Information Name: Address: Type: Date of Initial Operations Operator: TRAFFIC REPORT Conditional Use Permit Case Lubricating Specialties Company 3365 E. Slauson Ave Vernon, CA 90058 (562) 776-4000 Compounder and packaging facility 1968 Lubricating Specialties Company 8015 Paramount Blvd Pico Rivera, CA 90660 AIN (APN): 6310-004-008 Lubricating Specialties company is a lubricating oil compounder and packager. The facility at 3365 E. Slauson Ave, Vernon, CA contains a manufacturing and warehouse building, two outside contained bulk storage tank farms, tank car and truck loading and unloading areas, and drums storage of petroleum chemical and finished product. The present site is approximately four and a half acres with tank farms and buildings that occupy about two acres. Approximately 98% of the site has an impervious surface. The facility has been in operation since 1989. The attached Site Plan shows the location and layout of the facility. It also shows the location of oil containers, buildings, loading/unloading and transfer areas, and critical spill control structures. Logistics Department counts with two truck weight scales for incoming and outgoing shipments of our products (no scale service is provided to third parties). LSC employs a total of 35 workers. for actual operations. Normal working hours of operations are from 7:00am to 15:00pm, with extended hours up to 23:30pm for selected employees under special request, from Monday to Friday. Some logistics, production and maintenance employees could occasionally start at 4:00am, 10:00am or 14:00pm, following production schedule. Extended operation on Saturday and Sundays from 7:00am to 15:00pm, upon production and maintenance need. Sufficient number of parking spaces is available for both LSO's employees and visitors (56 standard, plus 2 handicapped). Also, for truck parking (2) loading and unloading (6) spaces are available onsite for actual and projected need. Most of the vehicular traffic at the existing operation will continue as before, which includes employee (35) ingress/egress and trucks that will deliver and pick -UP products. During normal operations the plant receives/ships 6 to 8 truck trips. The proposed project will add 3 to 5 employee and 4 to 6 more truck trips to the existing vehicular traffic. The number of truck trips for the purpose of ingress/egress combined will consist of 8 to 12 entering the premises during a typical 18-hour period, during the balance 6 hours; there is no shipment/receiving operation in the plant. The number of personal vehicle trips will consist of 38 to 42 employees that will ingress/egress according normal hours. Then, the balance of employees will spread over the normal and extended hours of operation. Vehicle traveling to the site will generally exit I-710 and travel southbound on Atlantic Boulevard, then westbound on Slauson Avenue to the site. Vehicles exiting the site will utilize the same streets in the opposite direction. Based in our actual and additional (increment by project) number of employees, the vehicle trips and traffic congestion generated by proposed use will not be enough to cause any significant impact. There is ample on -site perking available for all the vehicles (actual and additional) and the main gate will remain open during operation hours. Lubricating Specialties Company Estimated Peak Travel Times for Trucks and Autos Projections at Full Capacity, and based around Normal Working Hours 3365 E. Slauson Ave Vernon, CA:90058,; Time of Day Autos ` Trucks Existing, Proposed Existing Proposed . 4 am to 5 am 1 1 5amto6am 32 4 6amto7am 2 1 7amto8am 1 8amto9am 2 9 am to 10 am 2 10 am to 11 am 2 11 am to 12 am 2 12 am to 13 am 2 13 am to 14 am 1 14 am to 15 am 1 1 15 am to 16 am 28 2 16 am to 17 am 3 2 17 am to 18 am 2 1 18 am to 19 am 1 19amto20am 20 am to 21 am 21 am to 22 am 22 am to 23 am 23 am to 24 am Estimates are based upon the following assumptions: ❑ Normal working hours of production. ❑ Truck ingress is done off-peak to avoid traffic tie-ups, and spread over normal working hours. ❑ Auto traffic is primarily at the beginning and at the end of normal working hours. ❑ Suppliers and other LSC management visit are not included as they are spread over the day and they are not deemed to impact normal traffic or parking. 0 0 0 o e o o a 0 0o a "t 0 c� O o 0 O 0 0 co O M M dV a O O N 3 N M M 8�5 r r M ih N @ ftl N to L (o a) E E E E I t rr jo io �r 0 d LL LL LL LL N N Rn t� to m M D �•' O in b 0 10 -o - O O o -o Of O Lo P-- 00 0 0 0 Q N N N N N N N N N N = J � 7 2 2 2 2 0 aY fX1 CQ m m O X O O 0 d O UI._ ro U) U') U) �$' C r r U) LL 0 00 C 'I' � ( O w r N (o Lo U-) t-NNN (-) U U U (L N 0 W m � a �� O E' o ly � Z� W i O to �" 00 r-_ N NO I a ~ O r L U')M cl () N sSS M 4 O d N d Q r - o Q. 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U) W o �� �? o in o wy 2 m ZWa a IQ M W r. 00 cl) et r• to VD z h II,- w 00 d2 Q 4 d z yIy-(, y00 y0�0 -�� w w w w w w d 0 o O1 n 1-- co w w w z w w rr> >->-I >0 fA >0 LA N N W W w w W W o z z z 0 m _v y- a) o ro ro a " d Q m CD o Q n" Q. mUJaZcoa Ih 00 0) 0 et w I,- tl- 1 €w co 00 -u it = N cu ra O CO r n X cu C p M M O w II d NO N LO 3 p N LU) Lo u + U_ LO C LCa) Ltm NO dO x _ 1 C p cu$ c3r,v N II II a�N d' LO N 00 y C� NII u O 0LOCi MN '° U �LO uo �c E LO Ln O r X O UII .Qdld O$ 'aA > lY L4 .� N UJ � > p O Q Lo �E LO t t =C� c LA O O Ca 0 ++ LO cu >F—Q� c � U C1) m > � W .----------------- -� 0 � � O x y N0/-7-�Lo M r O CZ U \ ti y O Ln x U O U z a U W J Q W CL w CD a J U W 3 O Ix IL Z O V/ Q X Z W 00 rn .` w U c W 3 a' G N V1 A ccco f/! N L v Q a A Z O_ F- C� NGN LL Y Z a Lubricating Specialties Company Mr. Samuel Kevin Wilson, P.E. Director of Community Services & Water City of Vernon 4305 Santa Fe Avenue Vernon, California 90058 RE: Letter addressed to Lubricating Specialties Company dated August 10, 2009 8015 Paramount Blvd. Pico Rivera, CA 90660-4888 Telephone: 562-776-4000 Fax: 562-776-4004 September 2, 2009 Per your request of the letter dated August 10, 2009, the attachments will address "LSC shall perform an analysis in accordance with AQMD Guidelines to assess operating equipment and truck -related impacts to ensure that emissions will not expose sensitive receptors to pollutant concentrations. This analysis will determine whether the anticipated operating equipment and truck -related emissions are under the significant thresholds." We have referred to the documents that you shared with us from another company in Vernon, AQMD web site, and employees of the AQMD for formulas and process for completion of this report. If there any questions regarding the data provided, please feel free to call me. Regards, Stephen J. Miller Vice President, Manufacturing Lubricating Specialties Company 8015 Paramount Blvd, Pico Rivera, CA 90660 Phone: 562-776-4025 Fax: 562-776-4004 Lubricating Specialties Company 8015 Paramount Blvd. Pico Rivera, CA 90660 Telephone: (562) 776-4182 Fax: (562) 776-4171 ENGINEERING ANALYSIS OPERATING EQUPMENT AND TRUCK. -RELATED IMPACTS Lubricating Specialties Company (LSC) has submitted permit application to the City of Vernon for additional storage operation in the LSC facility located at 3365 Slauson Avenue in the City of Vernon. As the result of a written notification from the Department of Community Services & Water of the City of Vernon on August 10, 2009, LSC conducted the requested Engineering Analysis in accordance with SCAQMD Guidelines and sample analysis provided by the City of Vernon to assess operating equipment and truck -related impacts, ensuring the emissions are under the SCAQMD significance thresholds. Details of the analysis are attached and the results are summarized in the table below. Source CO NOx Sox PM10 PM10 Total V0C lb/day lb/slay lb/clay Fugitive Exhaust PM10 lb/day lb/day lb/day lb/day Additional 1.6 5.2 0 0.3 0.2 0.5 Truck Traffic Tanks 0.18 Truck 3.32 Loading Fugitive 7.86 Components Total 1.6 5.2 0 0.3 0.2 0.5 11.36 Emission Significant 550 100 150 150 55 Threshold Significant No NO NO NO NO As shown in the table, analyses were conducted on the following emission sources. 1. Additional Truck Traffic Emissions — potential emission estimates were calculated based on 10 addition truck trips per day and average trip length of 25 miles per trip. Emission factors were taken from SCAQMD 2009 Scenario. Calculation details are presented in Attachment A. 2. Tank Emissions — potential emission estimates for 5 tanks were calculated using EPA Tanks 4.0 Software. Tanks data, storage liquids data, and calculated emission results are summarized in Attachment B. Tank calculation details are presented in Attachment E. 3. T ruck Loading Emissions — potential emission estimates were calculated based on EPA AP-42, Section 5.2 equation for Truck Loadout and annual Net Throughput gallons for the 5 tanks. Calculation details are presented in Attaclunent C. 4. Fugitive Component Emissions — potential emission estimates were calculated based on the SOCMI Average Emission Factors published in EPA 453/R-95-017. The Average Emission Factors were used to quantify emissions of non -monitored components in the worst case scenario. Calculation details are presented in Attachment D. 5. 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II I 1i25� 1 (6 1 Y _i Co jI �j II I� U_ E ®i Cii G) s� l C • C I 'U) a �I m 0 60 1 u) G� �i ec9 OilSa i � CIcry I 1C):UI® � > CO �1- ®1 11 ill 11Mj Q) > )I I(5iC �I00I>I lu Uri 0u �i -1v- U im: Oi c5 OI(Di w j up C o as � a V) �I'� � I.U) Q) V) O I Y I 0< Ni I a)I �I U.. _ I. � _ Ml U) o I C1 ��� Q 0, EIfs �� >> U)I I> M :I CLjc.LL-I_}= O 0j I O Cccg G Va 0 > iII > CZt KL t� Tau'� Ennissions, Reports Tank --M77, 7/18, 84, 87, & 86 TANKS 4.0.9d Emissions Report- Detail Forget 'Tani Indentification and Physical Characteristics Identification User Identification: Tank #84 City: Vernon State: California Company: Lubricating Specialties Company Type of Tank: Vertical Fixed Roof Tank Description: Propanol Storage 'rank 1 Tank Dimensions Shell Height (ft): 21.00 Diameter (ft): 8.00 Liquid Height (ft) : 21.00 Avg, Liquid Height (ft): 18.50 Volume (gallons): 7,896.28 Turnovers: 2.30 Net Throughput(gal/yr): 18,161.44 Is Tank Heated (y/n): N Paint Characteristics Shell Color/Shade: Gray/Light Shell Condition Good Roof Color/Shade: Gray/Light Roof Condition: Good Roof Characteristics Type: Dome Height (ft) 0.67 Radius (ft) (Dome Roofl 8.00 Breather Vent Settings Vacuum Settings (psig): 0.00 Pressure Settings (psig) 0.03 Meterological Data used in Emissions Calculations: Los Angeles C.O., California (Avg Atmospheric Pressure = 14.67 psia) file://C:\Prograin Files\Tan ]cs409d\sUrnir,— iydisplayJ.ltm 8/31/2009 TANKS 4.0.9d Emissions Report - Detail Format Liquid Contents of Storage Tank Tank #84 - Vertical Fixed goof Tank Vernon, California Liquid Daily Liquid Surf. Bulk Temperature (deg F) Temp Mixture/Component Month Avg. Min. Max. (deg F) Propanol All 73.91 64.69 83.13 68.21 Vapor Liquid Vapor Vapor Pressure (psia) Met. Mass Mass Mot. Avg. Min. Max. Weight. Fract. Fracl. Weight 0.3418 0.2427 0.4749 60.0000 60.00 fi1e://C:\PrograiT: Filcs\Tai-lcs409d\sur,.tmaiydisplay.htm 8/01/2009 `TANKS 4.0.9d Emissions Report - Detail Format; Detail Calculations (Ali-42) "tank #84 - Vertical Fixed Roof Tank Vernon, California Annual Emission Calcaulations Standing Losses(Ib): 14.7643 Vapor Space Volume (cu ft): 142.6601 Vapor Density (lb/cu ft): 0.0036 Vapor Space Expansion Factor: 0.0832 Vented Vapor Saturation Factor: 0.9511 Tank Vapor Space Volume: Vapor Space Volume (cu ft): 142.6601 Tank Diameter (ff): 8.0000 Vapor Space Outage (ft): 2.8381 Tank Shell Height (ft): 21.0000 Average Liquid Height (ft): 18.5000 Roof Outage (ft): 0.3381 Roof Outage (Dome Roof) Roof Outage (ft): 0.3381 Dome Radius (ft): 8.0000 Shell Radius (ft): 4.0000 Vapor Density Vapor Density (lb/cu ft): 0.0036 Vapor Molecular Weight (lb/lb-mole): 60.0000 Vapor Pressure at Daily Average Liquid Surface Temperature (psia): 0.3418 Daily Avg. Liquid Surface Temp. (deg. R): 533.5767 Daily Average Ambient Temp. (deg. F): 65.9667 Ideal Gas Constant R (psia tuft / (lb-mol-deg R)): 10.731 Liquid Bulk Temperature (deg. R): 527.8767 Tank Paint Solar Absorplance (Shell): 0.5400 Tank Paint Solar Absorptance (Roof): 0.5400 Daily Total Solar Insulation Factor (Btu/sgft day): 1,567.1816 Vapor Space Expansion Factor Vapor Space Expansion Factor: 0.0839 Daily Vapor Temperature Range (deg. R): 36.8838 Daily Vapor Pressure Range (psia): 0,2322 Breather Vent Press. Setting Rana.e(psia): 0.0300 Vapor Pressure at Daily Average Liquid Surface Temperature (psia): 0.3418 Vapor Pressure at Daily Minimum Liquid Surface Temperature (psia): 0.2427 Vapor Pressure at Daily Maximum Liquid -Surface Temperature (pse): 0.4749 Daily Avg. Liquid Surface Temp. (deg R): 533.5767 Daily Min. Liquid Surface Temp. (deg R): 524.3557 Daily Max. Liquid Surface Temp. (deg R): 542.7976 Daily Ambient Temp. Range (deg. R): 18.3167 Vented Vapor Saturation Factor Vented Vapor Saturation Factor: 0.9511 Vapor Pressure at Daily Average Liquid: Surface Temperature (psia): 0.3418 Vapor Space Outage (ft): - 2.8381 Working Lasses (lb):. 8.8681 Vapor Molecular Weight (Ib/Ib-mole): 60.0000 Vapor Pressure at Daily Average Liquid Surface Temperature (psia): 0.3418 Annual Net Throughput (gal/yr.): 18,161.4359 Annual Turnovers: 2.3000 Turnover Factor: 1.0000 Maximum Liquid Volume (gal): 7,896.2765 Maximum Liquid Height (ft): 21.0000 Tank Diameter (ft): 8,0000 Working Loss Product Factor: 1.0000 Total Losses (lb): - 23.6324 file;://C:\Program Elks\Tani; s409d\summaiydisplay.htm 8/ )1 / 009 TANKS 4.0.9a Emissions report o Detail Format Individual "rank Emission Totals Emissions report for Annual Tank #84 a Vertical Fixed Roof Tank Vernon, California Losses(lbs) Components �- '— Working Lossil Breathing Loss r Total Emissions 'ropanol —1� ---8.87]1 14.76 — 23.63 file://C:\Pro cram Files\Tanl.s09d\suiT)-marydispl ay.htin 8/3 1 /7009 TANKS 4.0.9d Emissions Report u Detail Format Tangy: Pndentification and Physical Characteristics Identification User Identification: Tank #77 City: Vernon State: California Company: Lubricating Specialties Company Type of Tank: Vertical Fixed Roof Tank Description: n-Butyl Acetate Storage Tank Tank Dimensions Shell Height (ft): 44.00 Diameter (ft): 14.00 Liquid Height (ft) : 44.00 Avg. Liquid Height (ft): 29.00 Volume (gallons): 50,667.77 Turnovers: 4.50 Net Throughput(gal/yr): 228,004.98 Is Tank Heated (y/n): N Paint Characteristics Shell Color/Shade: Gray/Light Shell Condition Good Roof Color/Shade: Gray/Light Roof Condition: Good Roof Characteristics Type: Dome Height (ft) 0.67 Radius (ft) (Dome Roof) 14.00 Breather Vent Settings Vacuum Settings (psig): 0.00 Pressure Settings (psig) 0.03 Meterological Data used in Emissions Calculations: Los Angeles C.O., California (Avg Atmospheric Pressure = 14.67 psia) -rile;://C:\Program TIles\T'ai-iks409d\summaiyd.isplay.htm 8/31/2009 TANKS 4.0.9d Emissions Report - Detail Format Liquid Contents of Storage Tank Tank 477 - Vortical Fixed Roof Tank Vernon, California Liquid Daily Liquid Sur(. Bulk Vapor Liquid Vapor Temperature (deg F) Temp Vapor Pressure (psia) Mol. Mass Mass Mol. Mixture/Component Month Avg. Min. Max. (deg F) Avg. Min. Max. Weight. Fract. Fract Weight n-Butyl Acetate All 73.91 64.69 83.13 68.21 0.1966 0.142E 02669 116.6000 116.60 file: //C:AProgram Files\Tan1.s409d\summarydisplay.h,Lm 8/31/2009 TANKS 4.0.9d Emissions report - detail Format Di6tail Calculations (AP-42) Tank #77 - Vertical Fixed Roof Tank Vernon, California Annual Emission Calcaulalions Standing Losses (lb): 224.9837 Vapor Space Volume (cu ft): 2,360.7973 Vapor Density (lb/cu ft): 0.0040 Vapor Space Expansion Factor: 0.0756 Vented Vapor Saturation Factor: 0.8622 Tank Vapor Space Volume: Vapor Space Volume (cu ft): 2,360.7973 Tank Diameter (ft): 14.0000 Vapor Space Outage (ft): 16.3360 Tank Shell Height (ft): 44,0000 Average Liquid Height (ft): 29.0000 Roof Outage (ft): 0.3360 Roof Outage (Dome Roof) Roof Outage (ft): 0.3360 Dome Radius (ft): 14.0000 Shell Radius (ft): 7.0000 Vapor Density Vapor Density (lb/cu it): 0.0040 Vapor Molecular Weight (lb/Ib-mole): 116.6000 Vapor Pressure at Daily Average Liquid Surface Temperature (psia): 0.1966 Daily Avg. Liquid Surface Temp. (deg. R): 533.5767 Daily Average Ambient Temp. (deg. F): 65.9667 Ideal Gas Constant R (psia tuft/ (lb-mol-deg R)): 10.731 Liquid Bulk Temperature (deg. R): 527.8767 Tank Paint Solar Absorptance (Shell): 0.5400 Tank Paint Solar Absorptance (Roof): 0.5400 Daily Total Solar Insulation Factor (Btu/sgfl day): 1,567.1816 Vapor Space Expansion Factor Vapor Space Expansion Factor: 0.0756 Daily Vapor Temperature Range (deg. R): 36.8838 Daily Vapor Pressure Range (psia): 0.1241 Breather Vent Press. Setting Range(psia): 0.0300 Vapor Pressure at Daily Average Liquid Surface Temperature (psia): 0.1966 Vapor Pressure at Daily Minimum Liquid Surface Temperature (psia):. 0.1428 Vapor Pressure at Daily Maximum Liquid Surface Temperature (psia): 0.2669 Daily Avg. Liquid Surface Temp. (deg R): 533.5767 Daily Min. Liquid Surface Temp. (deg R): 524.3557 Daily Max. Liquid Surface Temp. (deg R): 542.7976 Daily Ambient Temp. Range (deg. R): 18.3167 Vented Vapor Saturation Factor Vented Vapor Saturation Factor: 0.8622 Vapor Pressure at Daily Average Liquid: Surface Temperature (psia): 0.1966 Vapor Space Outage (ft): 15.3360 Working Losses (Ib): 124.4.690 Vapor Molecular Weight (lb/lb-mole): 116.6000 Vapor Pressure at Daily Average Liquid Surface Temperature (psia): 0.1966 Annual Net Throughput (gal/yr.): 228,004.9834 Annual Turnovers: 4.5000 Turnover Factor: 1.0000 Maximum Liquid Volume (gal): 50,667.7741 Maximum Liquid Height (ft): 44.0000 Tank Diameter (ft): 14.0000 Working Loss Product Factor: 1.0000 Total Losses (lb): 349,4526 file://C:\Progra,ni >piles\Taiiks4'09d\suillmarydisplay.kti-ii 8/21/2009 TANKS 4.9.9d Emissions Deport m detail Format Individual Tank Emission `totals Emissions Report for: ,annual Tank, 977 - Vertical Fixed Roof Tangy: Vernon, California Losses(lbs) Components IWorking Lossil Breathing Lossl Total Emissions In -Butyl Acetate 124.47 222: 98 1 349.45 f`ilo://C:\Program. Tilcs\T uiks409d\suinrliarycl.isplay.htzn 8/31/2009 TANKS 4.0.9d Emissions Report.. Detail Format Tank indentification and Physical Characteristics Identification User Identification: Tank 4-78 City: Vernon State: California Company: Lubricating Specialties Company Type of Tank: Vertical Fixed Roof Tank Description: Ethyl Acetate Storage Tank Tank Dimensions Shell Height (ft): 44.00 Diameter (ft): 14.00 Liquid Height (ft) : 44.00 Avg. Liquid Height (ft): 25.00 Volume (gallons): 50,667.77 Turnovers: 3.30 Net Throughput(gal/yr): 167,203.65 Is Tank Heated (y/n): N Paint Characteristics Shell Color/Shade: Gray/Light Shell Condition Good Roof Color/Shade: Gray/Light Roof Condition: Good Roof Characteristics Type: Dome Height (ft) 0.67 Radius (ft) (Dome Roof) 14.00 Breather Vent Settings Vacuum Settings (psig): 0.00 Pressure Settings (psig) 0.03 Meterological Data used in Emissions Calculations: Los Angeles C.C., California (Avg Atmospheric Pressure = 14.67 psia) file://C:\Program FIles\Taiilcs409d\sumiriarydisplay.htm 00/31/2009 TANKS 4.0.9d Emissions Report - Detail Format LigUid Contents of Storage Tank Tank #78 - Vertical Fixed Roof Tank Vernon, California Liquid Daily Liquid Surf. Bulk Vapor Liquid Vapor Temperature (deg F) Temp Vapor Pressure (psia) Mol. Mass Mass Mol. Mixture/Component Month Avg. Min. Max. (deg F) Avg. Mtn. Max. Weight. Fracl. Fracl, Weight Ethyl acetate All 73.91 64.69 83.13 68.21 1.6791 1.2973 2.1501 88.1000 88.10 file://C:\Program Fibs\Tani,s409d\summa,ydisplay.htiLz 8/1 1/20Q9 TANKS 4.0.9d Emissions Report ® Detail Format Detail Calculations (APm42) Tank #78 d Vertical Fired Roof Tanks Vernon, California Annual Emission Calcaulations Standing Losses (Ib): 1,366.3262 Vapor Space Volume (Go ft): 2,976.5495 Vapor Density (lb/cu ft): 0.0258 Vapor Space Expansion Factor: 0,1324 Vented Vapor Saturation Factor: 0.3675 Tank Vapor Space Volume: Vapor Space Volume (cu ft): 2,976.5495 Tank Diameter (ft): 14.0000 Vapor Space Outage (ft): 19.3360 Tank Shell Height (ft): 44.0000 Average Liquid Height (ft): - 25.0000 Roof Outage (ft): 0.3360 Roof Outage (Dome Roof) Roof Outage (ft): 0.3360 Dome Radius (ft): 14.0000 Shell Radius (ft): 7.0000 Vapor Density Vapor Density (lb/cu ft): 0.0258 Vapor Molecular Weight (lb/lb-mole): 88.1000 Vapor Pressure at Daily Average Liquid Surface Temperature (psia): 1.6791 Daily Avg. Liquid Surface Temp. (deg. R): 533.5767 Daily Average Ambient Temp. (deg. F): 65.9667 Ideal Gas Constant R (psia cuff / (lb-mol-deg R)): 10.731 Liquid Bulk Temperature (deg. R): 527.8767 Tank Paint Solar Absorpfance (Shell): 0.5400 Tank Paint Solar Absorptance (Roof): 0.5400 Daily Total Solar Insulation Factor (Btulsgft day): 1,567.1816 Vapor Space Expansion Factor Vapor Space Expansion Factor: 0.1324 Daily Vapor Temperature Range (deg. R): 36.8838 Daily Vapor Pressure Range (psia): 0.8528 Breather Vent Press. Setting Range(psia): 0.0300 Vapor Pressure at Daily Average Liquid Surface Temperature(psia): 1.6791 Vapor Pressure at Daily Minimum Liquid Surface Temperature (psia): 1.2973 Vapor Pressure at Daily Maximum Liquid Surface Temperature (psis): 2.1501 Daily Avg. Liquid Surface Temp. (deg R): 533.5767 Daily Min. Liquid Surface Temp. (deg R): 524.3557 Daily Max. Liquid Surface Temp. (deg R): 542.7976 Daily Ambient Temp. Range (deg. R): 18.3167 Vented Vapor Saturation Factor Vented Vapor Saturation Factor: 0.3675 Vapor Pressure at Daily Average Liquid: Surface Temperature (psia): 1.6791 Vapor Space Outage (ft): 19.3360 Working Losses (lb): 588.9104 Vapor Molecular Weight (lb/lb-mole): 88.1000 Vapor Pressure at Daily Average Liquid Surface Temperature (psia): 1.6791 Annual Net Throughput (gal/yr.): 167,203.6545 Annual Turnovers: 3.3000 Turnover Factor: 1.0000 Maximum Liquid Volume (gal): 50,667.7741 Maximum Liquid Height (ft): 44.0000 Tank Diameter (ft): 14.0000 Working Loss Product Factor: 1.0000 Total Losses (Ib): 1,955.2367 file://C:\Program Files\Tai-iks409d\sulnmaiydisplay.ht,ii 8/31/2009 TANKS 4.0.9d Emissions Deport - Detail Format Individual Tank Emission T'otais Emissions Report for: Annual Tank #78 - Vertical Fixed Goof Tank Vernon, California Losses(lbs) � I Components Working Loss—�� Breathing Loss r Total Emissions �— (Ethyl acetate ��— 588.91 1,366.33 1,955.24 ,flu://C:\Progra-n Files\'Tai�-,s409d\suriaiTiarydispplay.htm 8/31/.2009 TANKS 4.0.9d Emissions Report W Oaten Format Tank indentit'ication and Physical Characteristics Identification User Identification: Tank #87 City: Vernon State: California Company: Lubricating Specialties Company Type of Tank: Vertical Fixed Roof Tank Description: Propanol Storage Tank 2 Tank Dimensions Shell Height (ft): 21,00 Diameter (ft): 8.00 Liquid Height (ft) : 21.00 Avg. Liquid Height (ft): 18.50 Volume (gallons): 7,896.28 Turnovers: 2.30 Net Through put(gal/yr): 18,161.44 Is Tank Heated (y/n): N Paint Characteristics Shell Color/Shade: Gray/Light Shell Condition Good Roof Color/Shade: Gray/Light Roof Condition: Good Roof Characteristics Type: Dome Height (ft) 0.67 Radius (ft) (Dome Roof) 8.00 Breather Vent Settings Vacuum Settings (psig): 0,00 Pressure Settings (psig) 0.03 Meterological Data used in Emissions Calculations: Los Angeles C.O., California (Avg Atmospheric Pressure = 14.67 psia) 8/3:1/2009 TA N KS 4.0.9d Liquid Contents of Storage Tank 'Tank #87 - Vertical Fixed woof Tank Vernon, California Liquid Daily Liquid Surf. Bulk Vapor Liquid Vapor Temperature (deg F) Temp Vapor Pressure (psia) Mol. Mass Mass Mol. Mixture/Component Month Avg. Min. Max. (deg F) Avg. Min. Max. Weight. Fract. Fract. Weight Propanol All 73.91 64.69 83.13 68.21 0.3418 0.2427 0.4749 60.0000 60.00 file://t AP.-rograni Fiies\Ts iT�Lrs4O9d..\sui-rfimarydisplay.hi n 8/31/2009 TANKS 4.0.9d Emissions Report - Detail Format Detail Calculations (A -42) Tank #87 - Vertical Fixed Roof i ank Vernon, California Annual Emission Calcaulations Slanding Losses (lb): 14,7643 Vapor Space Volume (cu ft): 142.13601 Vapor Density (Ib/cu ft): 0.0036 Vapor Space Expansion Factor: 0.0832 Vented Vapor Saturation Factor: 0.9511 Tank Vapor Space Voiurne: Vapor Space Volume (cu ft): 142.6601 Tank Diameter (ft): 8.0000 Vapor Space Outage (ft): 2.8381 Tank Shell Height (ft): 21.0000 Average Liquid Height (ft): 18.5000 Roof Outage (ft): 0.3381 Roof Outage (Dome Roof) Roof Outage (ft): 0,3381 Dome Radius (ft): 8,0000 Shell Radius (ft): 4.0000 Vapor Density Vapor Density (Ib/cu ft): 0.0036 Vapor Molecular Weight (lb/lb-mole): 60,0000 Vapor Pressure at Daily Average Liquid Surface Temperature (psia): 0,3418 Daily Avg. Liquid Surface Temp. (deg. R): 533.5767 Daily Average Ambient Temp. (deg. F): 65.9667 Ideal Gas Constant R (psia cuP / (lb-mol-deg R)): 10.731 Liquid Bulk Temperature (deg. R): 527.8767 Tank Paint Solar Absorptance (Shell): 0.5400 Tank Paint Solar Absorptance (Roof): 0.5400 Daily Total Solar Insulation Factor (Btulsgft day): 1,567.1816 Vapor Space Expansion Factor Vapor Space Expansion Factor: 0.0832 Daily Vapor Temperature Range (deg. R): 36,8838 Daily Vapor Pressure Range (psia): 0.2322 Breather Vent Press. Setting Range(psia): 0.0300 Vapor Pressure at Daily Average Liquid Surface Temperature (psia): 0.3418 Vapor Pressure at Daily Minimum Liquid Surface Temperature (psia): 0.2427 Vapor Pressure at Daily Maximum Liquid Surface Temperature (psis): 0.4749 Daily Avg. Liquid Surface Temp. (deg R): 533.5767 Daily Min. Liquid Surface Temp. (deg R): 524.3557 Daily Max. Liquid Surface Temp. (deg R): 542.7976 Daily Ambient Temp. Range (deg. R): 18.3167 Vented Vapor Saturation Factor Vented Vapor Saturation Factor: 0.9511 Vapor Pressure at Daily Average Liquid: Suiface Temperature (psia): 0.3418 Vapor Space Outage (ft): 2.8381 Working Losses (lb): 8.8681 Vapor Molecular Weight (lb/lb-mole): 60.0000 Vapor Pressure at Daily Average Liquid Surface Temperature (psia): 0.3418 Annual Net Throughout (gal/yr.): 18,161.4359 Annual Turnovers: 2,3000 Turnover Factor: 1,0000 Maximum Liquid Volume (gal): 7,606.2765 Maximum Liquid Height (ft): 21.0000 Tank Diameter (ft): 8.0000 Working Loss Product Factor: 1.0000 Total Losses (lb): 23.6324 �11,il.* s\Tanks409,1\su.11znarydisplay.htm 8/31/2009 TANKS 4.0.9d. Emissions report - Detaii Format indirriduai Tank Emission Totals Emissions Report for: Annual Tank *87 - Vertical Fixed Roof Tank Vernon, California —s--- � � Losses(lbs) _ Components --��� Working Loss F --y— Breathing Lossil Total Emissions Propanol —" --��� 8.871 14.76 23.63 i1C://C:\P, o , -air:. ri1Ps\ 1'ariks�! 09ci\suer zal�:i >>clisal ay.liti .i U/ 31 /1009 TANKS 4.0.9d Emissions Report - Detail Format Tank Indentification and Physical Characteristics Identification User Identification: Tank #86 City: Vernon State: California Company: Lubricating Specialties Company Type of Tank: Vertical Fixed Roof Tank Description: Propyl Acetate Storage Tank Tank Dimensions Shell Height (ft): 44.00 Diameter (ft): 14.00 Liquid Height (ft) : 44.00 Avg. Liquid Height (ft): 29.00 Volume (gallons): 50,667.77 Turnovers: 4.20 Net Throughput(gal/yr): 212,804.65 Is Tank Heated (y/n): N Paint Characteristics Shell Color/Shade: Gray/Light Shell Condition Good Roof Color/Shade: Gray/Light Roof Condition: Good Roof Characteristics Type: Dome Height (ft) 0.67 Radius (ft) (Dome Roof) 14.00 Breather Vent Settings Vacuum Settings (psig): 0.00 Pressure Settings (psig) 0.03 Meterological Data used in Emissions Calculations: Los Angeles C.O., California (Avg Atmospheric Pressure = 14.67 psia) Tile://C:\Progratn Files\I'ant,:s409d\si.itnlnarydisi l ty.htm 00/31/2009 TANKS 4.0.9d Emissions Report - Detail Format Liquid Contents of Storage Teak Tank #86 - Vertical Fixed Roof Tank Vernon, California Liquid Daily Liquid Surf. Bulk Vapor Liquid Vapor Temperature (deg F) Temp Vapor Pressure (psia) Mol. Mass Mass Mal. Mixture/Component Month Avg. Min. Max. (deg F) Avg. Min. Max. Weight. Fract. Fracl. Weight N-Propyl Acetate - All 73.91 64.69 83.13 68.21 0.5792 0.4338. 0.7637 102.1300 102.13 file,://':\Protrarn Files\Tari1,s409d\s-ummanjdl,,,play.h-im 8/31/2009 Emissions Report,. Detail Format Detail CraiCUiatiOnS (AP-42) "'rank ##€36 - Vertical Faxed Roof Tank Vernon, California Annual Emission Calcaulalions Standing Losses (lb): 547.1495 Vapor Space Volume (cu ft): 2,360.7973 Vapor Density (lb/cu ft): 0.0103 Vapor Space Expansion Factor: 0.0904 Vented Vapor Saturation Factor: 0.6799 Tank Vapor Space Volume: Vapor Space Volume (cu it): 2,360.7973 Tank Diameter (ft): 14.0000 Vapor Space Outage (ft): 15.3360 Tank Shell Height (it): 44.0000 Average Liquid Height (ft): 29.0000 Roof Outage (ft): 0.3360 Roof Outage (Dome Roof) Roof Outage (ft): 0.3360 Dome Radius (ft): 14.0000 Shell Radius (ft): 7.0000 Vapor Density Vapor Density (lb/cu it): 0.0103 Vapor Molecular Weight (lb/lb-mole): 102.1300 Vapor Pressure at Daily Average Liquid Surface Temperature (psia): 0.5792 Daily Avg. Liquid Surface Temp. (deg. R): 533.5767 Daily Average Ambient Temp. (deg. F): 65.9667 Ideal Gas Constant R (psia tuft / (lb-mol-deg R)): 10.731 Liquid Bulk Temperature (deg. R): 527.8767 Tank Paint Solar Absorptance (Shell): 0.5400 Tank Paint Solar Absorptance (Roof): 0.5400 Daily Total Solar Insulation Factor (Btu/sqft day): 1,567.1816 Vapor Space Expansion Factor Vapor Space Expansion Factor,. 