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9wwf e. Frank C. Alegre Trucking, Inc. OYZA(k% 5100 W. Highway 12 94Ma GUM Lodi, CA 95242 PC= GRAO6 Item#612: CFR 112.7(c)Plan failed to include secondary containment, diversionary structures,or equipment to prevent discharge. Summary of Violation: The SPCC plan states that " remaining excess oil not retained in the secondary containment structures would surface flow toward the center of the maintenance shop where it would pond." It is not stated in the plan and is unclear if the shop will be secondary containment structure the walls and floor must be capable of containing oil. A facility shall provide appropriate containment and/or diversionary structures or equipment to prevent a discharge. The entire containment system, including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system will not escape the containment system before cleanup occurs. Immediately provide adequate secondary containment for all aboveground petroleum storage containers larger than 55 gallons. This is a Class II violation. Corrective Actions Taken For Each Violation: 1. The two 250-gal. totes (filled with used oil) are now equipped with their own spill pallet. Each capable of holding 250-gal. The material of construction (plastic) is compatible with used motor oil. Item#705: CFR 112.8 (c)(1) Container not compatible with oil stored and/or storage conditions. Summary of Violation: In the discussion of the plan for compatibility of the containers, section 4.9, it is stated that "All the tanks are constructed of steel and meet industry standards for adequately storing their intended liquid contents." Two totes of 250 gallon capacity, each containing used oil, were observed to be constructed of a material other than steel. Containers shall be compatible with the material stored and the conditions of storage such as pressure and temperature. Immediately transfer the contents to a compatible container, or provide equivalence as allowed by CFR I I2.7(a)(2). This is a Class 11 violation. Corrective Actions Taken For Each Violation: 1. The 'material compatibility' section in Alegre Trucking's SPCC Plan has been revised to include a description of the 'polyethylene'tanks used to contain the used motor oil. The poly tanks are compatible with the used oil that is contained within them, according to research conducted on the internet. Item #706: CFR 112.8 (c) (2) Failure to provide and maintain adequate secondary containment. Summary of Violation: The secondary containment wall surrounding the two 10,000 gallon diesel tanks and the 5,000 gasoline tank was observed with a possible leak at the southwest corner of the wall. Water with an oily sheen was seen escaping from the secondary containment into the paved area of the facility. The 550 gallon single walled new oil tank's secondary containment is listed as being 509 gallons in the SPCC plan,this is not enough capacity to contain the entire capacity of the tank. Page 3 of 5