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To: Kurt Duren <br /> Cc: Scott Stortroen; Rich Gomez; Mike Repetto; Neil Edgar <br /> Subject: RE: Above Ground Inspection Report <br /> Hello Kurt, <br /> I reviewed everything that was sent over and I closed out three of the open violations. Is it safe to assume that the pit <br /> drainage was determined not to hold a petroleum product since it is not included in the SPCC plan? <br /> The violation that remains open is#712. It appears from the inspection forms that you are following the SP001 industry <br /> standard but it is not discussed in the SPCC plan. Here is what the code section says: <br /> Test each aboveground container for integrity on a regular schedule,and whenever you make material repairs.The frequency of and <br /> type of testing must take into account container size and design (such as floating roof,skid-mounted,elevated,or partially buried). <br /> You must combine visual inspection with another testing technique such as hydrostatic testing, radiographic testing, ultrasonic <br /> testing,acoustic emissions testing,or another system of non-destructive shell testing.You must keep comparison records and you <br /> must also inspect the container's supports and foundations. In addition,you must frequently inspect the outside of the container for <br /> signs of deterioration, discharges,or accumulation of oil inside diked areas. Records of inspections and tests kept under usual and <br /> customary business practices will suffice for purposes of this paragraph. <br /> To close out the violation the SPCC plan needs to: <br /> -pick an industry standard (SP001, etc.) <br /> -discuss the inspection schedule (SP001 requires monthly inspections for all containers, annual inspections for non- <br /> portable tanks and a SP001 certified external inspection every 20 years for tanks 10,000 gallons and larger) <br /> Section 4.1 talks about weekly inspections and that integrity testing is not required. This is a deviation from the SP001 <br /> standard. It is acceptable to deviate from the chosen standard but you still must choose a standard and the plan should <br /> talk about why you are deviating, describe what you are doing instead and explain how it is equivalent or better than the <br /> chosen standard. <br /> If you have any questions please let me know. Have a happy Thanksgiving. <br /> Best Regards, <br /> Lydia Baker <br /> Registered Environmental Health Specialist <br /> San Joaquin County <br /> Environmental Health Department <br /> 209-468-8257 <br /> (baker@sjgov.org <br /> Please note my email address has changed to(baker@sjgov.org <br /> From: Neil Edgar<neil@edgarinc.org> <br /> Sent:Thursday, November 21, 2019 11:39 AM <br /> To: Baker, Lydia <Ibaker@sjgov.org> <br /> Cc: Kurt Duren <kurtd@tdswm.com>; Scott Stortroen <scotts@tdswm.com>; Rich Gomez<richg@tdswm.com>; Mike <br /> Repetto<miker@tdswm.com> <br /> Subject: RE:Above Ground Inspection Report <br /> Lydia— <br /> 2 <br />