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SAN J D AL I L , Environmental Health Department Aboveground Petroleum Storage Act Inspection Report Facility Name: Facility Address: Date: PACIFIC ETHANOL STOCKTON LLC 3028 NAVY DR, STOCKTON December 06, 2018 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 603 CFR 112.7(a)(3)Failed to adequately describe the physical layout of the facility in the Plan. The facility diagram is lacking connecting pipes regulated under APSA. The Spill Prevention, Control, and Countermeasure(SPCC)Plan shall include a facility diagram which must mark the location and contents of each fixed storage container and the storage area where mobile or portable containers are located. It must identify the location of and mark as"exempt"underground tanks. It must also include all transfer stations and connecting pipes, including intra-facility gathering lines. Immediately update the facility diagram to include all of the required information. Submit a legible copy of the updated facility diagram to the EHD for review. This is a repeat violation, Class ll. 625 CFR 112.7(h) Plan failed to adequately discuss facility tank car and tank truck loading/unloading rack. The SPCC plan failed to discuss the rail loading/unloading rack and its containment.Where loading/unloading rack drainage does not flow into a catchment basin or treatment facility designed to handle discharges, use a quick drainage system for tank car or tank truck loading/unloading racks.You must design any containment system to hold at least the maximum capacity of any single compartment of a tank car or tank truck loaded or unloaded at the facility.Amend the SPCC plan to include a discussion of all loading/unloading rack. This is a minor violation. 710 CFR 112.8(c)(6)Plan failed to adequately discuss procedures to test or inspect each container for integrity. The SPCC plan states that integrity tests on tanks are performed per Air Permit 40 CFR 60 subpart Kb, Standards of Performance for VOC Liquid Storage Vessels. The SPCC plan also mentions STI SP-001 industry standard, which applies to aboveground storage tanks between 5,000 and 30,000 gallons(per the SPCC plan), are conducted every 20 years but that facility has opted for the 40 CFR subpart Kb inspections.The 40 CFR 60 subpart Kb is not an industry standard.The qualifications of personnel performing tests and inspections is not discussed.The largest storage tank at the facility regulated under APSA is listed as 582,750 gallons.The monthly inspections conducted by the facility do not reference an industry 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. Ammend the SPCC plan to include an industry standard or standards that apply to all tanks on site, or provide equivalence as allowed by CFR 112.7(a)(2). This is a Class II violation. FA0019299 PR0530029 SCO01 12/06/2018 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