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SANJ O 1` Q U I `IA,II, Environmental Health Department COUNTY Aboveground Petroleum Storage Act Inspection Report Facility Name: T36 y Address: Date: SILVA TRUCKING MATHEWS RD, FRENCH CAMP January 31, 2019 Other Violations 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 706 CFR 112.8(c)(2)Failed to provide and maintain adequate secondary containment. The 10,000 and 12,000 gallon diesel tanks appear to be permanently manifolded and may not have sufficient secondary containment. A pipe was observed connecting the two tanks and this was not addressed in the SPCC plan.According the the secondary containment calculations for the 10,000 gallon diesel tank,the diesel exhaust fluid (DEF)container inside the secondary containment wall was not considered in determining the capacity of the secondary containment. Table 8 of the SPCC plan states that secondary containment for the 300 and 400 gallon tanks is provided by concrete, other parts of the plan describe the tanks as double walled steel tanks. All bulk storage tanks must be provided with a secondary means of containment for the entire capacity of the tank and sufficient freeboard to contain precipitation. Immediately provide sufficient secondary containment for this and all other tanks at this facility. Note: Permanently manifolded tanks are tanks that are designed, installed,or operated in such a manner that the multiple containers function as a single storage unit(67 FR 47122, July 17,2002).Accordingly,the total capacity of manifolded containers is the design capacity standard for the sized secondary containment provisions(plus freeboard in certain cases). This is a Class II violation. 711 CFR 112.8(c)(6)Failed to perform scheduled tank tests or inspections by appropriately qualified personnel. The 10,000 gallon diesel tank was not tested on schedule by certified personnel. Per the SPCC plan, external inspections by a certified inspector, as per Steel Tank Institute(STI)Standard SP-001, is recommended every 10 years for the 10,000 and 12,000 gallon tanks.The 10,000 gallon tank has been in service for over 20 years, according to facility personnel. The SPCC plan indicates that a certified SPCC inspection was conducted in 2013. Records at the facility indicate that the 10,000 gallon,400 gallon and 300 gallon tanks had a Tank Thickness testing performed on April 9, 2013. The Tank Thickness Testing Report was stamped by a professional engineer, but a Certified SP001 inspection could not be located. The Tank Thickness Testing Report does not meet the full requirements of the STI SP001 standard. Each aboveground container shall be tested and inspected for integrity on a regular schedule and whenever repairs are made. The qualifications of personnel performing tests and inspections,frequency and type of testing and inspections that take into account container size, configuration, and design shall be determined in accordance with industry standards. Examples of these integrity tests include, but are not limited to:visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing,or other systems of non-destructive testing. Comparison records and other records of inspections and tests must be maintained on site. Immediately conduct the necessary testing and submit a copy of the test results to the EHD, or provide equivalence as allowed by CFR 112.7(a)(2). This is a Class II violation. FA0009414 PR0516179 SCO01 01/31/2019 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