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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 ICI ASS I,CLASS II,or MINOR-Noticeto Comply) Item M Remarks 710 CFR 112.8(cx6)Plan failed to adequately discuss procedures to test or inspect each container for integrity. The Spill Prevention,Control and Countermeasures plan does not determine what the industry standard will used for the testing and inspection of the tanks.The industry 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 should be addressed in the SPCC plan.The testing and inspection requirements indicated in the SPCC plan are the following Veeder Root Annual testing Annual Vapor Recovery Testing as specified in California Executive Order G-70-139 Semi Annual Leak Check as Required by the San Joaquin Valley Air Pollution Control 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 record keeping requirements of this paragraph. The SPCC plan should address what the standard is a list the requirements specified in regulation or provide equivalence as allowed by CFR 112.7(a)(2). Submit Professional Engineer certified SPCC plan for review. Note: 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. 718 CFR 112.8(cx11)Failed to locate properly or provide sufficient secondary containment for mobile/portable containers. In the discussion for this section,the SPCC plan states that the facility does not have mobile or portable containers regulated under APSA.There were 55 gallon drums and 275 gallon totes storing regulated APSA product.Secondary containment for these tanks was not evident and not fully addressed in the SPCC plan. Position or locate mobile or portable oil storage containers to prevent a discharge as described in §112.1(b).Except for mobile refuelers and other non-transportation-related tank trucks, you must furnish a secondary means of containment, such as a dike or catchment basin,sufficient to contain the capacity of the largest single compartment or container with sufficient freeboard to contain precipitation. The SPCC plan should address secondary containment for all mobile or portable containers regulated under APSA. This is a Class II violation. FMW3771 PR0=69 SN01 050&2019 MAD28-01 Rcr.0.127/AI8 Page 6at7 AIaA,,JPtl eum 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