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SANJ OA U I Environmental Health Department — 0U NTY Aboveground Petroleum Storage Act Inspection Report Facility Name: Facility Address: Date: VAN DE POL ENT INC-PRIMARY 4895 S AIRPORT WAY, STOCKTON March 26, 2019 SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Notice to Comply) Item# Remarks 618 CFR 112.7(e), 112.8(c)(6) Failed to keep records of procedures, inspections, or integrity tests for three years. Copies of inspection and testing records as required by the SPCC plan 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. This is a repeat violation, Class Il. 710 CFR 112.8(c)(6) Plan failed to adequately discuss procedures to test or inspect each container for integrity. The SPCC plan deviates from the Steel Tank Institute's SP-001 standard, which is referenced in the plan. Table 9 of the SPCC plan, which contains the frequency of inspections for the APSA regulated tanks, states that the frequency is based on implementation of a scheduled inspection testing program and that to initiate the program ASTs will be inspected by the following dates. The section for the dates states "following repairs or as directed by local enforcement agency".This is not in accordance the the STI SP-001 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. The SPCC plan must not deviate from industry standards, environmental equivalence can be provided as allowed by CFR 112.7(a)(2). This is a Class II violation. 726 CFR 112.8(c)(8) Plan failed to adequately describe overfill prevention methods for each container. Overfill prevention is described as direct read gauges for all tanks. The 12,000 gallon diesel tank does not have a direct read gauge. Facility personnel described the process as sticking the tank and using a tank chart as overfill prevention. Engineer or update each container installation in accordance with good engineering practice to avoid discharges. You must provide at least one of the following devices: (i) High liquid level alarms with an audible or visual signal at a constantly attended operation or surveillance station In smaller facilities an audible air vent may suffice. (ii) High liquid level pump cutoff devices set to stop flow at a predetermined container content level. (iii) Direct audible or code signal communication between the container gauger and the pumping station. (iv)A fast response system for determining the liquid level of each bulk storage container such as digital computers, telepulse, or direct vision gauges. If you use this alternative, a person must be present to monitor gauges and the overall filling of bulk storage containers. (v)You must regularly test liquid level sensing devices to ensure proper operation. The SPCC plan should address overfill for all tanks in the SPCC plan. This is a Class II violation. Overall Inspection Comments: FA0015758 PRO526970 SCO01 03/26/2019 EHD 28-01 Rev.09/27/2018 Page 5 Of 6 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