0,0904 Daily Vapor Terperature Range (deg. R): 36.8838 Daily Vapor Pressure Range (psia): 0.3299 Breather Vent Press. Setting Range(psia): 0.0300 Vapor Pressure at Daily Average Liquid Surface Temperature (psia): - 0.5792 Vapor Pressure at Daily Minimum Liquid Surface Temperature (psia): 0.4338 Vapor Pressure at Daily Maximum Liquid Surface Temperature (psia): 0.7637 Daily Avg. Liquid Surface Temp. (deg R): 533,5767 Daily Min. Liquid Surface Temp. (deg R): 524.3557 Daily Max. Liquid Surface Temp. (deg R): 542.7976 Daily Ambient Temp. Range (deg. R): 18.3167 Vented Vapor Saturation Factor Vented Vapor Saturation Factor: 0.6799 Vapor Pressure at Daily Average Liquid: Surface Temperature (psia): 0.5792 Vapor Space Outage (ft): 15.3360 Working Losses (Ib): 299.6942 Vapor Molecular Weight (lb/lb-mole): 102.1300 Vapor Pressure at Daily Average Liquid Surface Temperature (psia): 0.5792 Annual Net Throughput (gal/yr.): 212,804.6512 Annual Turnovers: 4.2000 Turnover Factor: 1.0000 Maximum Liquid Volume (gal): 50,667.7741 Maximum Liquid Height (ft): 44.0000 Tank Diameter (ft): 14.0000 Working Loss Product Factor: 1.0000 Total Losses (lb): 846.8437 ;_II f..II� . \T TO .i"8 it i ill 5` 1 1>;_S��OJCl\5L1I111i l i1',jC 15��� �ty.liL 1�. 8/3' 1 /20G) TANKS 4.0.9d Emissions Report- DetaH Format 1ndividua[ Tank Ernission IF ota[s Emissions Reporlt for: Annual Tani-, #86 - Vertical Fixed Roof Tank Vernon, California Components _ �F— Working Loss Breathing Loss Total Emissions N-Propyl Acetate _ � 299.69 547.15If--- — — ----� 846.84 fid Fi'ieS\,ric`lalk \SLIT �_7]7cLl"j/C�'SI:1�Jy.Ylt:t17 8/31/-2009 r bAricatine Specialties Company Spill Prevention Control and Countermeasure (SPCCI Plan SPILL PREVENTION, CONTROL, AND COUNTERMEASURES PLAN LUBRICATING SPECIALTIES COMPANY 3365 East Slauson. Avenue Vernon, California 90058 Prepared by: _ John Alexander Compliance Manager Prepared: March 16, 2009 Re-vised: 2/29/96, 7/14/99, 5/27/00, 4/01/03, 01/18/071 03/16/09 - 1 - Version 1.2, 03-16-2009 LuMicating Specialties Company Spill Prevention Control and Countermeasure (SPCCI Plan - 2 - Version 1.2, 03-16-2009 'l, . +d ' Lui3ricating Specialties Company Spill Prevention Control and Countermeasure (SPCC) Plan Contents Introduction Part 1: Plan Administration 1.1 Management Approval and Designation Person 1.2 Professional Engineer Certification 1.3 Location of SPCC Plan 1.4 Plan Review 1.5 Facilities, Procedures, Methods, or Equipment Not Yet Fully Operational Part 2: General Facility Information 2.1 Facility Description 2.2 Evaluation of Discharge Potential Part 3: Discharge Prevention — General SPCC Provisions 3.1 Compliance with. Applicable Requirements 3.2 Facility Layout Diagram 3.3 Spill Reporting 3.4 Potential Discharge Volumes and Direction of Flow 3.5 Containment and Diversionary Structures 3.6 Practicability of secondary Containment 3.7 Inspections, Tests, and Records 3.8 Personnel, Training, and Discharge Prevention Procedures 3.9 Security Part 5: Discharge Response 5.1 Response to Minor Discharge 5.2 Response to a Major Discharge 5.3 Waste Disposal 5.4 Discharge Notification 5.5 Cleanup Contractors and Equipment Supplies List of Tables Table 1-1: Plan review Log Table 1-2: SPCC Cross -Reference Table 2-1: Oil Containers Table 3-1: Potential Discharge Volumes and Direction of Flow Table 3-2: Inspection and Testing Program Appendices A.: Site plan and Facility Diagram B: Substantial Harm Determination C: Facility Inspection Checklist D: Record of Containment Outfall Drainage E: Record of Annual Discharge Prevention Briefings and Training F: Emergency Contacts G: Discharge Notification Form H: Discharge Response Equipment Inventory I: Agency Notification Standard Report PAGE 4 5 5 5 5 6 6 10 10 11 12 12 12 12 12 13 14 14 15 16 17 17 17 18 18 19 8 9 11 12 14 - 3 - Version 1.2, 03-16-2009 Lubricating Specialties Company Spill Prevention, Control, and Countenneasure (SPCCI Plan Introduction Purpose The purpose of this Spill Prevention, Control, and Countermeasures (SPCC) Plan is to describe measures implemented by LSC to prevent oil discharges from occurring, and to prepare LSC 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), and supercedes the 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 (Class III) storage information and testing records, as a tool to communicate practices on preventing and responding to discharge with employees, as a guide to facility inspections, and as a resource during emergency response. This update of the .Plan also includes flammable products (Class I and Class II) and is used as a reference for its storage and. handling practices. LSC 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 Appendix B of this Plan. This Plan provides guidance on key actions that LSC must perform to comply with the SPCC rule: ❑ Complete monthly and annual site inspections as outlined in the Inspection, Test, and Records section of this Plan (Section 3.7) using the inspection checklists included on Appendix C. ❑ 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 included in Appendix E. ❑ If either of the following occurs, submit the SPCC Plan to the EPA Region 9 Regional Administrator and the California Department of Environmental Protection, along with other information as detailed in Section 5.4 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 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 filed at the time of the review. Plan amendments, other than administrative changes discussed above, must be decertified by a Professional Engineer on the certification page in Section 1.2 of this Plan. Amend the SPCC Plan within 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 recertified by a Professional Engineer: ❑ 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 a contact information, such as phone numbers. Administrative changes must be documented in review the Plan review log of Section 1.4 of this Plan, but do not have to certified by a Professional Engineer. - 4 - Version 1.2, 03-16-2009 c• w Lubricating Specialties Company Spill Prevention Control and Countermeasure (SPCC) Plan Part 1: Plan Administration 1.1 Management Approval and Designated Person (40CFR 112.7) Lubricating Specialties Company (LSC) 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 LSC management. LSC 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): John Alexander Signature: Title: Compliance Manager Date: . 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 20 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. 1.3 Location of SPCC Plan (40 CFR 112.3(e)) In accordance with 40 CFR 112.3(e), a complete copy of this SPCC Plan is maintained at the facility in the office building. The front office is attended whenever the facility is operating, i.e. 7:00 AM to 5:00 PM, 5 days per week. - 5 - Version 1.2, 03-16-2009 91 1 Lubricating Specialties Company Spill Prevention, Control, and Countermeasure (SPCC) Plan 1.4 Plan Review (40 CFR 112.3 and 112.5) 1.4.1 Change in Facility Configuration In accordance with 40 CFR 112.5 (a), LSC 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 tanks; ➢ Reconstruction, replacement, or installation of piping systems; ➢ Construction or demolition that might alter secondary containment structures; or ➢ Changes of product or services, revisions to standard operations, 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. LSC must make the needed revisions to the SPCC Plan as soon as possible, but no later than 6 months after the change occurs. The Plan must be implemented as soon as possible following any technical amendment, but no later than 6 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), LSC reviews this SPCC Plan at least once every five years. Revisions to the Plan, if needed, are made within 6 months of the 5 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 last SPCC review occurred on February 15, 2007. The Plan is dated January 31, 2007. The next review is therefore scheduled to take place on or prior to February 15, 2012. 1.4.3 Record of Plan Reviews Scheduled reviews and Plan amendments are recorded in the Plan Review Log (Table 1-1). 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 February 15, 2012. 1..5 Facilities, Procedures, Methods, or Equipment Not Yet Fully Operational (40 CFR 112.7) Bulk storage tanks at this facility are on a 10 year inspection and rotation program. All tanks are current and have been inspected within the past 5 years. Section 3.7 of this Plan describes the inspection program. -6- Version 1.2, 03-16-2009 LulfricatinQ Specialties Company Spill Prevention Control and Countermeasure (SPCC) Plan 1.5.1 Cross -Reference with the 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 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, - 7 - Version 1.2, 03-16-2009 Lublicating Specialties Company Spill Prevention, Control, and Countermeasure (SPCC) Plan Table 1-1: Plan Review Log -�r'�r R L. - 8 - Version 1.2, 03-16-2009 Lubricating Specialties Company Spill Prevention Control and Countermeasure (SPCC) Plan Table 1-2: SPCC Cross -Reference Table 1-2: SPCC Cross Reference 12.3(d) Professional Engineer Certification 5 .. 112.3(e) Location of SPCC Plan 5 112.5 Plan Review 6 112.7 Management Approval g 112.7 Cross Reference with SPCC Rule 10 112.7(a)(3) Part 2: General Facility Information Appendix A: Site Plan and Facility Diagram Appendix A 112.7(a)(4) 5.4 Discharge Notification Appendix G Appendix I 112.7(a)(5) Part 5: Discharge Response 17 112.7(b) 3.4 Potential Discharge Volumes and Direction of Flow 12 112.(c 3.5 Containment and Diversionary Structures 13 112.7(d) 3.6 Practicability of Secondary Containment 14 112.7(e) 3.7 Inspections, Tests, and Records 14 Appendix B 112.7(f) 3.8 Personnel, Training and Discharge Prevention Procedures 15 112.7(g) 3.9 Security 16 Appendix B - Facility Inspection Checklist Appendix C 112.8(c)(8) 4.2.8 Overfill Prevention System 17 112.8(c)(10) 4.2.10 Visible Discharges 18 112.20(e) Certification of Substantial Harm Determination Appendix B * Only selected excerpts of relevant rule text are provided. For a complete list of SPCC requirements, refer to full text of 40 CFR part 112. - 9 - Version 1.2, 03-16-2009 Lulmicatine Specialties Company Spill Prevention. Control and Countermeasure (SPCC) Plan Part 2: General Facility Information Name: Lubricating Specialties Company Address: 3365 E. Slauson Ave Vernon, CA 90058 (562)776-4000 Type: Compounder and packaging facility Date of Initial Operations: 1968 Owner/Operator: Lubricating Specialties Company 8015 Paramount Blvd Pico Rivera, CA 90660 Primary Contact: John Alexander, Compliance Manager Work: (562) 776-4090 Cell: (213) 792-2265 2.1.1 Facility Description (40 CFR 112.7(a)(3)) 2.1.2 Location and Activities Lubricating Specialties company is a lubricating oil compounder and packager. The facility at 3365 E. Slauson Ave, Vernon, CA contains a manufacturing and warehouse building, two outside contained bulk storage tank farms, tank car and track loading and unloading areas, and drums storage of petroleum chemical and finished product. The present site is approximately four and a half acres with tank farms and buildings that occupy about two acres. Approximately 98% of the site has an impervious surface. The facility has been in operation since 1989. There has been one spill that has contributed significantly to storm runoff pollution. The site stores lubricating oils and petroleum chemicals. These items are the major pollution concern of the facility. The sites' vulnerability and sources for pollution potential are listed in the "Vulnerability Analysis and "Spill Sol;-: e, and Containment". The facility handles, stores, uses, and distributes petroleum products in the form of motor oil additives, automatic transmission oil, greases, and specialty products. LSC receives products by common carrier via tanker truck and rail cars. The products are stored in several aboveground storage tanks (ASTs). They are delivered to customers by common carrier and independent contractors. Hours of operations are between 5:00 AM and 4:00 PM 5 days per week. Personnel at the facility include plant manager, staff and 34 hourly employees. 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, buildings, loading/unloading and transfer areas, and critical spill control structures. - 10 - Version 1.2, 03-16-2009 y. Lubricating Specialties Company Spill Prevention Control and Countermeasure (SPCCI Plan 2.1.3 Oil Storage Oil storage at the facility consists of ASTs 87 tanks. In addition, the facility stores varying stock of oil drums inside the plant boundaries. The capacities of oil tanks present at the site are listed below and are also indicated on the facility diagram of Figure A-2, All containers with a capacity of 55 gallons or more are included. The capacity of the oil/water separator is not included in the total storage capacity for the facility since it is used to treat storm water and as a means of secondary containment for areas of the facility with potential for an oil discharge outside dikes or berms. Table 2-1: Oil Containers # of tanks size of tanks Contents Description 49 50,000 gallons oils raw materials and finished products 9 30,000 gallons oils raw materials and finished products 6 20,000 gallons oils blender for finished products 2 11,000 gallons additives raw materials 1 10,000 gallons oil raw materials and finished products 3 9,000 gallons additives raw materials 6 7,000 gallons oils finished products 2 5,000 gallons oils finished products Total Oil Storage: 2,951,000 gallons 2.2 Evaluation of Discharge Potential 2.2.1 Distance to Navigable Waters and Adjoining Shorelines and Flow Paths The facility is located on relatively level terrain. Drainage generally flows in the direction of South East to the general out fall area. This out -fall area asphalt and is a locked gate. Spill trajectories are indicated on the facility diagram. Storm drains are located along Slauson Ave. on the South side of the property. All rainfall that runs from the roofs and pad east of the ridge line will flow in that direction. No loading or off- loading takes place to the south of the ridge line protecting all storm drains. All of the facility's ground surface is paved with either asphalt or concrete. There is one small area in the center of the facility that separates parking from the facility that is ground. 2.2.2 Discharge history 'There is one recordable discharge that occurred in 2003 that involved Polyalphaoliphin to reach the sewer system. This spill required a response team clean up. - 11 - Version 1.2, 03-16-2009 Lubricating Specialties Company Spill Prevention, Control. and Countermeasure MCC) Plan 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 implementations of these measures. 3.1 Compliance with Applicable Requirements (40 CFR 112.7(a)(2)) This facility uses an oil/water separator as part of its drainage system to contain oil discharged in certain areas of the facility. The separator provides environmental protection equivalent to the requirements under 112.8(b)(3) to use ponds, lagoons, or catchments basins to retain oil at the facility.in the event of an uncontrolled discharge. As described in Section 3.5 of this Plan the operational and emergency oil storage capacity of the oil/water separator is sufficient to handle the quantity of oil expected to be discharged in undiked areas from tank overfills or transfer operations. All truck unloading, railcar unloading and drum storage is within bermed areas that control the flow of any material keeping it well clear of any possible opportunity to contaminate rain water. Corrosion poses minimal risk of failure since drums are single use and remain on site for a relatively short period of time (less than 1 year generally). The drum storage area is inspected monthly. This is in accordance with accepted industry practice for drum storage and provides an effective means of verifying container integrity, as noted by EPA in the preamble to the SPCC rule at 67 FR 47120. 