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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: J B HUNT TRANSPORT INC 2660 LOOMIS RD, STOCKTON January 18, 2019 Other Violations 4040 See below Unlisted Release/Leaks/Spills violation ❑V ❑R ❑COS 4050 See below Unlisted Abandon ment/lIlegal Disposal/Unauthorized Treatment violation ❑V ❑R ❑COS SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Notice to Comply) Item# Remarks 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 does not explain how it achieves environmental protection equivalent to the applicable industry standard or the reasons for nonconformance.The industry standard, STI SP-001, calls for integrity testing by a certified STI SP-001 inspector, every 20 years, per the certifying professional engineer.The SPCC plan also seems to use secondary containment of the 15,000 gallon tank for the environmental equivalence. 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: EPA noted in a May 2004 letter to the Petroleum Marketers Association of America (PMAA),the presence of sized secondary containment for bulk storage containers,which is required under§112.8(c)and other relevant parts of the SPCC rule, does not provide, by itself, an environmentally equivalent alternative to performing integrity testing of bulk storage containers If an owner or operator deviates from applicable industry standards to develop an integrity testing program,then a PE must certify an environmentally equivalent alternative in the SPCC Plan.The Plan must provide the reason for the deviation, describe the alternative approach, and explain how it achieves environmental protection equivalent to the applicable industry standard. This is a Class II violation. 613 CFR 112.7(c) Failure to provide appropriate secondary containment, diversionary structures or equipment. The 1,000 gallon new oil tank was observed without appropriate secondary containment.The secondary containment for the 1,000 gallon new oil tank is described in the plan as being concrete curbing around the area where the tank is stored. One end of the tank goes over the concrete curbing and the tank is not fully contained within the secondary containment area so that a discharge from the primary containment system will be contained before cleanup occurs.A facility shall provide appropriate containment and/or diversionary structures or equipment to prevent a discharge. The entire containment system, including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system will not escape the containment system before cleanup occurs. Immediately provide adequate secondary containment for all aboveground petroleum storage containers larger than 55 gallons. This is a minor violation. FA0007705 PR0528418 SCO01 01/18/2019 EHD 28-01 Rev.09/27/2018 Page 4 of 5 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