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S b N J 0 A Q U I N Environmental Health Department COUNTY— Aboveground CUNTYAboveground Petroleum Storage Act Inspection Report Facility Name: Facility Address: Date: YRC INC 1 1535 E Pescadero Ave, Tracy [May24, 2019 SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Notice to Comply) Item# Remarks 712 CFR 112.8(c)(6)Failed to test or inspect each container for integrity based on industry standards. Tank 2 was installed in 1991 per the 2016 API 653 external inspection. Internal inspection records were unavailable for review during the inspection. Tank 3 had an API 653 internal inspection in 2010. The SPCC plan does not adequately discuss testing and inspection for integrity based on an industry standard. Section 8.3.6 of the SPCC plan does not take into account 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 CUPA does not have the authority to dictate which forms to use in the standards and that if the SP-001 forms will be used the engineer needs to certify that they meet the requirements of the API standard. Each aboveground container shall be tested and inspected for integrity on a regular schedule and whenever repairs are made. The qualifications of personnel performing tests and inspections,frequency and type of testing and inspections that take into account container size, configuration, and design shall be determined in accordance with industry standards. 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. Comparison records and other records of inspections and tests must be maintained on site. Immediately conduct or find the necessary internal testing for Tank 2 and submit a copy of the test results to the EHD, or provide equivalence as allowed by CFR 112.7(a)(2). Immediately ensure that the SPCC plan adequately discusses the inspection and testing schedule per industry standard and submit a copy of the amended SPCC plan to the EHD. 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: Complete and submit a copy of the Return to Compliance Certification form to the EHD with a statement documenting the corrective actions that have been or will be taken for each violation, and any supporting paperwork, by June 24, 2019. Starting September 1, 2018, all in-office CERS help will be provided at EHD hourly rate ($152). To schedule an appointment, please call (209)468-3420. Inspector Provided: Return to Compliance certification, flier for free CUPA classes Tanks Observed: 2-80,000 gallon diesel tanks 2-500 gallon diesel generators FA0003854 PR0515797 SCO01 05/24/2019 EHD 28-01 Rev.09/27/2018 Page 5 of 6 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