3.2 Facility Layout Diagram (40CFR 112.7(a)(3)) Figure A-1 in Appendix A shows the general location of the facility on a U.S. Geological Survey topographic map. Figure A-2 in Appendix A presents a layout of the facility and the location of storage tanks and drums. The diagram also shows the location of 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 and transfer stations and connecting piping. 3.3 Spill Reporting (40 CFR 112.7(a) (4)) The discharge notification form included in Appendix G will be completed upon immediate detection of a discharge and proper 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. Table 3-1: potential Discharge Volumes and Direction of Flow Maximum volume Maximum released Discharge Potential Event (gallons) Rate Bulk storage Area (Aboveground Storage Tanks) Failure of aboveground Gradual to tank 50,000 instantaneous Tank overfill 1 to 600 150 gpm Pipe failure Leaking pipe or valve Loading/Unloading Area Truck leak or failure hose leak during loading 1 to 600 150 gpm 1 to 600 10 gpm Direction of Flow NW to Outfall Area NW to Outfall Area NW to Outfall Area Secondary Containment Cement Block Dike Cement Block Dike Cement Block Dike NW to Outfall Area Cement Block Dike Gradual to 1 to 7,000 instantaneous NW to Outfall Area Cement Block Dike 1 to 600 10 gpm NW to Outfall Area Cement Block Dike - 12 - Version 1.2, 03-16-2009 Lubricating Specialties Company Spill Prevention Control and Countermeasure (SPCC, Plan Drum Storage Area Gradual to ruptured drum 1 to 55 instantaneous NW to Outfall Area Blending Area Failure of aboveground Gradual to tank 5,000 instantaneous West to sump area Tank overfill 1 to 600 150 gpm West to sump area Pipe failure 1 to 600 150 gpm West to sump area Leaking pipe or valve 1 to 600 150 gpm West to sump area Container Filling Area Leaking Valve 1 to 600 150 gpm West to sump area Hose Rupture or Leak 1 to 600 150 gpm West to sump area Filled Container Leak 1 to 600 150 gpm West to sump area Equipment Overflow 1 to 600 150 gpm West to sump area 3.5 Containment and Diversionary Structures (40 CFR 112.7) Cement Block Dike rollover berm at door rollover berm at door rollover berm at door rollover berm at door rollover berm at door rollover berm at door rollover berm at door rollover berm at door Methods of secondary containment at this facility include a combination of structures (e.g., dikes, berms, built-in secondary containment), drainage systems (e.g., oil/water separator), and land -based spill response (e.g., drain covers, sorbent) to prevent oil from reaching navigable waters and adjoining shorelines: ➢ For bulk storage containers (refer to Section 4.2.2 of this Plan): Dike. A concrete wall enclosure is provided around fixed aboveground storage tanks in the tank farm. ➢ At the loading rack and unloading area (refer to Section 3.10 of this Plan): Rollover berm. The loading rack/unloading area is surrounded by a 4 inch rollover berm that provides sufficient containment for the largest tank truck loading or unloading at the facility (7,000 gallons), and an additional 2 inches of freeboard for precipitation. ➢ Sorbent material. Spill cleanup kits that include absorbent material, and other portable barriers are located inside the transfer areas. The spill kits are located within close proximity of the oil product storage and handling areas for rapid deployment should a spill occur. The response equipment inventory for the facility is listed in Appendix H of this Plan. The inventory is checked monthly to ensure that used material is replenished. ➢ Oil/Water separator. The oil/water separator is designed to separate oil at the facility. The separator has a total capacity of 800 gallons and a design flow rate of 150 gallons per minute. The separator outlet valve can be closed in the event of a large discharge (greater than 300 gallons) to provide additional emergency containment of up to 100,000 gallons. The maximum amount of oil potentially discharge outside of the diked or bermed areas is estimated at roughly 5,000 gallons. A spill of this volume outside the bermed area will be primarily contained by the out -fall system. Best Management Practices are used to minimize the amount of solids and oil that flow into the out -fall area. Facility personnel are instructed to avoid and address small spills using sorbent to minimize runoff of oil into the out -fall area. The oil/water separator is inspected twice annually as part of the - 13 - Version 1.2, 03-16-2009 Lubricating Specialties Company Spill Prevention Control and Countermeasure (SPCC) Plan scheduled inspection to check the level of water and measure the depth of bottom sludge and floating oils. Floating oil is removed by a licensed waste collector when it reaches a thickness of 4 inches. 3.6 Practicability of Secondary Containment (40 CFR 112.7 (d)) LSC management has determined that secondary containment is practicable at this facility. 3.7 Inspections, Tests, and Records (40 CFR 112.7 (e)) i aoie a-z: inspection ana i estmg grogram Facility Component Action Frequency/Circumstances Aboveground tank Test tank integrity. Combine Following a regular schedule and visual inspection with whenever material repairs are another testing technique. made. Inspect outside of tank for signs of deterioration and discharges. liquid level sensing Inspect tank supports and Following a regular schedule and devices foundations whenever material repairs are made. Diked areas inspect for signs of Monthly deterioration, discharges, or accumulation of oil inside diked areas. lowermost drain and all outlets of tank trucks Effluent treatment facilities All aboveground valves, piping and appurtenances 3.7.1 Daily Inspection Visually inspect content for presence of oil visually inspect Detect possible system upsets that could cause a discharge 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. Prior to draining Prior to filling and departure monthly Monthly A LSC employee performs a complete walk-through of the facility each day. This daily visual inspection involves: (1) looking for tank/piping damage or leakage, stained or discolored concrete, or excessive accumulation of water in diked and bermed areas; (2) observing the effluent from the oil/water separator; and (3) verifying that the oil/water separator valve is securely closed. This inspection will not be documented. - 14 - Version 1.2, 03-16-2009 Lubricating Specialties Comnanv Spill Prevention Control and Countermeasure (SPCCI Plan 3.7.2 Monthly Inspection The checklist provide in Appendix C issued for monthly inspections by LSC personnel. The monthly inspections cover the following key elements: o Observing the exterior of aboveground storage tanks, pipes, and other equipment for signs of deterioration, leaks, corrosion, and thinning. o Observing the exterior of portable containers for signs of deterioration or leaks. o Observing tank foundations and supports for sign of instability or excessive settlement. o 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. o Verify the proper functioning of overfill prevention systems. o Checking the inventory of discharge response equipment and restocking as needed. o Observing the effluent and measuring the quantity of accumulated oil within the oil/water separator. All problems regarding tanks, piping, containment, or response equipment must be immediately reported to the Plant 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 adjourning shorelines. Pooled oil is removed immediately upon discovery. Written monthly inspection records are signed by the Plant Manager and maintained with this SPCC Plan for a period of 3 years. 3.7.3 Annual Inspection Plant personnel perform a more thorough inspection of plant equipment on an annual basis. This annual inspection complements the monthly inspection described above and is performed in June of each year using the checklist provided in Appendix C of this Plan. The annual inspection is preferable performed after a large storm event in order to verify the imperviousness and/or proper functioning of drainage control systems such as the dike, rollover berm, central valves, and oil/water separator. Written annual inspection records are signed by the Plant Manager and maintained with this Plan for a period of 3 years 3.8 Personnel, Training, and Discharge Prevention Procedures (40 CFR 112.7 (f)) The Plant Manager is the facility designee and is responsible for oil discharge prevention, control, and response preparedness activities at this facility. LSC management has instructed oil handling 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 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 trainings are held by the Plant Manager or his designated representative for all facility personnel involved in oil operations. The trainings are aimed. at ensuring continued understanding and adherence to the discharge prevention procedures presented in the SPCC Plan. The training also highlights and describes known discharge events or failures, malfunctioning components, and recently implemented precautionary measures and best practices. Operators and other personnel will have the opportunity during the training to share recommendations concerning health, safety, and environmental issues encountered during plant operations. A simulation of an on -site discharge has been conducted, and future training exercises will be periodically held for possible discharge responses. Records of the training and discharge prevention training are kept on the form shown in Appendix E and maintained with this SPCC Plan for a period of 3 years. - 15 - Version 1.2, 03-16-2009 Lubricating Specialties Company Spill Prevention Control and Countermeasure (SPCCI Plan 3.9 Security (40 CFR 112.7 (g)) The facility is surrounded by 7-feet tall steel security fencing. The single entrance gate is locked when the facility is unattended. The gate and drive areas are under 24 hour surveillance cameras, and scanned by electronic beams that are monitored 24 hours a day by a security company. All drain valves for containment areas are locked in the closed position to prevent unauthorized opening. The area is lighted for loading and drum storage. The electrical starters for all pumps are located inside the manufacturing building. The building is locked and under motion detection surveillance systems when the plant is not operation. The plant securely caps or blank -flanges the loading/unloading connections of hoses and piping when not in service or when in standby service for any extended period of time. 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 of particular concern at this facility. LSC management is committed to ensuring the safe transfer of material to and from storage tanks. 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)) The loading and unloading areas are used by outside suppliers making deliveries to the facility and to load contract delivery trucks. The tank truck loading and unloading area is surrounded with a 4-inch rollover asphalt berm that provides secondary containment in the event of a discharge during transfer operations. The secondary containment berm is designed to address the more stringent rack containment requirements of 40 CFR 112.7 (h), which requires that the berm be sufficient to contain the capacity of the largest compartment, plus freeboard for precipitation. The curbed area provides a catchment capacity of 9,000 gallons, which is capable of containing the largest compartment of the petroleum supplier's truck making deliveries at the plant, and is also capable of containing the capacity of contract delivery trucks. The area is graded to direct the flow of oil or water away from the vehicle, and the low point of the curbed area is fitted with a gate valve that is normally kept closed and locked. The key for that lock is kept in the Compliance Manager's office. The berm is drained by LSC personnel after verifying that the retained water is free of oil. The accumulated water is released to the out -fall area. The drain is closed and locked following drainage. 3.10.2 Loading/Unloading Procedures (40 CFR 112.7 (h) (2) and (3)) All truckers must meet the minimum requirements and regulations for tank track loading and unloading establ shco 0 ; ai U.S. Department of Transportation. LSC ensures that the trucker 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. The Plant Manager or his/her designee supervises oil deliveries and pick-ups of all loads, and periodically observes these deliveries/pick-ups for existing, approved truckers. All loading and unloading of tank trucks takes place only in designated loading rack/unloading areas. Vehicle filling, operations are performed by plant personnel trained in proper discharge prevention procedures. The truck driver or plant personnel remain with the vehicle at all times. - 16 - Version 1.2, 03-16-2009 N Lui'lricatin2 Specialties Company Spill Prevention Control and Countermeasure(SPCQ Plan 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, or soil is prohibited by state and federal laws. Immediate action must be taken to control, contain, and recover discharged product. In general, the following steps are taken: ➢ Eliminate potential spark sources; ➢ Identify and shut down sources of the discharge to stop the flow; ➢ Contain the discharge with sorbents, berms, fences, trenches, sandbags, or other material; ➢ Contact the Plant Manager and the Compliance Manager; ➢ Contact regulatory authorities and the response organization; ➢ Collect and dispose of recovered products according to 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 I. The list is also posted at prominent locations throughout the plant. A list of discharge response material kept at the plant is included in Appendix H, 5.1 Response to a Minor Discharge A "minor" discharge is defined as one that poses no significant harm or threat to human health and safety to the environment. Minor discharges are generally those where: ➢ The quantity of product discharged is small (e.g, may involve less than 20 gallons of oil); ➢ Discharged material is easily stopped and controlled at the time of the discharge; ➢ Discharge is localized near the source; Discharge material is not likely to reach water; ➢ Discharge material is not likely to leave the property; ➢ There is little risk of fire or explosion. Minor discharges can usually be cleaned up by LSC personnel. The following guidelines apply: ➢ Immediately notify the Plant Manager and the Compliance Manager; ➢ Under of the direction of either, contain the discharge with discharge response materials and equipment. Place discharge debris in properly labeled waste containers. ➢ The Plant Manager will complete the discharge notification form (Appendix G) and attach a copy to this SPCC Plan. ➢ If the discharge involves more than 20 gallons of oil, the Plant Manager will call the California Department of Environmental Protection Incident Response Division. 