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SANJ O 1` Q U I `IA,II, Environmental Health Department COUNTY Aboveground Petroleum Storage Act Inspection Report Facility Name: Facility Address: Date: UNION PACIFIC RAILROAD- Intermodal Facility 1000 E ROTH RD, FRENCH CAMP October 26, 2018 Other Violations 4040 See below Unlisted Release/Leaks/Spills violation ❑V ❑R ❑COS 4050 See below Unlisted Abandon ment/lIlegal Disposal/Unauthorized Treatment violation ❑V ❑R ❑COS SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Notice to Comply) Item# Remarks 301 CFR 112.5(a) Failed to amend Plan as necessary. Approximately three 55 gallon drums containing product regulated under APSA were observed inside the garage area near the east wall.That storage location of the drums is not addressed in the SPCC plan. The Spill Prevention, Control, and Countermeasure(SPCC) Plan must be amended when there is a change in the facility design, construction, operation,or maintenance that materially affects its potential for a discharge,within 6 months of the change, and implemented as soon as possible, not later than 6 months following preparation of the amendment. Immediately make all necessary amendments to the SPCC Plan to accurately represent the procedures and policies currently in place at the facility. This is a minor violation. 602 CFR 112.7(a)(2)Plan failed to discuss equivalent environmental protection, if applicable. The Spill Prevention, Control, and Countermeasure(SPCC)failed to discuss alternative environmental protection requirements. Page 31 of the SPCC plan states that UPRR is following the provisions of 40 CFR 112.8(c)(6)based on good engineering practices and measures implemented by the facility.40 CFR 112.8(c)(6)states that You must determine, in accordance with industry standards,the appropriate qualifications for personnel performing tests and inspections,the frequency and type of testing and inspections, which take into account container size, configuration, and design.An industry standard is not referenced in this section of the plan. If the SPCC Plan does not conform to the applicable requirements, the reasons for nonconformance must stated and the alternate methods to achieve equivalent environmental protection must be described in detail in the Plan. Immediately amend the SPCC Plan to include a discussion of equivalent environmental protection. Note: If an owner or operator deviates from applicable industry standards to develop an integrity testing program,then a PE must certify an environmentally equivalent alternative in the SPCC Plan.The Plan must provide the reason for the deviation, describe the alternative approach, and explain how it achieves environmental protection equivalent to the applicable industry standard. This is a Class II violation. Overall Inspection Comments: Complete and submit a copy of the Return to Compliance Certification form to the EHD with a statement documenting the corrective actions that have been or will be taken for each violation, and any supporting paperwork by November 25, 2018 . Starting September 1, 2018, all in-office CERS help will be provided at EHD hourly rate ($152). To schedule an appointment, please call (209)468-3420. FA0010216 PR0523352 SCO01 10/26/2018 EHD 28-01 Rev.09/27/2018 Page 4 of 5 Aboveground Petroleum Storage Act OIR 1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjcehd.com