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SANJOARIN Environmental Health Department —COUNTY Aboveground Petroleum Storage Act Inspection Report Facility Name: I Facil it,Address: Oate: BROWN SAND INC 800 WMOSSCALEAVE, LATHROP February 04, 2020 SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Nmicem Comply) Item M Remarks 112 CFR 112.20(e)Failure to complete and maintain a Substantial Harm Criteria certification. A Substantial Harm Criteria Certification that is comparable to one contained in appendix C of CFR 112 was not found on site. If the owner or operator of a facility determines pursuant to paragraph(ax2)of this section that the facility could not, because of its location, reasonably be expected to cause substantial harm to the environment by discharging oil into or on the navigable waters or adjoining shorelines,the owner or operator shall complete and maintain at the facility the certification form contained in appendix C to this part and, in the event an alternative formula that is comparable to one contained in appendix C to this part is used to evaluate the criterion in paragraph(fx1)(iixB)or(f)(lxiixC)of this section,the owner or operator shall attach documentation to the certification form that demonstrates the reliability and analytical soundness of the comparable formula and shall notify the Regional Administrator in writing that an alternative formula was used. Complete and maintain a Substantial Harm Criteria Certification that is comparable to one contained in appendix C of CFR 112. This was corrected on site. This is a Class II violation. 208 CFR 112.3(dx1)Failure of owner to assure that the PE makes all required attestations in the Plan. The certifying Professional Engineer did not make all the required attestations. The attestations in the SPCC plan were"I hereby certify that I have examined the facility, and being familiar with the provisions of 40 CFR part 112, attest that this SPCC Plan has been prepared in accordance with good engineering practices." Except as provided in§112.8, a licensed Professional Engineer must review and certify a Plan for it to be effective to satisfy the requirements of this part. (1)By means of this certification the Professional Engineer attests: (i)That he is familiar with the requirements of this part; (ii)That he or his agent has visited and examined the facility; (iii)That the Plan has been prepared in accordance with good engineering practice,including consideration of applicable industry standards, and with the requirements of this part; (iv)That procedures for required inspections and testing have been established;and (v)That the Plan is adequate for the facility. (vi)That, if applicable,for a produced water container subject to§112.9(cx8),any procedure to minimize the amount of free-phase oil is designed to reduce the accumulation of free-phase oil and the procedures and frequency for required inspections,maintenance and testing have been established and are described in the Plan. This is a minor violation. FA0010a. PROSIU83 SN01 0290.2021 EHD18U1 Rcr.&2N1019 Page 5 of Abaveg JPtl eum Sbra)e AC OR 1868 E. Hazelton Avenue I Stockton,California 95205 1 T 209 488-3420 1 F 209 484-0138 1 www.sjoehd.com