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SA NA MU I N Environmental Health Department
<br /> COUNTY—
<br /> Aboveground Petroleum Storage Act Inspection Report
<br /> Facility Nam: Facility Address: Oau:
<br /> UNION PACIFIC RAILROAD-STOCKTON 833 E EIGHTH ST,STOCKTON June 12, 2019
<br /> SUMMARY OF VIOLATIONS
<br /> MIM (CLASS I,CLASS II,or MINOR-Notice to Comply)
<br /> Item M Remarks
<br /> 710 CFR 112.8(cx6)Plan failed to adequately discuss procedures to test or inspect each container for integrity.
<br /> The SPCC plan states that for single-walled tanks that are not elevated to allow inspection of all sides,including the
<br /> bottoms, single-walled tanks not installed on impervious concrete surface that allow inspection of all remaining sides,for
<br /> double-walled tanks that do not provide for interstitial space inspection,and for shop built and field erected tanks that
<br /> are insulated,UPRR is following the non-destructive shell evaluation component of integrity testing provision of 40 CFR
<br /> 112.8(cx(3).These referenced tanks are periodically tested for integrity by combining visual inspection with another
<br /> testing technique,such as hydrostatic testing,acoustic emission testing,or any other non-destructive shell testing
<br /> (NDT).If NDT testing is required,due to tank size or design,the integrity testing/inspection methods utilized will follow
<br /> inspection guidance of American Petroleum Institute(API)Standard 653,5th Edition(2014)or protocols of the Steel
<br /> Tank Institute(STI) Standard SP-001,6th Edition(January 2018)or Underwriter Laboratories(UL)Standard 142,9th
<br /> Edition(2007).For tanks that have been Out of Service and have exceeded the recommended frequency interval for
<br /> NDT,the appropriate tests and inspections will be conducted on the tank prior to return to service and will be included in
<br /> the periodic tank testing and inspection schedule.This schedule will be maintained in Appendix F of this SPCC Plan.
<br /> The inspection frequency in Appendix F does not state which industry standard is being used for the 10,000 gallon used
<br /> oil tank,TNKO-0295,20 year formal inspection and the qualifications for personnel performing tests and inspections
<br /> are not discussed.
<br /> Appendix F of the SPCC plan calls for formal external 20 year inspections for the 10,000 gallon used oil tank(TNKO-
<br /> 0295).The age of the tank is unknown and a 20 year inspection for the tank could not be provided.Appendix F has a
<br /> footnote that states,alternatively,the inspection protocol of the STI-SP001 or UL142 may be utilized for shop built AST
<br /> tanks under 75,000 gallons in capacity.
<br /> Per facility personnel the interstitial space for Tank TNKG-0079,a 250 gallon gasoline tank and 250 gallon diesel tank,
<br /> is not being inspected.
<br /> Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material
<br /> repairs.You must determine,in accordance with industry standards,the appropriate qualifications for personnel
<br /> performing tests and inspections,the frequency and type of testing and inspections,which take into account container
<br /> size,configuration, and design(such as containers that are:shop-built,field-erected,skid-mounted,elevated,equipped
<br /> with a liner,double-walled,or partially buried).Examples of these integrity tests include,but are not limited to:visual
<br /> inspection,hydrostatic testing, radiographic testing, ultrasonic testing,acoustic emissions testing,or other systems of
<br /> non-destructive testing.You must keep comparison records and you must also inspect the container's supports and
<br /> foundations. In addition,you must frequently inspect the outside of the container for signs of deterioration,discharges,
<br /> or accumulation of oil inside diked areas. Records of inspections and tests kept under usual and customary business
<br /> practices satisfy the recordkeeping requirements of this paragraph.
<br /> The SPCC plan should address the requirements of the regulations. Submit amended SPCC plan that addresses the
<br /> requirements of the regulations and proof of correction of inspections.
<br /> Note: If an owner or operator deviates from applicable industry standards to develop an integrity testing program,then
<br /> a PE must certify an environmentally equivalent alternative in the SPCC Plan.The Plan must provide the reason for the
<br /> deviation,describe the alternative approach,and explain how it achieves environmental protection equivalent to the
<br /> applicable industry standard.
<br /> FM=818 PR0529trX SN01 0WA2019
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