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Stacy Rivera August 3, 2011 Page 6 UPDATE ON RETURN TO COMPLIANCE CERTIFICATION - HAZARDOUS WASTE GENERATOR PROGRAM INSPECTION REPORT AND ABOVEGROUND PETROLEUM STORAGE ACT INSPECTION REPORT FOR CITY OF STOCKTON MUNICIPAL UTILITIES DEPARTMENT MAIN PLANT, TERTIARY PLANT AND STORES FACILITIES INSPECTIONS CONDUCTED MAY 11, 2011 change took place over six months ago, and the SPCC Plan has not been updated to reflect this change. The State Office of Emergency Services is now called the California Emergency Management Agency (CalEMA). The SPCC Plan mist include a contact list and phone numbers for the facility response coordinator, National Response Center, cleanup contractors with whom you have an agreement for response and all appropriate federal, state and local agencies who must be contacted incase of a discharge. Retained the services of Condor Earth Technologies, who are in the process R of conducting a Spill Prevention, Control and Countermeasures Plan update. July 2011 Draft Working Copy has incorporated these contact changes. Will provide follow-up letter by July 29, 2011. 31 31. Failed to conduct inspections and test in accordance with the written V procedures and /or maintained signed records of inspections and tests as required by the facility's SPCC Plan on site for 3 years. N Copies of inspection and testing records were not found in site. Retained the services of Condor Earth Technologies, who are in the process of conducting a Spill Prevention, Control and Countermeasures Plan R update. July 2011 Draft Working Copy has incorporated changes or provided place holders for information update. Will provide follow-up letter by July 29, 2011. 32 32. Failed to: (1) train personnel on discharge prevention; (2) designate a V person to be accountable for discharge prevention; or (3) schedule prevention discharge briefings at least annually. N Annual Training is not being conducted for the aboveground petroleum storage pro ram and containers. No training records were available on site. R SPCC Training Plan is will be finalized and implemented upon completion of SPCC update. Will provide follow-up when plan is finalized. 48 48. Failed to test each aboveground container for integrity of a regular V schedule or when repairs were made; inspect containers and container supports; or keep records of inspections and tests, or provide equivalence as allowed by CFR 112.7(a) (2). Copies of integrity inspection or integrity test records were not available on N site. All aboveground containers are to be inspected on a regular basis in accordance with appropriate indust standards. Retained the services of Condor Earth Technologies, who are in the process of conducting a Spill Prevention, Control and Countermeasures Plan R update. July 2011 Updated Draft Working Copy has incorporated changes or provided place holders for information update. Will provide follow-up as plan is finalized. 50 V 50. Failed to install and regularly test approved liquid level sensing devices, or provide equivalence as allowed by CFR 112.7 a (2). Liquid Level sensing devices have not been tested. Procedures and N frequency of testing for these devices was not addressed in the SPCC Plan. Liquid level sensing devices must be installed in accordance with 40 CFR 112.8 and shall be regularly tested to ensure proper operation.