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SAN :J O A Q U I N Environmental Health Department COUNTY Aboveground Petroleum Storage Act Inspection Report Facility Name: Facility Address: Date: MOUNTAIN VALLEY EXPRESS INC 1 1019 BESSEMER AVE, MANTECA April 11, 2019 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 SPCC plan states that the concrete pad with an internalized slope has a total containment area and discharge capacity which is sufficient volume for the largest tank and is designed to manage the precipitation around the AST. Based on observations and discussion with the facility personnel the oil water separator is the actual secondary containment for single wall 600 gallon oil tank. Certain parts of the plan suggest that the containment pad is the secondary containment for the double walled 10,000 gallon diesel tank and the double walled 550 gallon used oil tank. 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. The SPCC plan should accurately address secondary containment and capacity of the oil water separator. This is a Class II violation. 712 CFR 112.8(c)(6) Failed to test or inspect each container for integrity based on industry standards. -Table 9 in the SPCC plan deviates from the SP001 standard. Table 9 footnote states that the inspection frequency is based on implementation of a scheduled inspection/testing program. To initiate the programs, ASTs will be inspected following shell repairs or as directed by local enforcement agency. Section 3.1 of the SPCC plan states that non-destructive integrity evaluation is not performed on ASTs. Facility management has deemed that routine AST inspections are sufficient for identifying potential spills. -The tank inspection form included in the SPCC plan deviates from the SP001 standard monthly and annual inspection checklist. The presence of water in the tank, interstitial monitoring and checking if the interstitial space is free of liquid are some of the items not included in the checklist. Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs.You must determine, in accordance with industry standards,the appropriate qualifications for personnel performing tests and inspections, the frequency and type of testing and inspections,which take into account container size, configuration, and design(such as containers that are: shop-built, field-erected, skid-mounted, elevated,equipped with a liner, double-walled, or partially buried). 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.You must keep comparison records and you must also inspect the container's supports and foundations. In addition, you must frequently inspect the outside of the container for signs of deterioration,discharges, or accumulation of oil inside diked areas. Records of inspections and tests kept under usual and customary business practices satisfy the record keeping requirements of this paragraph. Ensure the the industry standard mentioned in the SPCC plan is followed. 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. FA0010328 PRO515715 SCO01 04/11/2019 EHD 28-01 Rev.09127/2018 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