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SA NA MU I N Environmental Health Department COUNTY— Aboveground Petroleum Storage Act Inspection Report Facility Name: IF cin iry Address: Date: E F KLUDT&SONS INC 1126 E PINE ST, LODI May 09,2019 SUMMARY OF VIOLATIONS ICLASS I,CLASS II,or MINOR-Noticeto Comply) Item M Remarks 705 CFR 112.8(cx1)Container not compatible with oil stored and/or storage conditions. The SPCC plan certifies the tanks material and construction for 4 tanks within the diked area and 3 tanks outside the diked are.There were also 55 gallon drums and 275 gallon totes being used as containers for the storage of oil and the material and construction are not certified. Not use a container for the storage of oil unless its material and construction are compatible with the material stored and conditions of storage such as pressure and temperature. The SPCC should certify material and construction for all containers regulated under APSA storing APSA regulated product This is a Class II violation. 706 CFR 112.8(cx2)Failed to provide and maintain adequate secondary containment. Some of the single walled tanks in the diked secondary containment area appear to be permanently manifolded.This is not discussed in the SPCC plan and the secondary containment for the combined tanks is not addressed in the SPCC plan. 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 the entire capacity for the single largest container and sufficient freeboard to contain precipitation. Submit Professional Engineer Plan for review. Note: Permanently manifolded tanks are tanks that are designed, installed,or operated in such a manner that the multiple containers function as a single storage unit(67 FR 47122,July 17, 2002).Accordingly,the total capacity of manifolded containers is the design capacity standard for the sized secondary containment provisions(plus freeboard in certain cases). The EPA believes the proper standard of'sufficient freeboard'to contain precipitation is that amount necessary to contain precipitation from a 25-year,24-hour storm event.That standard allows flexibility for varying climatic conditions. It is also the standard required for certain tank systems storing or treating hazardous waste.(67 FR 47117, July 17, 2002) This is a Class II violation. FMW3771 PR0=69 SN01 059&2019 EHD28U1 Rcr.0.12FC0I8 Page5of7 Abaveg J Pertlam Sbra)e AC OIR 1868 E. Hazelton Avenue I Stockton,California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjcehdCom