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SA NA MU I N Environmental Health Department COUNTY— Aboveground Petroleum Storage Act Inspection Report Facility Name: Fecn im Address: Data: E F KLUDT&SONS INC 1126 E PINE ST, LODI May 09,2019 Other Violations 4030 See below Unlisted OperationvMaintenance violation o V o R o COS 4040 See below Unlisted ReleasvLeaksl5pills violation oV oR oCOS 4050 See below Unlisted AbandonmenVlllegal Disposal/Unauthorized Treatment violation oV oR oCOS SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Nmica to Comply) Item M Remarks 603 CFR 112.7(ax3)Failed to adequately describe the physical layout of the facility in the Plan. The facility diagram does not mark as'exempt"underground storage tanks located at the facility.The facility diagram does not included transfer stations or connecting pipes,specifically the underground pipes associated with the aboveground storage tanks. Describe in your Plan the physical layout of the facility and include a facility diagram,which must mark the location and contents of each fixed oil storage container and the storage area where mobile or portable containers are located.The facility diagram must identify the location of and mark as'exempt'underground tanks that are otherwise exempted from the requirements of this part under§112.1ftl The facility diagram must also include all transfer stations and connecting pipes,including intra-facility gathering lines that are otherwise exempted from the requirements of this part under§112.1(d)(11). The SPCC plan should include all the required components in the facility diagram. Submit facility diagram for review. This is a Class II violation. 626 CFR 112.7(hx1)Loading/unloading rack containment system not adequate to contain spill. The SPCC plan does not address the secondary containment system for the loading rack.Three movable piping assemblies with at least one swivel joint were observed and meet the definition Cie loading rack.A containment system capable of holding at least the maximum capacity of any single compartment of a tank truck loaded at the facility was not evident and was not addressed in the SPCC plan.The oil/water separator capacity is not discussed and the largest container on the truck is not discussed.A drain for the oil water separator was not observed in the immediate vicinity of the loading rack. (1)Where loading/unloading rack drainage does not flow into a catchment basin or treatment facility designed to handle discharges,use a quick drainage system for tank car or tank truck loading/unloading racks.You must design any containment system to hold at least the maximum capacity of any single compartment of a tank car or tank truck loaded or unloaded at the facility. (2)Provide an interlocked warning light or physical barrier system,warning signs,wheel chocks or vehicle brake interlock system in the area adjacent to a loading/unloading rack,to prevent vehicles from departing before complete disconnection of flexible or fixed oil transfer lines. (3)Prior to filling and departure of any tank car or tank truck,closely inspect for discharges the lowermost drain and all outlets of such vehicles,and if necessary,ensure that they are tightened,adjusted,or replaced to prevent liquid discharge while in transit. The SPCC plan should adress secondary containment in all loading rack truck loading and unloading areas.Submit a Professional Engineer Certified SPCC plan for review. This is a Class II violation. FMW3771 PR0=69 SC001 059&2019 EHD2SU1 Rcr.0.l9/A1S Fage4of] Abaveg JPtlrtlam Stemal AC OIR 1868 E. Hazelton Avenue I Stockton,California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjoehd.com