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SA NA MU I N Environmental Health Department <br /> COUNTY— <br /> Aboveground Petroleum Storage Act Inspection Report <br /> Facility Name: Fecil ity Address: Date: <br /> E F KLUDT&SONS INC 1126 E PINE ST, LODI May 09,2019 <br /> SUMMARY OF VIOLATIONS <br /> (CLASS I,CLASS II,or MINOR-Notice to Comply) <br /> Item M Remarks <br /> 726 CFR 112.8(cx8)Plan failed to adequately describe overfill prevention methods for each container. <br /> The SPCC plan describes the overfill prevention system for the tanks as a Scully System. Per facility personnel,not all <br /> APSA regulated tanks use the Scully system.Per facility personnel,the Scully system is to prevent overfill of the truck <br /> tank being filled and not the APSA storage tank.Some of the tanks were describes as being `sticked'as an overfill <br /> precaution,being monitored by the Veeder Root system or as having a High liquid level pump cutoff devices <br /> Engineer or update each container installation in accordance with good engineering practice to avoid discharges.You <br /> must provide at least one of the following devices: <br /> (i)High liquid level alarms with an audible or visual signal at a constantly attended operation or surveillance station. In <br /> smaller facilities an audible air vent may suffice. <br /> (ii)High liquid level pump cutoff devices set to stop flow at a predetermined container content level. <br /> (iii)Direct audible or code signal communication between the container gauger and the pumping station. <br /> (iv)A fast response system for determining the liquid level of each bulk storage container such as digital computers, <br /> telepulse,or direct vision gauges. If you use this alternative,a person must be present to monitor gauges and the <br /> overall filling of bulk storage containers. <br /> (v)You must regularly test liquid level sensing devices to ensure proper operation. <br /> The SPCC plan should be address the current practices of the facility. <br /> Note: <br /> The SPCC plan seems to cover overfill prevention of the Underground Storage Tanks. Underground storage tanks at <br /> the facility are not regulated under APSA or 40 CFR 112. <br /> This is a Class II violation. <br /> Overall Inspection Comments: <br /> Complete and submit a copy of the Return to Compliance Certification form to the EHD with a statement <br /> documenting the corrective actions that have been or will be taken for each violation, and any supporting <br /> paperwork, by June 8, 2019. <br /> Starting September 1, 2018, all in-office CERS help will be provided at EHD hourly rate($152). To schedule an <br /> appointment, please call (209)468-3420. <br /> AFTER THE COMPLIANCE DATE, EHD WILL BILL FOR ALL TIME AND ACTIVITIES ASSOCIATED WITH BRINGING THIS <br /> FACILITY BACK INTO COMPLIANCE. <br /> THIS FACILITY IS SUBJECT TO REINSPECTION AT ANY TIME AT EH D'S CURRENT HOURLY RATE. <br /> QBCB1vad by` / Date: May 09,2019 Inepeutor. Inspector Phone: <br /> 7l Pdnad Nam and Title. CESAR RUVALCABA, REHS (209)953-6213 <br /> \l Michael Kludt,Operations Manager <br /> FMW3771 PR0=69 SN01 059&2019 <br /> MAD28U1 R-09CUMIS Page]of] AIoAa JPetro—Ste-Se AC OIR <br /> 1868 E. Hazelton Avenue I Stockton,California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjcehdCom <br />