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i f The following is an itemized list of aboveground petroleum storage act violations that have not been addressed for PANELLA TRUCKING LLC as of May10, 2019. i I Open violations from October 19, 2018 inspection Violation #301 -Failed to amend Plan as necessary. Page 5, section 2.5, of the SPCC plan states that the facility meets the criteria of a Tier II qualified facility. The I facility does not qualify for Tier II requirements based on the aggregate storage capacity of the facility being over 10,000 gallons. Page 10 of the SPCC plan states that storage drums are not addressed in the plan as they are not utilized for oil storage. Based on observations made at the facility and other sections of the plan, 55 gallon drums f are used for the storage of petroleum product. Page 20, section 4.2.4 of the plan, which addresses 40 CFR 112.8(c)(3), states that the section does not apply as berms are not utilized at the facility for secondary containment. Several tanks were observed to to have a diked area as secondary containment and is described in other sections of the plan. The Spill Prevention, Control, and Countermeasure (SPCC) Plan must be amended when there is a change in the facility design, construction, operation, or maintenance that materially affects its potential for a discharge, within 6 months of the change, and implemented as soon as possible, not later than 6 months following preparation of the amendment. Immediately make all necessary amendments to the SPCC Plan to accurately represent the procedures and policies currently in place at the facility. Note: A 100 gallon used oil container was removed from the facility within the last 6 months. Violation #603 -Failed to adequately describe the physical layout of the facility in the Plan. The storage area where mobile or portable containers are located was not included in the facility diagram. 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. Violation #609 - Plan failed to adequately contain procedures for reporting a discharge. The Spill Prevention, Control, and Countermeasure (SPCC) Plan does not provide information and procedures to enable a person to adequately report a discharge. The 24 hour phone number for the San Joaquin County Environmental Health Department provided in the SPCC plan is incorrect. If a response plan was not submitted to j the Regional Administrator, this information must be included in the SPCC Plan Immediately amend the SPCC j Plan to include this information and submit a copy of the revision to the EHD. Violation #706 - Failed to provide and maintain adequate secondary containment. The areas referred to as West Tank Farm and East Tank Farm were observed with insufficient secondary containment. The wall providing secondary containment for the up t0 10,000 gallon tanks were observed to have i holes at ground level next to the corners. The circular holes of approximately one inch in diameter where observed near corners of the containment wall and traversed the entire wall. Construct all bulk storage tank installations (except mobile refuelers and other non-transportation-related tank trucks) so that you provide a secondary means of containment for the entire capacity of the largest single container and sufficient freeboard to contain precipitation. You must ensure that diked areas are sufficiently impervious to contain discharged oil Dikes, containment curbs, and pits are commonly employed for this purpose. You may also use an alternative system consisting of a drainage trench enclosure that must be arranged so that any discharge will terminate and be safely confined in a facility catchment basin or holding pond. Immediately provide secondary containment that sufficiently impervious to contain discharged oil and is capable of containing the entire capacity of the largest single container and sufficient freeboard to contain precipitation. Page 1 of 2