5.2 Response to a Major Discharge A. "major" discharge is defined as one that cannot be safely controlled or cleaned up by plant personnel, such as when: ➢ The discharge is large enough to spread beyond the immediate discharge area; ➢ The discharge material enters water; ➢ The discharge requires special equipment or training to cleanup; ➢ The discharged material poses a hazard to human health or safety; ➢ The discharged material leaves the property; or ➢ There is a danger of fire or explosion. - In the event of a major discharge, the following guidelines apply: ➢ . Immediately notify the Plant Manager and the Compliance Manager; - 17 - Version 1.2, 03-16-2009 Lubricating Specialties Company Spill Prevention, Control, and Countermeasure (SPCC) Plan ➢ Under of the direction of either, contain the discharge with discharge response materials and equipment. Place discharge debris in properly labeled waste containers. ➢ If the Plant Manager or Compliance Manager is not present at the plant, the senior on -site person notifies the Plant Manager and Compliance Manager of the discharge and has authority to initiate notification and response. Certain notifications are dependent on the circumstances and types of discharge. ➢ The Plant Manager or Compliance Manager (or senior on -site person) must call for medical assistance if workers are injured. ➢ The Plant Manager or Compliance Manager (or senior on -site person) must notify the Fire Department and/or Police Department. ➢ The Plant Manager or Compliance Manager (or senior on -site person) must call the spill response and cleanup contractors listed in the Emergency Contacts list in Appendix F. ➢ The Plant Manager or Compliance Manager (or senior on -site person) must immediately contact the California Department of Environmental protection Incident Response Division, and the National Response Center. ➢ The Plant Manager or Compliance Manager (or senior on -site person) must record the calls on the Discharge Notification form in Appendix I and attach a copy to this SPCC Plan. 5.3 Waste Disposal Waste resulting from a minor discharge response will be containerized in impervious bags, drums, or pails. The compliance Manager will characterize the waste for proper disposal and ensure that it is removed from the facility by a licensed waste hauler within two weeks. Wastes resulting from a major discharge response will be removed and disposed of by a cleanup contractor. 5.4 Discharge Notification ➢ Any size discharge (i.e., one that creates a sheen, emulsion, or sludge) that affects or threatens to affect navigable waters or adjourning 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 Appendix I to facilitate reporting. The person reporting the discharge must provide the following information: o Name, location, organization, and telephone number o Name and address of the party responsible for the incident o Date and time of the incident o Location of the incident o Source and cause of the release or discharge o Types of material(s) released or discharged o Quantity of the materials released or discharged o Danger or threat posed by the release or discharge o Number and types of injuries o Media affected or threatened by the discharge (water, land, air) o Weather conditions at the time of the incident o 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 F 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 whenever the facility discharges more than 1,000 gallons of oil in a single event, or discharges more than 42 gallons of oil in each of 2 discharge incidents within a 12-month period. The following information must be submitted to the EPA Regional Administrator within 60 days: ➢ Name of the facility; ➢ Name of the owner/operator; ➢ Location of the facility; - 18 - Version 1.2, 03-16-2009 Le ricatine Specialties Company Snill Prevention Control and Countermeasure (SPCCI Plan ➢ Maximum storage or handling capacity and normal daily throughput; ➢ Corrective action and countermeasures taken, including a description of equipment repairs and replacement; ➢ Description of facility, including maps, flow diagram, and topographical maps; ➢ Cause of the discharge(s) to navigable waters and adjourning 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 is included in Appendix I of this Plan. 5.5 Cleanup Contractors and Equipment Supplies Contact information for specialized spill response and cleanup contractors are provided in Appendix F. These contractors have the necessary equipment to respond to a discharge of oil that affects navigable waters. Spill kits are located at the loading rack/unloading area and inside the maintenance building. The inventory of response supplies and equipment is provided in Appendix H of this Plan. The inventory is verified on a monthly basis. - 19 - Version 1.2, 03-16-2009 LuVricatingSpecialties Company Spill Prevention. Control and Countermeasure (SPCC) Plan Figure A-1: Site Plan Appendix A Site Plan and Facility Diagram - 20 - Version 1.2, 03-16-2009 Lubricating Specialties Company Spill Prevention, Control and Countermeasure (SPCC) Plan Figure A-2: Facility Diagram. - 21 - Version 1.2, 03-16-2009 LuBricating Specialties Company Spill Prevention Control and Countenneasure (SPCCI Plan Appendix B Substantial Harm Determination Facility Name: Lubricating Specialties Company (LSC) Facility Address: 3365 E. Slauson Ave. Vernon, CA 90058 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 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 such that a discharge from the facility could cause injury to fish and wildlife and sensitive environment? 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 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 past 5 years? Yes ❑ No Certification I certify under penalty of law that I have completely examined and am familiar with the information submitted in this document, and that based on my inquiry of these individuals responsible for obtaining this information, I believe that the submitted information is true, accurate, and complete. Signature John Alexander Compliance Manager Title Date - 22 - Version 1.2, 03-1`6-2009 LuliricatingSpecialties Company Spill Prevention, Control, and Countermeasure (SPCC) Plan Appendix C Facility Inspection Checklists The following checklist are to be used for monthly and annual facility conducted inspections. Completed checklist must be signed by the inspectors and maintained at the facility, with this SPCC Plan, for at least 3 years. - 23 - Version 1.2, 03-16-2009 LuWcatine Specialties Company Spill Prevention Control and Countermeasure (SPCC) Plan Monthly Inspection Checklist This inspection record must be completed each month except the month in which an annual inspection is performed. Provide further description and comments, if necessary, on a separated sheet of paper and attach to this sheet. *Any item that receives "yes" as an answer must be described and addressed immediately. Y* N Description & Comments Storage Tanks Tank surface show signs of leakage Tanks are damaged, rusted or deteriorated Bolts, rivets, or seams are damaged Tank supports are deteriorated or buckled Tank foundations have eroded or settled level gauges or alarms are inoperative Vents are obstructed Secondary containment is damage or stained Oil/water separator valve is open or unlocked Piping Valves seals, gaskets, or other appurtenances are leaking Pipelines or supports are damaged or deteriorated Joints, valves and other appurtenances are leaking Loading/unloading and transfer equipment Loading/unloading rack is damaged or deteriorated Connections are not capped or blank -flanged Secondary containment is damage or stained Berm drainage valve is open or not locked Oil/Vllater separator Oil/water separator > 2 inches of accumulated oil Outfall separator effluent has an oil sheen Security Fencing, gates, or lighting is non-functional Response Equipment Response Equipment inventory is complete Date: Signature: - 24 - Version 1.2, 03-16-2009 LdbricatingSpecialties Company Spill Prevention Control and Countermeasure (SPCCI Plan Annual Facility Inspection Cheddist This inspection record must be completed each year. If any response requires further elaboration, provide comments in Description & Comments space provided. Further description and comments, if necessary, must be provided on a separate sheet of paper and attached to the sheet. *Any item that receives "yes" as an answer must be described and addressed immediately. 1 Monthly Inspection Form Completed 2 Are rainfall records maintained and complete? 3 Is the site map valid? Are records kept showing oil/water separator 4 inspections performed in accordance with procedures? 5 Do laboratory personnel properly complete their portion of the inspection report? 6 Are oil/water separator discharge samples taken appropriately? 7 Are discharges being monitored? 8 Are discharges records being completed? 9 Are storm water samples being tested according to the permit requirements? 10 Are deficiencies noted in the monthly inspections being addressed? 11 Are records of discharges, spills, inspections, and audits being maintained? 12 Are discharge pollutant levels in compliance to permit requirements? 13 Have there been any spills to threaten the ground water? 14 Has a structural changes been made to either improve or worsen storm water pollution? 15 Has the drainage system changed? 16 Are pollution control structures being properly maintained? Is the housekeeping in the outside storage 17 area being properly maintained to prevent storm water pollution and in accordance with BMPs? 18 Are the oil/water separators being properly maintained? Do key employees understand the purpose 19 and concepts of the SPCC Plan? Are key employees adequately trained in the SPCC Plan? 20 Are training records being maintained? Y* N Description & Comments - 25 - Version 1.2, 03-16-2009 Lubdcatinjz Specialties Company Spill Prevention, Control, and Countenneasure (SPCA Plan ' Annual reminders: ➢ Hold SPCC training for all oil handling personnel; ➢ Check contact information for key employees and response/cleanup contractors and update them in the Plan as needed. Additional Remarks: Date: Signature: Plant Manager Signature: Compliance Manager - 26 - Version 1.2, 03-16-2009 J Lubricating Specialties Company Spill Prevention Control and Countermeasure (SPCCI Plan s• Appendix D Record of Containment Outfall Drainage This record must be completed when rainwater from diked areas is drained into the outfall area. Date I Presence of Oil Time Name Signature - 27 - Version 1.2, 03-16-2009 Lubricating Specialties Company Snill Prevention. Control and Countermeasure (SPCC) Plan Appendix E Record of Annual Discharge Prevention Briefings and Training Briefings will be scheduled and conducted by the Plant Manager or Compliance Manager for operating personnel at regular intervals to ensure adequate understanding of this SPCC Plan. The training 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. Plant operators and other personnel will have an opportunity during the training to share recommendations concerning health, safety, and environmental issues encountered during plant operations. Date Subject Covered Time Name Signature i - 28 - Version 1.2, 03-16-2009 bncatine Specialties Company Spill Prevention Control and Countermeasure (SPCC1 Plan VV Appendix F Emergency Contacts Response Team Ruben Montiel First Responder Operational Tony Pac First Responder Operational Marvin Zabalas First Responder Operational Manuel Waldren Site Incident Commander Steve Ross Hazardous Material Technician Greg Isom Hazardous Material Technician Ruben Flores Hazardous Material Technician Vernon Fire Department 323-583-6331 Vernon Police Department 323-587-8135 Paramedics, Police, Fire 6911 Ambulance 323-722-8481 Immediate. Medical Center 323-726-3212 Chemtrec 800-424-9300 U.S. Coast Guard 310-732-7380 Office. of Emergency Services EPA Regional Office 415-974-8071 75 Hawthorne San Francisco. CA 94105 John Alexander Compliance Manager Steve Miller VP Manufacturing Clean Up Companies: Ancon Marine 310-522-5110 ACTI 310-763-1423 Crosby & Overton 562-432-5445 562-926-7155 323-562-2746 323-225-0111 909-627-7742 626-919-6366 626-826-5781 213-792-2265 562-945-6637 - 29 - Version 1.2, 03-16-2009 ' Lubricating Specialties Company Spill Prevention, Control, and Countenneasure (SPCC) Plan APPENDIX G Discharge Notification Form Part A: Discharge Information General information when reporting a spill to outside authorities: Name: Lubricating Specialties Company Address: 3365 East Slauson Ave Vernon, CA 90058 Telephone: 562-776-4000 Owner/Operator: LSC Holdings Primary Contact: Daniel Doan, Plant Manager Work: 562-776-4140 Home: 323-225-0111 Type of oil: Dischar e Date and Time: Quantity Released: Discovery Date and Time: Quantity Released to a water body: Discharge Duration: Location source: Actions taken to stop, remove, and mitigate impacts of the discharge: Affected media air storm water sewer water oil/water separator soil other: Notification person: Telephone contact: Business: 24 hour: Nature of discharges, environmental/health, and damages: Injuries, fatalities or evacuation required? Part B: Notification Checklist Date and time I Name of person receiving call ivianuei vvaiaren, runt manager (562)776-4140 / (213)216-2741 / (323)225-0111 Local Fire Department: - 30 - Version 1.2, 03-16-2009 f Lubricating Specialties Company Spill Prevention Control and Countermeasure (SPCCI Plan EPA: clean up company: - 31 - Version 1.2, 03-16-2009 Lubricating Specialties Company Spill Prevention, Control, and Countermeasure (SPCC) Plan APPENDIX H Discharge Response Equipment Inventory The discharge response equipment inventory is, verified during the monthly inspection and must be replenished. as needed. Tank Truck Loading/Unloading Area o Empty 55 gallon drums to hold contaminated material o Loose absorbent material o Absorbent pads o Nitrile gloves o Neoprene gloves o Vinyl/PVC pull -on overboots o Shovels o Brooms 4 4 bags 3 boxes 6 pairs 6 pairs 3 pairs 2 2 - 32 - Version 1.2, 03-16-2009 R'J f jo Lubricating Specialties Company Spill Prevention Control and Countermeasure (SPCCI Plan APPENDIX I Agency Notification .Standard Report Facility: Lubricating Specialties Company Owner: LSC Holdings 8015 Paramount Blvd Pico Rivera, CA 90660 Name of person filing the report: Location: 3365 E. Slauson Ave Vernon, CA 90058 Maximum storage capacity: 960,000 gallons Daily throughput: 125,000 gallons Nature of qualifying incident: ❑Check Box i Discharge to navigable waters exceeding 1,000 gallons Check Box 2 Second discharge exceeding 42 gallons within a 12 month Period Description of facility (attach maps, flow diagrams, and topographical maps) Lubricating Specialties company is a lubricating oil compounder and packager. The facility at 8015 Paramount Blvd., Pico Rivera, CA contains a office building, a manufacturing and warehouse building, an outside contained bulk, storage tank farm, tank car and truck loading and unloading areas, and drum storage of petroleum chemical and finished products. The site is six acres with buildings than occupy about 2 of the 6 acres. Approximately 98% of the site has impervious surface. The facility has bee in operation since 1981. There have been no spills or runoff that has contributed significantly to storm runoff or spill pollution. The site stores lubricating oils and petroleum chemicals on site. These items are the major pollution concern for the facility. - 33 - Version 1.2, 03-16-2009 S 1 ` 'Lubricating Specialties Company Spill Prevention Control and Countermeasure (SPCA Plan Agency notification Standard Report (cont'd) Cause of the discharge including a failure analysis of the system and subsystems in which the failure occurred: Corrective actions and countermeasures taken, including a description of equipment repairs and replacements: Additional preventive measures taken or contemplated to minimize the possibility of recurrence: Other pertinent information: - 34 - Version 1.2, 03-16-2009 y2. GRECO FIRE PROTECTION Special Hazards Specialists May 11, 2009 City of Vernon Department of Community Services & Water 4305 Santa Fe Avenue Vernon, CA 90058 Attn: Bill Wilson Code Inspector Subject: Lubricating Specialties Company 3365 Slauson Avenue Vernon, CA 90058 Gentlemen: Please find the following findings, 2007 California Fire Code Chapter 34 paragraph by paragraph comments, fire flow calculations and summaries, LSC Hazardous Material Report, proposed fire protection, and fire and water drainage drawing for your consideration as concerns the LSC additions/expansion to the facility: The plant is located at the above referenced address. The plant entrance is off of Slauson Avenue, which has commercial activities, but the LSC facility is actually in an industrial area that is to the north of Slauson Avenue that is consistent with the industrial theme in the City of Vernon. The driveway into the facility is 20'-2" to 20'-51/2" in width. At this entry is where a 10" underground fire water main enters the facility, it is controlled by a PIV, and there is a 6" FDC header with 4-21/2" hose connections. The main building/warehouse is protected by automatic sprinkler systems which come off the facility's 10" looped underground fire water main. The facility contains blending and storage of hydraulic oils, motor oils, and grease. The chemicals are Class IB, II, & IIIB (See attached LSC Hazardous Material Report). CALIFORNIA FIRE CODE CHAPTER 34 3403.1 This is in place. 3403.1.1 " " " 3403.1.2 NA 1346 Oakheath Drive, Harbor City, CA 90710-1248, Phone/Fax: (310) 539-4019 Page 2 3403.1.3 Areas are not explosion proof, however, they will be made so if this project is approved. 3403.2 See fire protection as applicable. 3403.2.1 Fire extinguishers and hose lines are provided. 3403.3 The site contains diked areas, a berm, and sloped areas. The diked areas are in the tank farms, and the rail car parking area. The berm (2" high) is located at the truck loading area (adjacent to and south of the B tank farm) and at the west end of the B tank farm, where rail car and truck loading occurs. The asphalt paved surface slopes to the dike wall and rail line area. There is no sloping that would cause any drainage or spill to proceed out of the property toward the railroad right of way/rail lines/links outside the NW gate. This area can drain around the SW corner of the B tank farm dike wall to the east, and possibly flow down the rail line into the rail car parking area to the south. The rail car parking area has the facility's sump which is sized to contain a spill from plant. The truck loading area south of the B tank farm has a small drain that is inadequate, it is not at a low point, and flow continues east to the building loading dock where a main drain is located. This area is where trucks load and it is under a sprinklered roof/canopy that is attached to the building. (Flows can not be allowed to proceed to this drain and toward the building) At the east end of the truck loading area, a grated trench drain needs to be installed from the tank farm dike wall, across the truck loading area, to the 2" high berm. This will prevent a spill from the south side of the B tank farm dike wall from reaching the building. Also in this area is a fire hydrant that needs a berm installed around it to preclude a spill or pool from engulfing it. An additional grated trench drain needs to be installed from the SW corner of the B tank farm out to the 2" high berm. This will prevent a spill from the west side of the B tank farm from migrating into and involving the south side area of the B tank farm. The B tank farm itself has a 4' high dike wall inside and around it in the areas that communicate to the facility. There are actually 2 dike areas in the. B tank farm, but the common dike wall inside has openings in it that allow flow from the west portion to travel through the openings, through the east portion, to the tank farm's only drain. The openings in the wall need to be cemented closed. This will stop any involvement of the east tank farm area from a problem in the west tank farm area. A new drain needs to be installed in the west tank farm area. All areas inside the tank farm should be for temporary occupancy only. All meter/blend/control stations should be located outside of the dike areas, including all desks, clothes storage lockers, mix stations, etc. Page 3 All blockages to drains and impediments to drainage are to be removed. All electrical inside diked and berm areas is to be explosion proof. Fire protection is be added as part of the expansion project. Another point of access into the facility needs to be provided, and this is underway via the electrical transmission lines right of way on the west side of the facility. 3403.4 Containment is via dike walls and berm, with secondary containment located at the rail car parking area. 3403.5 Labeling and signage are in place. 3403.5.1 This is in place. 3403.5.2 Additional piping needs to be identified, but major lines are identified at this time. 3403.5.3 This is in place. 3403.5.4 " " " 3403.6 " " 3403.6.1 NA 3403.6.2 This is in place. 3403.6.2.1 " 3403.6.3 " 3403.6.3.1 " " .. 3403.6.4 Additional protection will be installed as necessary, especially at new fire protection subject to damage. 3403.6.5 This is in place. 3403.6.6 " " " 3403.6.6.1 " . If a foam water connected system will be utilized, then a reduced pressure backflow preventer will be installed to protect for cross contamination of the public water supply. (At this time, above ground foam totes will be used if foam water is to be utilized.) 3403.6.6.2 This is in place. 3403.6.7. 69 3403.6.8 46" 3403.6.9 " 3403.6.9.1 NA 3403.6.10 This is in place. 3403.6.11 46" 3404.1 44" 3404.2 " " " 3404.2.1 If change occurs, this will be followed. 3404.2.2 NA 3403.2.3 Labeling and signage are in place. 3404.2.3.1 This is in place. 3404.2.3.2 " " " 3404.2.4 " " " 3404.2.5 66 44 64 Page 4 3404.2.6 Incompatable materials are separated. 3404.2.7 This is in place. 3404.2.7.1 " " " 3404.2.7.2 " " " 3404.2.7.3 46 66" 3404.2.7.3.1 " " " 3404.2.7.3.2 " " " 3404.2.7.3.3 " " " 3404.2.7.3.4 " " " 3404.2.7.3.5 " 3404.2.7.3.5.1 " 3404.2.7.3.5.2 NA 3404.2.7.3.5.3 This is in place. 3404.2.7.3.6 " " " 3404.2.7.4 46 46" 3404.2.7.5. " " " 3404.2.7.5.1 44" 3404.2.7.5.2 " 3404.2.7.5.3 3404.2.7.5.4 " 3404.2.7.5.5 NA. Tanks are bottom loaded. 3404.2.7.5.5.1 This is in place. 3404.2.7.5.5.2 NA 3404.2.7.5.6 This is in place. 3404.2.7.5.7 " 3404.2.7.5.8 " 3404.2.7.6 If this occurs, this will be followed. 3404.2.7.7 This is in place. 3404.2.7.8 NA 3404.2.7.9 NA 3404.2.7.10 This is in place. 3404.2.7.10.1 " " " 3404.2.7.11 NA 3404.2.8 This is in place. 3404.2.8.1 " " " 3404.2.8.2 NA 3404.2.8.3 NA 3404.2.8.4 NA 3404.2.8.5 NA 3404.2.8.6 NA 3404.2.8.7 NA 3404.2.8.8 NA Page 5 3404.2.8.9 NA 3404.2.8.10 NA 3404.2.8.11 NA 3404.2.8.12 NA 3404.2.8.13 NA 3404.2.8.14 NA 3404.2.8.15 NA 3404.2.8.16 NA 3404.2.8.17 NA 3404.2.8.18 NA 3404.2.9 This is in place. 3404.2.9.1 Fire protection will be installed — See below. 3404.2.9.1.1 3404.2.9.1.2 ` 3404.2.9.1.2.1 AFFF (Foam) will be stored on the premises in totes. 3404.2.9.1.3 NA 3404.2.9.1.4 NA 3404.2.9.2 This is in place. 3404.2.9.3 " " " 3404.2.9.4 NA 3404.2.9.5 This is in place. 3404.2.9.5.1 NA 3404.2.9.5.1.1 NA 3404.2.9.5.1.2 NA 3404.2.9.5.1.3 NA 3404.2.9.5.1.4 NA 3404.2.9.5.1.5 This is in place — Not less than 3'. 3404.2.9.5.1.6 NA 3404.2.9.5.2 This is in place — not less than 3' — Fixed fire protection will allow for application into the rows of vertical tanks. 3404.2.9.5.3 NA 3404.2.9.6 This is in place. 3404.2.9.6.1 " " " 3404.2.9.6.2 44 " " 3404.2.9.6.3 44 66 66(There are no flame arrestors) 3404.2.9.6.4 This is partially in place. See 3404.3 for additional drainage that will be installed. 3404.2.9.6.5 This is in place. 3404.2.9.6.6 " 3404.2.9.6.6.1 Information is in the office. 3404.2.9.6.6.2 " 3404.2.9.6.7 " 3404.2.9.6.8 " Page 6 3404.2.9.6.9 This is in place. 3404.2.9.6.10 " 3404.2.10 See 3403.3 Dikes and berm are in place. The 2 openings in the common dike wall in the B tank farm will be closed and a new drain will be installed in the west farm area. 3404.2.10.1 This is in place. 3404.2.10.2 See 3404.2.10 & 3403.3. 3404.2.10.3 NA 3404.2.10.4 NA 3404.2.10.5 This is in place. No fire protection equipment will be located inside the dike areas. 3404.2.11 NA 3404.2.11.1 NA 3404.2.11.2 NA 3404.2.11.3 NA 3404.2.11.4 NA 3404.2.11.5 NA 3404.2.11.5.1 NA 3404.2.11.5.2 NA 3404.2.12 NA 3404.2.12.1 NA 3404.2.12.2 NA 3404.2.13 This will be in place when applicable. 3404.2.13.1 NA 3404.2.13.1.1 NA 3404.2.13.1.2 NA 3404.2.13.1.3 NA 3404.2.13.1.4 NA 3404.2.13.1.5 NA 3404.2.13.2 This will be in place when applicable. 3404.2.13.2.1 44 44 44There is no in place fire protection of this type in the facility. 3404.2.13.2.2 This will be in place when applicable. There is no in place fire protection of this type in the facility. 3404.2.13.2.3 This will be in place when applicable. 3404.2.14 64 66 6C 66" 3404.2.14.1 46 46 66 3404.2.14.2 This is in place. 3404.3 C6" 3404.3.1 " 3404.3.1.1 " 3404.3.2 " 3404.3.2.1 " Page 7 3404.3.2.1.1 This is in place. 3404.3.2.1.2 " 3404.3.2.1.3 " 3404.3.2.1.4 " 3404.3.2.2 " 3404.3.3 " 3404.3.3.1 " 3404.3.3.2 This situation does not exist in this facility. 3404.3.3.3 All means of egress are clear. 3404.3.3.4 This is in place. 3404.3.3.5.1 NA 3404.3.3.5.2 This is in place. 3404.3.3.5.3 " " " 3404.3.3.6 " " " 3404.3.3.7 NA 3404.3.3.8 NA 3404.3.3.9 This is in place. 3404.3.3.10 " " " 3404.3.4 NA 3404.3.4.1 NA 3404.3.4.2 NA 3404.3.4.3 This is in place. 3404.3.4.4 " " " 3404.3.5 This is in place. 3404.3.5.1 NA 3404.3.5.2 This is in place. 3404.3.5.3 " " " 3404.3.5.4 66" 3404.3.6 NA 3404.3.6.1 NA 3404.3.6.2 NA 3404.3.6.3 NA 3404.3.6.4 NA 3404.3.7 NA 3404.3.7.1 NA 3404.3.7.2 NA 3404.3.7.2.1 NA 3404.3.7.2.2 NA 3404.3.7.2.3 NA 3404.3.7.3 NA 3404.3.7.4 NA 3404.3.7.5 NA ' 3404.3.7.5.1 NA Page 8 3404.3.8 NA 3404.3.8.1 NA 3404.3.8.1.1 NA 3404.3.8.1.2 NA 3404.3.8.2 NA 3404.3.8.3 NA 3404.3.8.4 NA 3404.3.8.5 NA 3404.4 NA 3404.4.1 NA 3404.4.2 NA 3404.4.2.1 NA 3404.4.2.2 NA 3404.4.2.3 NA 3404.4.3 This is in place. See 3403.4 3404.4.4 " " " 3404.4.5 " " " 3404.4.6 " " " 3404.4.7 NA 3404.4.8 This is in place. 3405.5.1 " " " 3405.2 " " " 3405.2.1 " " " 3405.2.2 NA 3405.2.3 This is in place. 3405.2.4 NA 3405.2.5 NA 3405.2.6 NA 3405.3 NA 3405.3.1 NA 3405.3.2 NA 3405.3.3 NA 3405.3.4 NA 3405.3.5 NA 3405.3.5.1 NA 3405.3.5.2 NA 3405.3.5.3 This is in place. 3405.3.6 NA 3405.3.6.1 NA 3405.3.6.2 NA 3404.3.6.2.1 NA 3405.3.6.2.2 NA 3405.3.6.2.3 NA Page 9 3405.3.6.2.4 NA 3405.3.6.2.5 NA 3405.3.6.2.6 NA 3405.3.6.2.7 NA 3405.3.7 NA 3405.3.7.1 NA 3405.3.7.2 NA 3405.3.7.3 This is in place. 3405.3.7.4 " " " 3405.3.7.5 " " " 3405.3.7.5.1 " " " 3405.3.7.5.2 NA 3405.3.7.5.3 This is in place. 3405.3.7.6 " " " 3405.3.7.6.1 " " " 3405.3.7.6.2 NA 3405.3.7.6.3 This is in place. 3405.3.8 " " " 3405.3.8.1 " " " 3405.3.8.2 " 3405.3.8.3 NA 3405.3.8.4 NA 3405.4 NA 3405.4.1 NA 3405.4.2 NA 3405.4.3 NA 3405.4.4 NA 3405.4.5 NA 3405.4.6 NA 3405.4.7 NA 3405.4.8 NA 3405.4.9 NA 3405.5 NA 3405.5.1 NA 3406.1 This is in place. 3406.2 NA 3406.2.1 NA 3406.2.2 NA 3406.2.3 NA 3406.2.4 NA 3406.2.4.1 NA 3406.2.4.2 NA 3406.2.4.3 NA Page 10 3406.2.4.4 NA 3406.2.4.5 NA 3406.2.5.1 NA 3406.2.5.1.1 NA 3406.2.5.2 NA 3406.2.6 NA 3406.2.7 NA 3406.2.8 NA 3406.2.8.1 NA 3406.3 NA 3406.3.1 NA 3406.3.1.1 NA 3406.3.1.2 NA 3406.3.1.3 NA 3406.3.1.3.1 NA 3406.3.1.3.2 NA 3406.3.2 NA 3406.3.2.1 NA 3406.3.2.2 NA 3406.3.3 NA 3406.3.3.1 NA 3406.3.3.2 NA 3406.3.3.3 NA 3406.3.4 NA 3406.3.5 NA 3406.3.6 NA 3406.3.7 NA 3406.3.8 NA 3406.4 This is in place. 3406.4.1 " " " 3406.4.2 " " " 3406.4.3 NA 3406.4.4 NA 3406.4.4.1 NA 3406.4.4.2 NA 3406.4.5 This is in place. 3406.4.6 " " " 3406.4.7 NA 3406.4.7.1 NA 3406.4.7.2 NA 3406.4.7.3 NA 3406.4.7.4 NA 3406.4.7.5 NA 3406.4.7.6 NA Page 11 3406.4.7.7 NA 3406.4.7.8 NA 3406.4.8 This is in place. 3406.4.9 " 3406.4.10 " 3406.4.10.1 " 3406.4.10.2 " 3406.4.10.3 NA 3406.4.10.4 NA 3406.5 This is in place except as indicated in 3406.5.1.1. 3406.5.1 " " " " " 3406.5.1.1 The distances from Class IB, II, and I1I13 liquids is not being met. There are alternative measures that need to be considered due to this existing deficiency, and they need to be accepted or rejected by the City of Vernon as an alternative. 1) Build/continue the west dike wall up to at least the height of a tank car with a minimum 2 hour rating, and/or up to a height to match the existing wall located on the north side of the B tank farm. 2) Install a water curtain along the existing west dike wall with sprinkler heads spaced 6' on center with a discharge of 3 gpm per lineal foot, in lieu of the wall extension. 3) Accept the use of the discharge from monitors, located at the SW corner and the NW corner of the west dike wall, in lieu of the wall extension or water curtain. 3406.5.1.2 NA 3406.5.1.3 This is in place, and most of the facility is located outside. 3406.5.1.4 " " " 3406.5.1.5 66 cc" . See 3403.4 & 3403.3 for future that will be installed. 3406.5.1.6 See fire protection as applicable. 3406.5.1.7 This is in place. 3406.5.1.8 NA 3406.5.1.9 NA 3406.5.1.10 This is in place. 3406.5.1.10.1 " 3406.5.1.10.2 " 3406.5.1.10.3 " 3406.5.1.10.4 " 3406.5.1.11 " 3406.5.1.12 " 3406.5.1.13 " 3406.5.1.14 NA 3406.5.1.15 This is in place. Page 12 3406.5.1.16 This is in place. 3406.5.1.16.1 " 3406.5.1.16.2 " 3406.5.1.16.3 " 3406.5.1.17 , via an attendant. 