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to Industry Standards. Testing of the tanks was performed by Certified SP001 Inspector on May 17, 2017. The monthly inspections are recorded on page 33. This violation was for not having an industry standard referenced in the SPCC plan. This standard would need to be certified and approved by the Professional Engineer. I have attached discussion on industry standards that are found in EPA guidance document. Here is a link for the typical standard used for your types of tanks,this is only an example,the Professional Engineer needs to certify in the SPCC plan what the standard is and determine, according to the standard, 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.The link can be found here. Depending on what standard is chosen for the facility the inspection forms being used may not be adequate. Some standards have their own inspection checklists for monthly and/or yearly inspections. I have included sample inspection checklists of a standard, as an example. The adequacy of the inspection forms cannot be determined until an engineer certifies a standard. Here is the regulation: 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. FREE classes presented by NES Inc. are available to all San Joaquin County Hazardous Waste, Underground Storage Tank, and Aboveground Petroleum Storage Facility Business Owners and Operators. List and schedule of classes can be found here. Thank you, Cesar Ruvalcaba San Joaquin County Environmental Health Department Environmental Health Specialist 1868 East Hazelton Ave Stockton, CA 95205 2 (209)953-62131 A (209) 464-0138 2 cruvalcaba@sigov.org All°1OANIN -C0UNTv— ; F +■! Greotness grows pert, From: Michael Collins<mcollins@foodexp.com> Sent:Tuesday,June 25, 2019 10:21 AM To: 'Garrison Reeves'<greeves455@aol.com>; Ruvalcaba, Cesar<cruvaIca ba@sogov.org>;Justin Keeney <itkeeney@foodexp.com> Subject: FW: SPCC Plan updates Good Morning Cesar. Here are the new revised documents for the SPCC Plan from Gary. I believe this takes care of the missing updates. If there is anything else you need from me to complete the return to compliance let me know! I appreciate all of your help! 2