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T- - , i &T TRUCKING, INC. a.U,56- 301 CFR 112.5(a) Failed to amend Plan as necessary. The SPCC plan states that buried piping is not part of the Aboveground Storage Tank system. Piping leading from aboveground storage tanks to dispensers was observed to be buried,and corrosion protection for the buried pipes is not discussed in the SPCC plan.The SPCC plan states that the facility does not have mobile or portable above ground storage tanks. Several 55 gallon drums were observed at the facility and mentioned in other sections of the Plan.The Spill Prevention, Control,and Countermeasure(SPCC) Pian 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. Plan is being amended by Advanced Geo Environmental to include underground piping and 55 Gal drums. Amended plan will be proved to SJEHD when complete. 30 day oxtonsion from January 3rd requested to complete. 618 CFR 112.7(e), 112.8(c)(6) Failed to keep records of procedures,inspections,or integrity tests for three years. The inspection forms being used do not meet the requirements of the STI SP-001 standard called for by Spill Prevention,Control,and Countermeasure(SPCC) Plan, The 1,000 gallon gasoline tank is being inspected using Air Resources phase I and phase it inspection form. Other tanks are being visually inspected daily and the inventories of the tanks being recorded but a checklist that meets the requirements of the STI SP-001 standard is not being used. Inspections and tests must be conducted and stored in accordance with the written procedures developed for this facility in the SPCC Plan. Immediately begin conducting all inspections and tests in accordance with the procedures in the SPCC Plan,or amend the Plan and have it recertified by a Professional Engineer to accurately reflect the inspection procedures currently followed at the facility and that meet the requirements of the referenced STI SP-001 industry standard. This is a Class II violation, Monthly visual tank inspections were started in December,please see attached inspection checklist provided by Gary Reeves, LLC(Certified Steel Tank Institute Level I &Level II Tank System Inspector). SPCC Plan is being amended to include inspection requirements 30 day extension from January 3'd requested to complete. 706 CFR 112.8(c)(2) Failed to provide and maintain adequate secondary containment. Parts of the SPCC plan describe a berm as the secondary containment for the area described as the tank farm containing 20,000 gallon, 10,000 gallon, 12:000 gallon and 500 gallon tanks.The bermed area is described in the SPCC plan as having a capacity of 13,900 gallons, which is insufficient for the 20,000 gallon diesel tank. The plan also states that secondary containment is achieved through a retention basin with a capacity of 748,000 gallons. At the time of the inspection,the retention basin seemed to be near capacity because of recent rains and due to the water from the oil/water separator draining into the basin.This water storage diminishes the storage capacity from a potential release event from petroleum storage tanks.This storage of water in the basin is not discussed in the SPCC plan,to ensure there is sufficient capacity to contain the entire capacity of the largest tank_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. Every tank should have a secondary containment that fulfills the requirements of the regulations and this should be reflected in tho SPCC plan. This is a Class II violation, 30 day extension from January 3r7 reQuested for construction, calculations and SPCC plan updates. 11396 NORTH HWY 991 LODI,CALIFORNIA USA 95240-68991(800)692-34571 FAX(209)931-6156 wwwAttruckinv-,.cn,rr