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7"Wf e. Frank C. Alegre Trucking, Inc. 0XZA(k% 5100 W. Highway 12 .�.G,Va Lodi, CA 95242 '°°°°""°` The two 10,000 gallon diesel tanks seemed to be permanently manifolded making the tanks a 20,000 gallon capacity tank. The secondary containment for the tanks is described as being 14,246 gallons in one part of the plan and 13,640 gallons in another part of the plan. The two 250 gallon totes of used oil are described as having an active secondary containment (spill kit). The two 250 gallon tanks are defined as being bulk storage tanks and do not meet the requirement for the entire capacity of the tank,based on the limited mention in the SPCC plan. All bulk storage tanks must be provided with a secondary means of containment for the entire capacity of the tank and sufficient freeboard to contain precipitation. Immediately provide sufficient secondary containment for this and all other tanks at this facility. SUMMARY OF VIOLATIONS (CLASS 1, CLASS II, or MINOR-Notice to Comply)Remarks Note: For onshore storage facilities and production facilities, permanently manifolded oil storage tanks are defined as tanks that are designed, installed, and/or operated in such a manner that the multiple tanks function as one storage unit (i.e., multiple tank volumes are equalized). In a worst case discharge scenario, a single failure could cause the discharge of the contents of more than one tank. The owner or operator must provide evidence in the response that tanks with common piping or piping systems are not operated as one unit or comply with secondary containment regulations. This is a Class 11 violation. Corrective Actions Taken For Each Violation: 1. The leak at the southwest corner of the containment wall has been patched. The storm water with the oily sheen observed in the containment area has been removed and disposed properly. 2. The secondary containment for the 550-gallon single wall tank has been revised in Table 4 (SPCC Plan)to 550-gallons. 3. The EPA Region#9 determined that the two 10,000 gallon tanks are permanently manifolded together in the current configuration. The EPA stated that if the pipe (at the top of each tank) connecting the two tanks together was removed and capped, then the tanks would be considered as two single 10,000 gallon tanks. The secondary containment was recalculated (as a single 20,000 gallon tank) and proved have sufficient containment. The new calculations include an allowance for a 25-year, 24-hour rainfall event, and 5% displacement. After allowances, there is approximately 3,610 gallons of `excess' secondary containment available. 4. The SPCC Plan has been revised to indicate that the net secondary containment capacity is 23,610 gallons. 5. Each of the two 250-gallon totes (containing `used' motor oil) now has their own spill pallet which is able to contain the entire contents of the tote (250-gal.). The SPCC Plan has been updated accordingly. No allowance for rainfall is necessary because both totes are indoors. The SPCC Plan has been updated to reflect the changes. Page 4 of 5