3406.5.1.18 The entire facility is fenced in. 3406.5.2 " 3406.5.2.1 " 3406.53 " 3406.5.3.1 " 3406.5.3.1.1 " 3406.5.3.1.2 " 3406.5.3.1.3 NA 3406.5.3.2 This is in place. 3406.5.3.3 " 3406.5.4 NA 3406.5.4.1 NA 3406.5.4.2 NA 3406.5.4.3 NA 3406.5.4.4 NA ' 3406.5.4.5 NA 3406.6. This is in place. 3406.6.1 " " " 3406.6.1.1 " " " 3406.6.1.2 " " " 3406.6.1.3 64" 3406.6.1.4 " 3406.6.1.5 " 3406.6.1.6 " 3406.6.1.7 3406.6.1.8 NA 3406.6.1.9 This is in place. 3406.6.1.10 NA 3406.6.1.10.1 NA 3406.6.1.11 NA 3406.6.2 This is in place. 3406.6.2.1 " " " 3406.6.2.2 NA 3406.6.2.3 This is in place. 3406.6.3 NA 3406.6.4 This is in place. 3406.6.7 NA 3406.6.7.1 NA Page 13 3406.6.7.2 NA 3406.6.7.3 NA 3406.6.8 This is in place. 3406.8.1 " 3406.8.2 " 3406.8.3 " 3406.8.4 " 3406.8.5 " FIRE FLOW CALCULATIONS AND SUMMARIES 1) Tank Car: 22' x 100' = 2,200 ft2 Water required: 2,200 ft2 x .17 gpm /ft2 = 374 gpm x 30 minutes = 11,220 gals. Foam required (30): 374 x .03 = 11.22 gpm x 30 minutes = 337 gals. Using a 500 gpm nozzle x 30 minutes = 15,000 gals x .03 = 450 gals 3x3 AFFF Using 2 monitors, 450 gals/2 = 225 gals. Use 2 — 265 gal totes (1 at each monitor) 2)Tank Car Water Curtain: 100' x 3 gpm/lineal ft. = 300 gpm. 3) B Tank Farm West Dike: 6,418 ft2 — 2,710.49 ft2 (tank footprints except largest) 3,707.51 ft2. Water required: 3,707.51 ft2 x .17 gpm/ft2 = 630.28 gpm x 30 minutes = 18,908.4 gals. Foam required (30): 630.28 gpm x .03 = 18.91 gpm x 30 minutes = 567.3 gals AFFF. 4) B Tank Farm East Dike: 9,045 ft2 — 3,213.96 ft2 (tank footprints except largest) _ 5,831.04 ft2. Water required: 5,831.04 ft2 x .17 gpm/ft2 = 991.28 gpm x 30 minutes = 29,738.4 gals. Foam required (30): 991.28 gpm x .03 = 29.74 gpm x 30 minutes = 892.2 gals AFFF. 5) B Tank Farm Truck Loading: 25' x 125' = 3,125 ft2 Water required: 3,125 ft2 x .17 gpm/ft2 = 531.25 gpm x 30 minutes = 15,937.5 gals. Foam required (30): 531.25 gpm x .03 = 15.94 gpm x 30 = 478.2 gals AFFF. 6) Rail Car Spur (Across asphalt FAR from B tank farm SW corner of the dike wall to start of rail car parking area of tank farm A): 22' x 82' = 1,804 ft2 Water required: 1,804 ft2 x .17 gpm/ft2 = 306.68 gpm x 30 minutes = 9,200.4 gals. Page 14 Foam required (30): 306.68 gpm x .03 = 9.2 gpm x 30 minutes = 276 gals AFFF. 7) Rail Car Parking Area ( Area along A tank farm): 268.5' x 22' = 5,907 ft2 Water required: 5,907 ft2 x .17 gpm = 1,004.19 gpm x 30 minutes = 30,125.7 gals. Foam required (30): 1,004.19 gpm x .03 = 30.15 gpm x 30 minutes = 904.5 gals AFFF. All references to AFFF are for alcohol resistant foam (AR-AFFF) Water summaries for the above listed areas 1 through 7 are as follows: 1) 374 gpm x 1.15 = 430 gpm + 500 gpm for hose allowance = 930 gpm. Using a 500 gpm nozzle + 500 gpm for hose allowance = 1,000 gpm requirement. 2) 300 gpm x 1.15 = 345 gpm + 500 gpm for hose allowance = 845 gpm requirement. 3) 630.28 gpm x 1.15 = 724.82 gpm + 500 gpm for hose allowance=1,224.82 gpm. Using 2 — 500 gpm nozzles = 1,000 gpm + 500 gpm for hose allowance = 1,500 gpm requirement. 4) 991.28 gpm x 1.15 = 1,139,97 gpm + 500 gpm for hose allowance = 1,639.97 gpm. Using 3 — 500 gpm nozzles =1,500 gpm + 500 gpm for hose allowance = 2,000 gpm requirement. 5) 531.25 gpm x 1.15 = 610.94 gpm + 500 gpm for hose allowance = 1,110.94 gpm. Using 2 — 500 gpm nozzles = 1,000 gpm + 500 gpm for hose allowance = 1,500 gpm requirement. 6) 306.68 gpm x 1.15 = 352.68 gpm + 500 gpm for hose allowance = 852.68 gpm. Using a 500 gpm nozzle + 500 gpm for hose allowance = 1,000 gpm requirement. 7) 1,004.19 gpm x 1.15 = 1,154.82 gpm + 500 gpm for hose allowance = 1,654.82 gpm. Using 3- 500 gpm nozzles = 1,500 gpm + 500 gpm for hose allowance = 2,000 gpm requirement. The largest requirement for water is 2,000 gpm and 125 psi at the monitor nozzles. The city supply does not have the total pressure required for this project (see graphs attached). Approximately 149 psi is needed due to the 50' elevated monitors that will be stationed around the B tank farm. The water main to the property and inside the facility is 10" which lends itself to the use of either a 2,000 gpm booster pump or a 2,500 gpm booster pump. LSC has indicated that they would like to use a 2,500 electric booster pump rated at 80 psi for the site. Page 15 PROPOSED FIRE PROTECTION AND ASSOCIATED WORK There will be 7 — 500 gpm monitors for the project. 3 monitors will be 50' free standing for use in the B tank farm. All monitors will have a tote of foam positioned and connected to each monitor, except for the 2 monitors along the rail car parking area which shall have 2 totes each. The totes will have 3x3 AR-AFFF foam. The monitor locations are shown on the attached drawings. The monitors also have the ability to be water only. The monitors will be fed by a 2,500 gpm @ 80 psi electric pump with by- pass. The existing underground main system will be added to in order to supply the new monitors. A new entrance to the facility will be provided on the west side of the property for Fire Department Use. The common dike wall in the B tank farm will be made whole, and new drains and a supplementary drainage system will be installed. If you have any questions, or desire more information, please call me at (310) 539-4019. Sincerely, GRECO FIRE ROTECTION Gregory D. Donnan President License No. 837164 CONTRACT NO.--. -------- --------- f " H_�! C) 1 System lI No.--------- ------ - Sheet_....--------------- ~ yII ils Eli Iil... W.A. ` 'q�, t f• r + 1 y I 1A, ` 4{ 1� I �I rLr'� jllr yr 1 pp L. 1 i 1' F. 1 - 1 J I i- 41,11�-5! it Ip.'t 1 it 71 I W V 7 f S1.'1_.�!- C { r 1114 t1 afipr[ t1 i i "F sil I - i 1- NJ. I- .F' I Y 1 f I I f l t- s 'tl° rr131 s»i.,ss 11 .1 -i r -l.f-: t e � { r rf ISd - TWISS3Ud F ' II 1 - I•'Ir'�j�-1 � It I':'. ,'�5'_v 1 I I- __ 1 r •I S owl [.. LU t Y _ :. rI. I '� { - -f — "ITT: ft: I „'. l.s - Lre.rll I+iJcji j .I.fI ^#I i-I 1 I EnrolI r I� 1 i i; t l •.6 3 is I i S. 1.i 1. 1 , }.1a _. - ...1 1 r Ono Q, V * SIZ T YrES' ■ O FIRE HYDRANT ACOW TEST REPORT P Location: S/S SLAUSON 4th W/O DOWNEY RD. Time: 1033 Tester: Lazar / Moore, D Test Date: 10/3/2004 Hydrant Number Location Test Hydrant: 385 S/S SLAUSON 4th W/O DOWNEY RD Flow Hydrant 1: 384 N/S SLAUSON 2ND E/O ALCOA Flow Hydrant 2: 386 N/S SLAUSON 1ST W/O DOWNEY PSI FLOW 70 1969 60 2634 50 3179 40 3654 30 4081 20 4473 10 4838 0 5181 Test Hydrant No: 385 Main Size: 10 Static Residual Total flow - 1812 Page 1 of 1 Subj: FW: LSC Tank Farm Hydrant Flow Test ( Shawn Arballo) Date: 2/25/2009 9:34:14 A.M. Pacific Standard Time From: Ihaselhorst@coscofire.com To: grecofire aol.com Greg, See flow test information below. Thanks, Liam P. Haselhorst Sales Representative Cosco Fire Protection, Inc. 321 E. Gardena Blvd. Gardena, CA 90247 (323) 321-5155 Ph. (310) 323-0761 Fax. (213) 494-6917 Cell �'.. COSCO yS jo'J pqF y From: Jimmy Vargas Sent: Tuesday, February 17, 2009 8:27 AM To: Liam Haselhorst Subject: LSC Tank Farm Hydrant Flow Test ( Shawn Arballo) Liam; Here is the Hydrant Flow Test results from LSC Tank Farm Dry barrel (2) 2 1/2" outlets (1) 4" outlet Test was done by putting the 2 1/2" cap and gauge on the hydrant as marked on the print given to me and flowing the 2 1/2" outlet and the 4" outlet using a pitot tube. Barrel size Flow (gpm) Pressure (psi) 2 1/2" 1320 gpm 89 psi (static)/ 70 psi (residual) 4" - 2650 gpm 93 psi (static)/ 55 psi (residual) any questions please call me Shawn September 30, 2009 Samuel Kevin Wilson, P.E. Director of Community Services & Water City of Vernon 4305 Santa Fe Avenue Vernon, California 90058 Subject: Alternate Means & Methods for Fire Protection Features at the Lubricating Specialties Company's Vernon, CA Facility Dear Mr. Wilson: In accordance with Section 111.2.4 and Appendix Chapter 1, Section 104.9, of the 2007 California Fire Code, we are requesting an alternate means and method of fire protection for the proposed addition to the Lubricating Specialties Company (LSC) facility in Vernon, CA. PROJECT INFORMATION Project: Eastman Expansion Project 3365 East Slauson Ave. Vernon, CA 90058 Owner: Lubricating Specialties Company 8015 Paramount Blvd. Pico Rivera, CA 90660 Contact Info for Questions Regarding This Letter: Justin D. Reid, P.E. (213) 798-0251 Or: Greg Donnan w/ Greco Fire Protection At (310) 539-4019 REQUEST: To allow bulk transfer tank car unloading at a distance less than 25 feet (ft) from above ground storage tanks. CODE SECTION REFERENCE AND THE INTENT: The 2007 California Fire Code (CFC) Section 3406.5.1.1 requires the bulk transfer areas of Class I liquids to be located at least 25 feet away from above ground storage tanks. The intent of this section is that the transfer of liquids is inherently more hazardous due to the potential for the fuel to escape enclosed transport equipment such as hoses or nozzles and create a spill condition. PROPOSAL: Due to the existing site layout and space available the bulk transfer area is proposed to be allowed within a distance of 14 ft of the new above ground storage tanks which will LSC Addition Vernon, CA AM&M Request contain Class IB flammable liquids. The 14 ft distance is from the center of the rail car to the outside of the closest tank containing Class IB flammable liquids. This distance constitutes the worst condition for the tank closest to the dike wall. Other tanks containing Class IB flammable liquids are in the proximity of this tank and range from one foot to two feet further away from the dike wall. The distance these tanks are to the dike wall is due to the existing site conditions. The rail car route is existing in relation to theTank Farm B diked storage area. ..- Rail Car ` J'-0 , Grade Outside Dike rade Inside Dike Wall Ex10'-2 lit isting Dike Wall 2 Figure 1 - Distances from rail car to dike area. To mitigate the code deficiency and provide an equivalent level of safety, the following is proposed: • Provide a 9 ft concrete wall, consisting of at least a 2 hour fire rating, along the wall of the diked storage area which fronts the bulk transfer. o Provide a fixed fire suppression system consisting of manual hose monitors stations utilizing AR-AFF Foam in accordance with NFPA 11. September 30, 2009 LSC Addition Vernon, CA JUSTIFICATION: AM&M Request The addition of the 9 ft high concrete wall will provide an additional barrier to radiative heat produced by a fire to and from the bulk transfer area. This wall will also serve as an added vapor barrier for fuels with vapor densities heavier than air. A comparative study was conducted to look at the differences between fire exposure in the code compliant configuration of a 25 ft separation versus the proposed configuration of an 14 ft separation with a wall. An additional scenario was conducted to compare the results of an 14 ft separation without the 9 ft high wall. The Fire Dynamics Simulator (FDS) developed by the National Institute of Standards and Technology (NIST) was used to compare the differences in exposure (related in heat flux kW/m2) to the bulk transfer area from a fire in the diked area of Tank Farm B. This test scenario was selected since a fire resulting after a tank rupture in the diked area would be more hazardous than a fire originating in the bulk transfer area. The results of the study are shown in Figure 1. (Please see attached Exhibit A for additional information on the analysis). Figure 2-LSC9nw Figure 3-LSC25nw The graphed data is represented as follows: Figure 2-LSC9 LSC25nw = the tank car is located 25 ft from the edge of the diked area and no additional height is provided for the wall. September 30, 2009 100 80 E 60 Y_ X 7 LL d 40 m Y 20 -20 LSC Addition Vernon, CA AM&M Request LSC 9 = the tank car is located 5 feet 2 inches from the edge of the diked wall (14 feet to the above ground tanks when the distance from the center of the rail car is taken into account). The wall on the side of the bulk transfer area is increased to 9 ft. LSC 9nw = the tank car is located 5 feet 2 inches from the edge of the diked wall and no additional height is provided for the wall. Comparison of Radiative Heat Flux —Isc25nw TC 1 rad kW/m2 Isc9nwTC 1 rad kW Isc9 TC1 rad kW Time (s) Figure 4- Comparison of Exposures The results show that the tank car located at 5 feet 2 inches with no additional wall height is the worst scenario. When the tank car is located 5 feet 2 inches from the wall with the additional wall height (proposed condition) the exposure the tank car is subject to is equivalent to the same exposure condition where the tank car is located 25 ft away with no additional wall height (code compliant condition). These results help substantiate the claim that an equivalent level of safety will be provided by the features being proposed. In addition to the 9 ft high concrete wall, fixed fire protection will be added to protect Tank Farm B and the bulk transfer area in the -event of a fire. The benefits of the fixed fire protection by means of foam water monitors are: September 30, 2009 LSC Addition Vernon, CA AM&M Request • They provide the capability to wet exposed surfaces to decrease the radiative heat surfaces in the area receive from an exposure fire. • They provide on -site extinguishing capabilities for suppression of a spill fire by forming a foam blanket over the fuel surface and extinguishing the flame. • They provide a means of early intervention, in the event of a fire, by preventing spread of the fire until emergency crews can arrive. Lastly, NFPA 30 2008 Edition is The Flammable and Combustible Liquids Code produced by the National Fire Protection Association (NFPA) and is written by consensus of a committee of national fire experts. Section 28.4.1 is the equivalent section to 3406.5.1.1 of the 2007 CFC pertaining to the bulk transfer of liquids. This section also limits a distance of 25 feet for the bulk transfer process from above ground storage tanks. However, section 28.4.2 states: "These distances shall be permitted to be reduced if there is suitable protection from exposures." Appendix section A.28.4.2 goes on to say: "Use of fixed fire protection systems, dikes, fire -rated barriers, or a combination of any of these can provide suitable protection from exposures." This stance by NFPA 30 helps to demonstrate that there is body of consensus that are of the same opinion that the distance can be reduced when mitigating features are provided. The LSC Facility will be provided with fixed fire protection systems, dikes and fire -rated barriers to provide an equivalent level of protection as intended by the 25 ft separation requirement. September 30, 2009 LSC Addition AM&M Request Vernon, CA REQUEST: To allow tanks with a capacity of 50,000 gallons containing Class IB liquids to be present at the facility. CODE SECTION REFERENCE AND THE INTENT: Section 3404.2.9.5.1 of the CFC essentially states that the size limitation of tanks be determined by the jurisdiction in which they are located. The intent of this is to base the amount allowed to be stored on what the