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SANJ O 1` Q U I `IA,II, Environmental Health Department COUNTY Aboveground Petroleum Storage Act Inspection Report Facility Name: Facility Address: Date: AMERON INTERNATIONAL 10100 W LINNE RD,TRACY January 08, 2019 Other Violations 4030 See below Unlisted Operations/Maintenance violation ❑V ❑R ❑COS 4040 See below Unlisted Release/Leaks/Spills violation ❑V ❑R ❑COS 4050 See below Unlisted Abandonment/Illegal Disposal/Unauthorized Treatment violation ❑V ❑R ❑COS SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Notice to Comply) Item# Remarks 301 CFR 112.5(a) Failed to amend Plan as necessary. The SPCC plan does not address all APSA qualified tanks. The SPCC plan failed to address an emergency generator with a belly tank containing diesel and capacity which appears to be over 55 gallons. Operational equipment in the Bell Expander and Hydrotest areas were not addressed in the SPCC plan. The operational equipment consists of two hydraulic fluid reservoirs of 300 gallons and another that may be between 400 and 500 gallons. The area referred to as the Hazardous Waste consolidation area was observed with several 55 gallon drums, some of which were described as containing oily water and is not addressed in the plan.The Spill Prevention, Control, and Countermeasure(SPCC) Plan 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. Include all aboveground petroleum storage tanks with a capacity of 55 gallons or more. This is a minor violation. 602 CFR 112.7(a)(2)Plan failed to discuss equivalent environmental protection, if applicable. The Spill Prevention, Control, and Countermeasure(SPCC)failed to discuss alternative environmental protection requirements. The SPCC plan states that the 300 and 500 gallon tanks along with some 55 gallon drums do not have overfill protection as required by CFR 112.8(c)(8). The SPCC plan does not give the reasons for nonconformance and a detailed description of the alternate method is not discussed. Table 6 of the SPCC plan states that the 300 and 500 gallon tanks do not require inspections, given the use of environmental equivalent measures described in section 5.4 of the SPCC plan. Section 5.4 of the SPCC plan does not discuss the reasons for nonconfomance and fails to describe a detailed alternative method. If the SPCC Plan does not conform to the applicable requirements,the reasons for nonconformance must stated and the alternate methods to achieve equivalent environmental protection must be described in detail in the Plan. Immediately amend the SPCC Plan to include a discussion of equivalent environmental protection. Note: Requirements for overfill prevention per CFR 112.8(c)(8). (i) High liquid level alarms with an audible or visual signal at a constantly attended operation or surveillance station. In smaller facilities an audible air vent may suffice. (ii)High liquid level pump cutoff devices set to stop flow at a predetermined container content level. (iii)Direct audible or code signal communication between the container gauger and the pumping station. (iv)A fast response system for determining the liquid level of each bulk storage container such as digital computers, telepulse, or direct vision gauges. If you use this alternative, a person must be present to monitor gauges and the overall filling of bulk storage containers. This is a Class II violation. FA0004382 PR0515795 SCO01 01/08/2019 EHD 28-01 Rev.09/27/2018 Page 4 of 6 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