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Cesar Ruvalcaba [EH] From: Paul Ferroni <Paul.Ferroni@stocktonca.gov> Sent: Friday, February 22, 2019 3:01 PM To: Cesar Ruvalcaba [EH] Subject: RE: SPCC/APSA inspection - 2500 Navy Dr. - PR0527882 Cesar, Thank you for your continued assistance on this matter. I have been working with Condor to finalize our checklists and we have them ready to go. I will send the response next week as I am finalizing some HMMP currently today. I have also signed up for the SPCC training course on April 9t"with the county to update my knowledge. Appreciate your help. Paul S. Ferroni Safety Manager City of Stockton Municipal Utilities (209)937-7188 (209)351-6427 Cell From: Cesar Ruvalcaba [EH] <cruvalcaba@sjcehd.com> Sent: Friday, February 22, 2019 2:57 PM To: Paul Ferroni<Paul.Ferroni@stocktonca.gov> Subject: RE: SPCC/APSA inspection -2500 Navy Dr. - PR0527882 Paul, The training log has been received and the violation has been closed.There are two violations that remain open.As explained on the 01/17/2019 email, the inspection checklists provided do not meet the requirements of the of the STI SP-001 standard. A statement assuring the department that inspections are being conducted as required by the SPCC plan will be needed.The recommended checklists to use were attached to the 01/17/2019 email.A statement will also be needed for the testing of the liquid level devices. It was previously stated that some of the liquid level sensing devices had been replaced, but have the remaining devices been tested to ensure they are functional? If so submit a statement along with the return to compliance certification form. Violation#618-Failed to keep records of procedures,inspections,or integrity tests for three years. Copies of inspection and testing records were not found on site. Inspections and tests must be conducted in accordance with the written procedures developed in the Spill Prevention, Control, and Countermeasure (SPCC) Plan. Records of these inspections and tests must be signed by the appropriate supervisor or inspector and kept on site with the SPCC Plan for a period of three years. Immediately locate a copy of all inspection and testing records for the last three years, maintain them on site, and submit copies to the EHD. Violation#715-Failed to regularly test liquid level sensing devices to ensure proper operation. Liquid level sensing devices have not been tested for any of the tanks, as described in the SPCC plan. Liquid level sensing devices must be installed in accordance with CFR 112.8 and shall be regularly tested to ensure proper operation. Immediately conduct all necessary testing of liquid level sensing devices,or provide equivalence as allowed by CFR 112.7(a)(2). FREE classes presented by NES Inc. are available to all San Joaquin County Hazardous Waste, Underground Storage Tank, and Aboveground Petroleum Storage Facility Business Owners and Operators. List and schedule of classes can be found here. i