jurisdiction has determined they are capable of protecting based on their resources available. The City of Vernon has amended section 3404.2.9.5.1 to limit the size of tanks containing Class I liquids to 10,000 gallons. Proposal: It is proposed to allow the addition of 5 tanks with individual capacities of 50,000 gallons and containing Class IB liquids and the addition of 2 tanks with individual capacities of 14,000 gallons and containing Class IB liquids (see Exhibit B showing tank locations and capacities). The added tanks will be located in an existing diked area, Tank Farm B, at the facility which currently has a 4 ft high dike on three sides and an 8 ft high dike on one side. The size of the diked area is 6,418 ft2. The area of tanks (minus the largest) is 2,711 ft2 giving a net area of 3,707 ft2. If a 50,000 gallon tank were to completely spill its contents within the diked area the resulting height of the liquid level within the dike would be 1.8 ft high. A 14,000 gallon spill would equal 0.50 ft high. A 10,000 gallon spill would equal 0.36 ft high. For the 50,000 gallon tank, the remaining capacity in the diked area would be 8,144 ft' or 60,921 gallons. At 631 gpm from the fixed fire protection system (refer to the May 11, 2009 letter from Greco Fire Protection), the system could operate for 96 minutes before reaching capacity. This is without taking into consideration the drainage that will be provided for this diked area so the time for this diked area to reach capacity will be even greater. Because there will be tanks not in compliance with the size limitations set out by the City of Vernon, the proposal to mitigate the non -compliant tank size is to provide a fixed fire protection system consisting of water monitor nozzles discharging foam solution in accordance with NFPA 11 for Tank Farm B. Justification: In areas provided with diked barriers for secondary containment, the size of the fire is not affected by additional fuel present after a spill. A flammable liquid fire is essentially 2 dimensional and is dependent on the surface area of the fuel. The dike boundaries make this surface area constant so the dike area will, for the most part, experience the same September 30, 2009 LSC Addition Vernon, CA AM&M Request fire size (flame height, radiated heat; etc.) regardless of the amount of liquid beneath the surface. What is affected by the additional fuel is the duration in which the fire has the potential to burn and the time that it will take for the liquid to drain from the diked area. To mitigate this amended code deficiency and provide equivalency to the intent, a fixed fire protection system consisting of water monitor nozzles discharging foam solution in accordance with NFPA 11 will be provided for Tank Farm B. Section 3404.2.9.1.1 requires a foam fire protection system when required by the fire code official due to the amount of tanks and their proximity to each other. The foam fire protection system for Tank Farm B will be provided regardless of whether of this is required by the fire code official or not. An additional mitigation is that the facility will begin to be manned 24 hours a day. This will greatly decrease detection time should a fire incident occur at the facility. It should also be noted that a City of Vernon Fire Department is located approximately 0.6 miles from the facility. The presence of the fixed fire suppression system will allow onsite personnel the capability to begin attacking a fire immediately The addition of personnel on site, 24 hours a day, will ensure that there is no lapse in the ability to provide early intervention into a potential fire incident. This will allow greater time for the fire department to respond, plan and mobilize before beginning their fire suppression efforts. Should a delay in the beginning of their operations be necessary for any reason, the fixed fire suppression system will mitigate and provide equivalency to the increased volume of liquid at the facility by providing early intervention by onsite personnel. ADDITIONAL COMMENTS: Thank you for your consideration of the alternate means and methods presented in this letter. If you have any questions or comments regarding the information that has been provided, please do hesitate to contact me. Sincerely, v Justin D. Reid, P.E. (213) 798-0251 September 30, 2009 Exhibit A The comparative study conducted in the letter was conducted using the Fire Dynamics Simulator (FDS) developed by the National Institute of Standards and Technology (NIST). FDS is a computational fluid dynamics (CFD) model of fire -driven fluid flow.The software solves numerically a form of the Navier-Stokes equations appropriate for low - speed, thermally -driven flow with an emphasis on smoke and heat transport from fires. The intent of this analysis is to show a comparison of exposures based on the calculated data when subjected to the same exposure fire. The three scenarios looked at are as follows: LSC25nw = the tank car is located 25 ft from the edge of the diked area and no additional height is provided for the wall. LSC 9 = the tank car is located 9 ft from the edge of the diked wall (11 feet to the above ground tanks when 3 ft separation from wall is taken into account). The wall on the side of the bulk transfer area is increased to 9 ft. LSC 9nw = the tank car is located 9 ft from the edge of the diked wall and no additional height is provided for the wall. All three scenarios were conducted under the same conditions with only the distance of the tank car and the addition or deletion of the added wall changed in each. Below shows the LSC 9 scenario and will show the similarities between the models. Model Information: Cell size = 2ft x 2ft Number of cells = 388,800 Default surface characteristic = concrete Tank car surface characteristic = steel Fuel characteristic = Heptane, Time Duration = 60..Seconds A boundary recording condition was selected for Heat Flux. In addition to this, a thermocouple (TC) point measurement was also included for recording heat flux. The graph provided in the letter is representative of this point source. See attached data input file for more information L8CAddition Vernon, CA Figure 1-Model Domain Figure 2'Example ofthe common fire exposure AM&M Request LSC Addition AM&M Request Vernon, CA LSC25nw Scenario The scenario labeled LSC25nw is representative of a condition where the tank car is located 25 feet away from the dike area and no wall has been added. Figure 3- LSC25nw Figure 4- LSC25nw Showing Heat Flux Exposure August 20, 2009 LSC Addition AM&M Request Vernon, CA LSC9 Scenario The scenario labeled LSC9 is representative of a condition where the tank car is located 5 feet 2inches away from the dike area the wall has increased in height to 9 feet. Figure 5- LSC9 Figure 6-LSC9 Showing Heat Flux Exposure August 20, 2009 LSC Addition AM&M Request Vernon, CA LSC9nw Scenario The scenario labeled LSC8nw is representative of a condition where the tank car is located 5 feet 2inches away from the dike area the wall has not been increased in height. Figure 7-LSC9nw August 20, 2009 LSC Addition Vernon, CA Figure 9-LSC9nw Showing Heat Flux Exposure AM&M Request August 20, 2009 Lsc84.dat &HEAD CHID='LSC84',TITLE='5ft2.5in Foot separation WITH 9ft Wall' / &GRID IBAR=54, JBAR=30, KBAR=30 / &PDIM XBAR0=0,XBAR=32.9184,YBARO=0,YBAR=18.288,ZBARO=O,ZBAR=18.288 / &TIME TWFIN=60.0 / &MISC SURF_DEFAULT='CONCRETE',NFRAMES=3600, DATABASE='database4.data' REACTION='HEPTANE' / &SURF ID='BURNER',HRRPUA=1000.,RAMP_Q='IGNITION' / &RAMP ID='IGNITION', T= 0.0, F=1.0 / &RAMP ID='IGNITION', T= 20.0, F=0.0 / &VENT XB= 16.764, 16.9352, 17.6784, 17.6784, 0.85344, 1.15824, SURF_ID='BURNER',RGB=1.0,0.0,0.0 / &OBST XB= 16.764, 16.9352, 17.6784, 17.9832, 0.85344, 1.15824, RGB=1.0,0.0,0.0 / &VENT CB= 'XBARO' SURF_ID='OPEN' / &VENT CB= 'XBAR' SURF_ID='OPEN' / &VENT CB= 'YBARO' SURF_ID='OPEN' / &VENT CB= 'YBAR' , SURF_ID='OPEN' / &VENT CB= 'ZBAR' SURF_ID='OPEN' / &OBST XB= 14.9352,32.6136, 0.3048, 17.9832, 0.00, 0.85344,SURF_ID='HEPTANE'/ FUEL &OBST XB= 14.6304,32.9184, 17.9832, 18.288, 0.00, 2.4384 / &OBST XB= 14.6304,32.9184, 0.00, 0.3048, 0.00, 1.2192 / &OBST XB= 14.6304,14.9352, 0.00, 18.288, 0.00, 2.75 / &OBST XB= 32.6136,32.9184, 0.00, 18.288, 0.00, 1.2192 / &OBST XB= 10.6045,13.0429, 7.3152, 10.9728, 0.00, 2.4384,SURF_ID='STEEL' / TANK CAR 1.1938 HOLE XB= 4.00, 4.90, -0.20, 0.00, 0.00, 2.00 / Door VENT CB='YBARO',SURF_ID='OPEN' / Open the plane corresponding to y= ybarO= -0.8 VENT XB=0.00,5.20,0.00,4.60,0.00,0.00,SURF_ID='CARPET' / specify that the area given by the coordinates XB=... be given the attributes of carpet. POD DTSAM=30. / FDS Will create a P1ot3D file every DTSAM seconds. &BNDF QUANTITY='GAUGE_HEAT_FLUX' / &BNDF QUANTITY='WALL_TEMPERATURE' / &THCP XYZ=13.01,9.25,2.37,QUANTITY='RADIATIVE_FLUX',IOR=1 / &THCP XYZ=12.7381,9.0,2.45,QUANTITY='RADIATIVE_FLUX',IOR=3 / ***NOTE*** The following slice file lines (SLCF) instruct FDS to record various gas phase quantities on the planes specified by PBX, PBY, or PBZ, which correspond to the planes X=PBX, y=PBY, and Z=PBZ, respectively. The command QUANTITY=' — ' on each line tells FDS which specific value to record for that plane. slice files may be viewed in smokeview by selecting Load/unload >Slice file. SLCF PBX=2.60, QUANTITY='TEMPERATURE' / SLCF PBX=2.60, QUANTITY='HRRPUV' / Heat Release Rate per Unit Volume SLCF PBX=2.60, QUANTITY='MIXTURE_FRACTION' / Page 1 Lsc84.dat SLCF PBX=2.60, QUANTITY='RADIANT_INTENSITY' / SLCF PBX=2.60, QUANTITY='ABSORPTION_COEFFICIENT' / SLCF PBX=4.45, QUANTITY='TEMPERATURE' / SLCF PBX=4.45, QUANTITY='HRRPUV' / Heat Release Rate per Unit Volume SLCF PBX=4.45, QUANTITY='MIXTURE_FRACTION' / SLCF PBX=4.45, QUANTITY='RADIANT_INTENSITY' / SLCF PBX=4.45, QUANTITY='ABSORPTION_COEFFICIENT' / ***NOTE*** The following thermocouple (THCP) lines instruct FDS to record various values at the single point specified by XYZ=.... QUANTITY='TEMPERATURE' tells FDS that the gas temperature should be recorded at this point. THCP XYZ=2.6,2.3,2.1,QUANTITY='TEMPERATURE' / THCP XYZ=2.6,2.3,1.8,QUANTITY='TEMPERATURE' / THCP XYZ=2.6,2.3,1.5,QUANTITY='TEMPERATURE' / THCP XYZ=2.6,2.3,1.2,QUANTITY='TEMPERATURE' / THCP XYZ=2.6,2.3,0.9,QUANTITY='TEMPERATURE' / THCP XYZ=2.6,2.3,0.6,QUANTITY='TEMPERATURE' / THCP XYZ=4.5,0.3,2.1,QUANTITY='TEMPERATURE' / THCP XYZ=4.5,0.3,1.8,QUANTITY='TEMPERATURE' / THCP XYZ=4.5,0.3,1.5,QUANTITY='TEMPERATURE' / THCP XYZ=4.5,0.3,1.2,QUANTITY='TEMPERATURE' / THCP XYZ=4.5,0.3,0.9,QUANTITY='TEMPERATURE' / THCP XYZ=4.5,0.3,0.6,QUANTITY='TEMPERATURE' / THCP XYZ=0.3,4.3,2.1,QUANTITY='TEMPERATURE' / THCP XYZ=0.3,4.3,1.8,QUANTITY='TEMPERATURE' / THCP XYZ=0.3,4.3,1.5,QUANTITY='TEMPERATURE' / THCP XYZ=0.3,4.3,1.2,QUANTITY='TEMPERATURE' / THCP XYZ=0.3,4.3,0.9,QUANTITY='TEMPERATURE' / THCP XYZ=0.3,4.3,0.6,QUANTITY='TEMPERATURE' / THCP XYZ=2.6,2.3,-.01,QUANTITY='RADIATIVE_FLUX',IOR=3 / Records the net radiative flux at the specified point (on the floor). IOR=3 tells FDS that the surface where measurements are taken faces the positive z direction. Page.2 LSC8NW2.dat &HEAD CHID='LSC8nw2',TITLE='5ft2.5in Foot Separation WITHOUT Wall' / &GRID IBAR=54, JBAR=30, KBAR=30 / &PDIM XBARO=O,XBAR=32.9184,YBARO=0,YBAR=18.288,ZBARO=O,ZBAR=18.288 / &TIME TWFIN=60.0 / &MISC SURF_DEFAULT='CONCRETE',NFRAMES=3600, DATABASE='database4.data' REACTION='HEPTANE' / &SURF ID='BURNER',HRRPUA=1000.,RAMP_Q='IGNITION' / &RAMP ID='IGNITION', T= 0.0, F=1.0 / &RAMP ID='IGNITION', T= 20.0, F=0.0 / &VENT XB= 16.764, 16.9352, 17.6784, 17.6784, 0.85344, 1.15824, SURF_ID='BURNER',RGB=1.0,0.0,0.0 / &OBST XB= 16.764, 16.9352, 17.6784, 17.9832, 0.85344, 1.15824, RGB=1.0,0.0,0.0 / &VENT CB= 'XBARO' SURF_ID='OPEN' / &VENT CB= 'XBAR' , SURF_ID='OPEN' / &VENT CB= 'YBARO' SURF_ID='OPEN' / &VENT CB= 'YBAR' SURF_ID='OPEN' / &VENT CB= 'ZBAR' , SURF_ID='OPEN' / &OBST XB= 14.9352,32.6136, 0.3048, 17.9832, 0.00, 0.85344,SURF_ID='HEPTANE'/ FUEL &OBST XB= 14.6304,32.9184, 17.9832, 18.288, 0.00, 2.4384 / &OBST XB= 14.6304,32.9184, 0.00, 0.3048, 0.00, 1.2192 / &OBST XB= 14.6304,14.9352, 0.00, 18.288, 0.00, 1.2192 / &OBST XB= 32.6136,32.9184, 0.00, 18.288, 0.00, 1.2192 / &OBST XB= 10.6045,13.0429, 7.3152, 10.9728, 0.00, 2.4384,SURF_ID='STEEL' / TANK CAR HOLE XB= 4.00, 4.90, -0.20, 0.00, 0.00, 2.00 / Door VENT CB='YBARO',SURF_ID='OPEN' / Open the plane corresponding to y= ybarO= -0.8 VENT XB=0.00,5.20,0.00,4.60,0.00,0.00,SURF_ID='CARPET' / specify that the area given by the coordinates XB=... be given the attributes of carpet. PL3D DTSAM=30. / FDS will create a P1ot3D file every DTSAM seconds. &BNDF QUANTITY='GAUGE_HEAT_FLUX' / &BNDF QUANTITY='WALL_TEMPERATURE' / &THCP XYZ=13.01,9.25,2.37,QUANTITY='RADIATIVE_FLUX',IOR=1 / &THCP XYZ=12.7381,9.0,2.45,QUANTITY='RADIATIVE_FLUX',IOR=3 / ***NOTE*** The following slice file lines (SLCF) instruct FDS to record various gas phase quantities on the planes specified by PBX, PBY, or PBZ, which correspond to the planes X=PBX, y=PBY, and z=PBZ, respectively. The command QUANTITY='...' on each line tells FDS which specific value to record for that plane. Slice files may be viewed in Smokeview by selecting Load/Unload >Slice file. SLCF PBX=2.60, QUANTITY='TEMPERATURE' / SLCF PBX=2.60, QUANTITY='HRRPUV' / Heat Release Rate per Unit Volume Page 1 LSC8Nw2.dat SLCF PBX=2.60, QUANTITY='MIXTURE_FRACTION' / SLCF PBX=2.60, QUANTITY='RADIANT_INTENSITY' / SLCF PBX=2.60, QUANTITY='ABSORPTION_COEFFICIENT' / SLCF PBX=4.45, QUANTITY='TEMPERATURE' / SLCF PBX=4.45, QUANTITY='HRRPUV' / Heat Release Rate per Unit Volume SLCF PBX=4.45, QUANTITY='MIXTURE_FRACTION' / SLCF PBX=4.45, QUANTITY='RADIANT_INTENSITY' / SLCF PBX=4.45, QUANTITY='ABSORPTION_COEFFICIENT' / ***NOTE*** The following thermocouple (THCP) lines instruct FDS to record various values at the single point specified by xYz=.... QUANTITY='TEMPERATURE' tells FDS that the gas temperature should be recorded at this point. THCP XYZ=2.6,2.3,2.1,QUANTITY='TEMPERATURE' THCP XYZ=2.6,2.3,1.8,QUANTITY='TEMPERATURE' / THCP XYZ=2.6,2.3,1.5,QUANTITY='TEMPERATURE' / THCP XYZ=2.6,2.3,1.2,QUANTITY='TEMPERATURE' / THCP XYZ=2.6,2.3,0.9,QUANTITY='TEMPERATURE' / THCP XYZ=2.6,2.3,0.6,QUANTITY='TEMPERATURE' / THCP XYZ=4.5,0.3,2.1,QUANTITY='TEMPERATURE' / THCP XYZ=4.5,0.3,1.8,QUANTITY='TEMPERATURE' / THCP XYZ=4.5,0.3,1.5,QUANTITY='TEMPERATURE' / THCP XYZ=4.5,0.3,1.2,QUANTITY='TEMPERATURE' / THCP XYZ=4.5,0.3,0.9,QUANTITY='TEMPERATURE' / THCP XYZ=4.5,0.3,0.6,QUANTITY='TEMPERATURE' / THCP XYZ=0.3,4.3,2.1,QUANTITY='TEMPERATURE' / THCP XYZ=0.3,4.3,1.8,QUANTITY='TEMPERATURE' / THCP XYZ=0.3,4.3,1.5,QUANTITY='TEMPERATURE' / THCP XYZ=0.3,4.3,1.2,QUANTITY='TEMPERATURE' / THCP XYZ=0.3,4.3,0.9,QUANTITY='TEMPERATURE' / THCP XYZ=0.3,4.3,0.6,QUANTITY='TEMPERATURE' / THCP XYZ=2.6,2.3,-.01,QUANTITY='RADIATIVE_FLUX',IOR=3 / Records the net radiative flux at the specified point (on the floor). IOR=3 tells FDS that the surface where measurements are taken faces the positive z direction. Page 2 W GAY wffllrswo-O