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SANJ Q A Q U I N Environmental Health Department C: OuNTY Aboveground Petroleum Storage Act Inspection Report Facility Name: I Facility Address: Date: LODI USD-TRANSPORATION' 820SCLUFFAVE. LODI Aril 162019 SUMMARY OF VIOLATIONS IU ASS I,CLASS II,or MINOR-Noticeto Comply) Item M Remarks 621 CFR 112.7(fx1)Failure to include in the SPCC Plan an adequate description of employee training. Discharge prevention briefings are not scheduled at least once a year, per facility personnel. Discharge prevention briefings for oil handling personnel must be scheduled and conducted at least once a year to assure adequate understanding of the SPCC Plan for that facility. Such briefings must highlight and describe known discharges or failures,malfunctioning components, and any recently developed precautionary measures. Immediately schedule and conduct a discharge prevention briefing, ensure that they are scheduled and conducted at least once a year. This is a Class II violation. 710 CFR 112.8(cx6)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 (STI)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 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 recordkeeping 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 112.7(ax2). 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 is a Class II violation. Overall Inspection Comments: FMWM42 PRO515466 SN01 W&C019 EHDM8 I Rcr.0.l2]/A18 Page 5of6 Abaveg JPdod—SbrA,AC OIR 1868 E. Hazelton Avenue I Stockton,California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjcehdCom