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S b N J 0 A Q U I N Environmental Health Department COUNTY Aboveground Petroleum Storage Act Inspection Report Facility Name: Facility Address: Date: 711 MATERIALS 2714 STAGECOACH RD, STOCKTON June 04, 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. -An industry standard was not chosen for the 300 gallon motor oil tank, 300 gallon used oil tank, 300 gallon hydraulic oil and 55 gallon drums of gear oil. -Page 18 of the SPCC plan states that, "The facility will follow the manufacturer's recommendations for testing and maintenance as described in the ConVault Owner's Manual." The SPCC plan does not discuss the qualifications of personnel performing tests and inspections,frequency and type of testing and inspections. The inspection schedule in the SPCC plan deviates from the testing and maintenance described in ConVault's Owner's Manual. -The SPCC plan also states on page 18, "The testing program is based on the U.S. EPA letter, dated September 30, 2002,to the Petroleum Marketer's Association of America (PMAA)." This is a deviation from an industry standard and does not include a discussion of environmental equivalence. 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 ensure that an industry standard is chosen and adequately discussed in the SPCC plan or provide equivalence as allowed by CFR 112.7(a)(2)and submit proof 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. 715 CFR 112.8(c)(8)(v) Failed to regularly test liquid level sensing devices to ensure proper operation. Procedures and frequency of testing for these devices were not addressed in the Spill Prevention, Control, and Countermeasure(SPCC)plan. The monthly inspection checklist does not include testing of liquid level sensing devices. Per Steven Case (General Manager)liquid level sensing devices are tested by sticking the tank and comparing to the gauges. Liquid level sensing devices must be installed in accordance with CFR 112.8 and shall be regularly tested to ensure proper operation. Immediately ensure that liquid level sensing device testing is discussed in the SPCC plan and submit proof to the EHD. This is a repeat violation, Class II. FA0014705 PR0528419 SCO01 06/04/2019 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