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Cesar Ruvalcaba [EH] From: Cesar Ruvalcaba [EH] Sent: Thursday, February 21, 2019 2:16 PM To: 'Kari Casey' Cc: Juan Gutierrez;jcrawford@crst.com Subject: RE: Gardner Trucking - PR0513264 Kari, Thank you for submitting the return to compliance for Gardner Trucking in Manteca. I was able to close most of the violations based on the submitted statements, SPCC plan and training records. Below you will find a comment on overfill prevention and two violations that have not been fully addressed.Also, I did not have the opportunity to read through the whole plan, only sections dealing with the open violations were read. Comment: (No action required, but may be a question at next inspection) Under overfill prevention system,the Plan states that "The two (2) 10,00-gallon ASTs are equipped with remote liquid level sensors and an overfill prevention system." Since the alarm system is located in the parts department, how does the person who fills the tanks know when the alarm goes off and thus prevent the overfill of the tanks? Violations that remain open: Violation#618-Failed to keep records of procedures, inspections,or integrity tests for three years. There needs to be something submitted that assures the department that inspections/tests will be conducted as required by the SPCC plan and SP001 standard and that the records will be maintained as required. I did not see this addressed on either of the return to compliance communications. Violation#710-Plan failed to adequately discuss procedures to test or inspect each container for integrity. The industry standard for the tanks, per the SPCC plan, is the Steel Tank Institute's (STI) SP-001 standard. Per the table on page 19 of the SPCC plan, all tanks were classified as category 1 using the SP-001 criteria.The SPCC plan states that tables 5.5 and B2.1 of the SP-001 standard where used to determine the inspection/testing frequency for the tanks, as required by the SP-001 standard. On page 18 of the SPCC plan, it states that only visual inspections are required on a monthly and yearly cycle for the tanks at the facility.This is reaffirmed on page 19 of the SPCC plan, under the "testing required" column, only"visual inspection" is required for all tanks and the "testing frequency" column has "monthly and annual" for all tanks. For the 10,000 gallon diesel tanks there are additional inspections/testing requirements, per the STI SP-001 standard. Under the SP-001 standard any category 1 tank that has a capacity between 5,001 gallons to 75,000 gallons must undergo Formal External Inspection by a Certified Inspector every 20 years.To comply with the standard, this must be done for the 10,000 gallon tanks.To comply with the regulation, the appropriate qualifications for the personnel performing the tests and inspections,the frequency and type of testing and inspections would need to be addressed in the plan. It may be a good idea to have the year when the formal inspections are due, so that the facility knows exactly what and when to do it.Judging by the dates of manufacture provided in the SPCC plan for the 10,000 gallon tanks,the formal inspection is fast approaching. Feel free to contact me with any questions or concerns. 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