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Received on 10/29/2019 SJC EHD - CR The following is an itemized list of aboveground petroleum storage act violations that have not been addressed for LODI USD-TRANSPORATIOM as of October 22, 2019. Open violations from April 16, 2019 inspection ❑ This violation was corrected HI This violation will be corrected by(date(: ❑ Supporting documents included / Des nbe actions taken or will be taken to correct violation:awLskf M S Violation#710-Plan failed to adequately discuss procedures to test or inspect each container for integrity. The SPCC plan deviates from the referenced industry standard. The SPCC plan references the Steel Tank Institute's(STQ SP-001 standard and requires integrity inspections of all tanks every 10 years and exempts the 55 gallon APSA regulated drums from the integrity testing The age of the tanks could not be determined.The two 10,000 gallon diesel tanks and the 6,000 gallon gasoline tank have had a formal SP-001 inspection conducted within the last 10 years.There is no record of the two 300 gallon motor oil tanks, 240 gallon used oil tank or the 200 hundred gallon hydraulic tank having a formal SP-001 inspection conducted as required in the SPCC plan. The SPCC plan calls for daily,quarterly and annual inspection based on the San Joaquin Air Quality Management District(AQMD)criteria and inspection criteria developed by the plan writer,deviating from the SP-001 standard and a discussion of the deviation was not found in the SPCC plan. The two 10,000 gallon doublewalled diesel tanks,and the 6,000 gallon doublewalled gasoline tank's interstitial space is not being inspected or monitored. Per EPA SPCC guidance this is the only way on doublewalled tanks to comply with the requirement to inspect the outside of the container for signs of deterioration,discharges,or accumulation of oil inside diked areas. 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 containers 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 recofdkeeping requirements of this paragraph. Immediately conduct the necessary testing and submit a copy of the test results to the EHD,or provide equivalence as allowed by CFR 1127(a)(2). Note: 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 violation was correctedSJ This violation will be corrected by(date): I ADI 13 Supporting documents included I _ ,f� Des be ac" ns taken or will be tak n to conect viola to \ r/l �w_ -W dps J10`x--V'1µ." � L.* -1 n Page 2 of 2