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SAN JOAQU I N COUhliY Environmental Health Department FA0006141 PRO524264 SC333 08/21/2018 EHD 28-01 Rev. 11/07/2017 Page 2 of 4 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 Aboveground Petroleum Storage Act Inspection Report Facility Name: A L POWELL TRUCKING Facility Address: 23534 E ARTHUR RD, ESCALON Date: August 21, 2018 Qualified Facility - Tier II 502 CFR 112.6(b)(2) Tier II Qualified Facility Plan technical amendment not certified by the owner or a PE V R COS 503 CFR 112.6(b)(3), 112.6(b)(4) Failure to have a PE certify in writing alternative measures for a Tier II Qualified Facility V R COS 504 CFR 112.6(b)(4)(i) Failure of owner to assure that a PE makes all required attestations in a Tier II Plan V R COS General Requirements for SPCC Plans 601 CFR 112.7 Failure of Plan to fulfill basic requirements including a cross-referencing section V R COS 602 CFR 112.7(a)(2) Plan failed to discuss equivalent environmental protection, if applicable V R COS 603 CFR 112.7(a)(3) Failed to adequately describe the physical layout of the facility in the Plan V R COS 604 CFR 112.7(a)(3)(i) Plan failed to include oil type and storage capacity for each container V R COS 605 CFR 112.7(a)(3)(ii) Plan failed to adequately discuss discharge prevention measures, including routine handling V R COS 606 CFR 112.7(a)(3)(iii) Plan failed to adequately discuss facility drainage or drainage controls V R COS 607 CFR 112.7(a)(3)(iv) Plan failed to include countermeasures for discharge discovery, response and cleanup V R COS 608 CFR 112.7(a)(3)(v) Plan failed to address disposal methods for recovered materials V R COS 609 CFR 112.7(a)(3vi), 112.7(a4) Plan failed to adequately contain procedures for reporting a discharge V R COS 610 CFR 112.7(a)(5) Discharge procedures are not adequately addressed if the facility has no response plan V R COS 611 CFR 112.7(b) Plan failed to include a description of potential equipment failure or provide equivalence V R COS 612 CFR 112.7(c) Plan failed to include secondary containment, diversionary structures, or equip to prevent discharge V R COS 613 CFR 112.7(c) Failure to provide appropriate secondary containment, diversionary structures or equipment V R COS 614 CFR 112.7(d) PE certified Plan failed to explain impracticability of containment/diversionary structures V R COS 615 CFR 112.7(d) Failure to perform integrity and leak testing when claiming secondary containment impracticability V R COS 616 CFR 112.7(d)(1) Failure to prepare an oil spill contingency plan when claiming impracticability of structures V R COS 617 CFR 112.7(d)(2) No written commitment of manpower, equipment, and materials to control and remove oil discharge V R COS 618 CFR 112.7(e), 112.8(c) 6) Failed to keep records of procedures, inspections, or integrity tests for three years V R COS 619 CFR 112.7(f)(1) Failed to train personnel on all discharge prevention details listed in this section V R COS 620 CFR 112.7(f)(2) Failed to designate a person accountable for discharge prevention V R COS 621 CFR 112.7(f)(1) Failure to include in the SPCC Plan an adequate description of employee training V R COS 622 CFR 112.7(f)(3) Failure to conduct complete annual discharge prevention briefings for oil -handling personnel V R COS 623 CFR 112.7(g) Plan failed to address security of site and valves, lock out/tag out, and lighting V R COS 624 CFR 112.7(g) Facility failed to implement security of site and valves, lock out/tag out, and lighting V R COS 625 CFR 112.7(h) Plan failed to adequately discuss facility tank car and tank truck loading/unloading rack V R COS 626 CFR 112.7(h)(1) Loading/unloading rack containment system not adequate to contain spill V R COS 627 CFR 112.7(h)(2) Failed to provide vehicular departure system for loading and unloading racks V R COS 628 CFR 112.7(a)(1), 112.70) Failure to include in the Plan discussion of conformance with Federal and State requirements V R COS 629 CFR 112.7(i) Failed to evaluate field constructed container for brittle fracture and take appropriate action V R COS FA0006141 PRO524264 SC333 08/21/2018 EHD 28-01 Rev. 11/07/2017 Page 2 of 4 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