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SAN JOAQUIN COUNTY ENVIRONMENTAL HEALTH DEPARTMENT 600 East Main Street, Stockton, California 95202-3029 Telephone: (209) 468-3420 Fax: (209) 468-3433 Web: www.sogov.org/ehd ABOVEGROUND PETROLEUM STORAGE ACT (APSA) PROGRAM INSPECTION REPORT CONTINUED Facility A L Powell Trucking Co Addy": 23534 E Arthur Road, Escalon InsDae�On Sep 29, 2010 Name: VIOLATIONS # V R Code Section HSC = CA Heatth and Saf Code; CFR = Code of Federal Regulations V = Vidabon; RV = R dation S Ic requirements of HSC 25270.4.5 a are identified as CFR code sections inni with 112 27 CFR 112.7(b) SPCC Plan failed to include a description of potential equipment failure (direction, flow rate, quantity), or provide equivalence as allowed by CFR 112.7(a)(2) 28 CFR 112.7(c) Failed to provide secondary containment and/or diversionary structures that are capable of containing discharge from primary containment until it is cleaned u Failed to provide explanation, conduct periodic integrity testing of containers and/or periodic integrity and 29 CFR 112.7(d) leak testing for valves and piping if containment or discharge prevention structures were determined to be impracticable on an SPCC Plan or sections of one that is PE certified If a response plan was not submitted to the RA, and containment or discharge prevention structures were 30 CFR 112.7(d) determined to be impracticable, the SPCC Plan failed to provide: (1) an oil spill contingency plan, (2) written commitment of manpower, equipment, materials to control and remove oil discharge 31 CFR 112.7(e) Failed to conduct inspections and tests in accordance with written procedures and/or maintain signed records of inspections and tests as required by the facility's SPCC Plan on site for 3 years Failed to: (1) train personnel on discharge prevention; (2) designate a person to be accountable for 32 CFR 112.7(f) discharqe prevention; or 3) schedule prevention discharge prevention briefings at least annual) Failed to describe how the oil handling, processing and storage areas are secured and controlled; how 33 CFR 112.7(g) master flow and drain valves are secured; how unauthorized access to starter controls on oil pumps are prevented, how out -of -service and loading/unloading connections are secured, the appropriateness of security lighting; or provide equivalence as allowed by CFR 112-7(a)(2) Failed to provide sufficient secondary containment capacity for tank car or tank truck loading and 34 CFR 112.7(h)(1) unloading area if drainage area is not designed to flow into a catchment basin designed to handle discharges Failed to provide methods to prevent vehicles from departing loading and unloading areas before complete 35 CFR 112.7(h)(2) disconnection of transfer lines or provide equivalence as allowed by CFR 112.7(a)(2) Failed to inspect lower-most drains and all outlets of vehicles for discharge prior to filling and departure 36 CFR 112.7(h)(3) and take appropriate measures to prevent liquid discharge while in transit or provide equivalence as allowed b CFR 112-7(a)(2) Failed to evaluate field -constructed container for risk of discharge or failure due to brittle facture or other 37 CFR 112.7(i) catastrophe after repair, alteration, reconstruction, or change in service, or provide equivalence as allowed by CFR 112.7a 2 SPCC Plan failed to include a complete discussion of conformance to discharge prevention and 38 CFR 112.70) containment procedures as listed in part 112 and any applicable more stringent State rules, regulations, and guidelines If a response plan was not submitted to the RA, and secondary containment is not provided for qualified oil -filled equipment, the SPCC Plan failed to: (i) establish and document procedures for inspection or a 39 CFR 112.7(k)(2) monitoring program to detect equipment failure and/or discharge, (ii) provide oil spill contingency plan and/or written commitment of manpower, equipment, materials to control and remove oil discharge Failed to prevent discharge into the drainage system from diked storage areas and/or inspect 40 CFR 112.8(b)(1) accumulation prior to drainage, or provide equivalence as allowed by CFR 11 2.7 a 2 Failed to use manual, open -and -closed design valves for the drainage of diked areas, or provide 41 CFR 112.8(b)(2) equivalence as allowed by CFR 112.7(a)(2) Failed to design facility drainage system from undiked areas to flow into appropriate ponds, lagoons, or 42 CFR 112.8(b)(3) catchment basins (in areas not subject to flooding) designed to retain oil or return it to the facility, or provide equivalence as allowed by CFR 112.7(a)(2) Failed to equip the final discharge of all ditches with a diversion system that would retain oil in the facility in 43 CFR 112.8(b)(4) the event of an uncontrolled discharge if CFR112.8(b)(3) is not met, or provide equivalence as allowed by CFR 112-7(a)(2 Failed to provide two "lift" pumps, one permanently installed, where drainage waters are continuously 44 CFR 112.8(b)(5) treated in more than one treatment unit, or provide equivalence as allowed by CFR 112-7(a)(2) Container not compatible with oil stored and/or storage conditions, or failed to provide equivalence as 45 CFR 112.8(c)(1) allowed by CFR 112.7(a)(2) Failed to provide sufficient secondary containment capacity for a bulk storage tank that would hold the 46 CFR 112.8(c)(2) volume of the largest container plus sufficient freeboard to contain precipitation and/or diked area is not sufficiently impervious to contain discharged oil Allowed drainage of uncontaminated rainwater from a diked area and failed to: (i) keep bypass valves sealed closed, (ii) inspect retained rainwater prior to discharge, (iii) open bypass valve and reseal it under 47 CFR 112.8(c)(3) responsible supervision; (iv) maintain adequate records of such events; or provide equivalence as allowed by CFR 112.7a(2 Inspector Phone: (209) 468-3439 Rved ; Title (t le rn EHD 28-02 Rev 2/19/10 Page 2 APSA INSPECTION REPORI