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SAN 10 A Q U I N Environmental Health Department ,, Aboveground Petroleum Storage Act Inspection Report Facility Name: Facility Address: Date: STOCKTON STEEL CO 3003 E HAMMER LN STOCKTON May 15 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 portable generators mentioned in the SPCC plan are classified as operational equipment and only general secondary containment is addressed. The diesel belly tanks for the portable generators meet the definition of bulk storage containers and require sized secondary containment, and sufficient freeboard to contain precipitation,to be addressed in the SPCC plan. The two 100 gallon oil containers in the lube area did not appear to have adequate secondary containment. Portions of the two tanks were not within the secondary containment tank that was directly underneath them. The bottom corners of tanks closest to the wall did not appear to be within the secondary containment area.The SPCC plan stated the pit area would contain any oil not contained by the tank.The pit area had a metal berm around it that would prevent liquid from going into it. 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.The SPCC plan should address secondary containment for all bulk storage containers.All APSA regulated bulk storage tanks should be within described secondary containment Submit a P.E certified copy of the plan for review and ensure that all tanks are withing secondary containment. This is a Class II violation. 710 CFR 112.8(c)(6) Plan failed to adequately discuss procedures to test or inspect each container for integrity. There is no industry standard selected or referenced for the inspections/tests of most of the APSA regulated tanks. The 10,000 gallon tank has a hybrid plan developed for it which mentions the Steel Tank Institute SP-001 standard. The standard is deviated from and a full discussion of environmental equivalence is not provided in the SPCC plan. 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. The SPCC plan should address and am industry standard for all tanks or provide equivalence as allowed by CFR 112.7(a)(2). Note: Per EPA guidance, 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. FA0004400 PR0528317 SCO01 05/15/2019 EHD 2"1 Rev.09/27/2018 Page 6 of 7 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