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April 8,2020 Cesar Ruvalcaba,Aboveground Petroleum Storage Act Inspector San Joaquin County,Environmental Health Department 18685 East Hazelton Avenue Stockton,CA 95205 Re:CERS ID No.10187011(AAFES West Coast Distribution Center,700 E Roth Road,Lathrop),Program:2832 Dear Mr.Ruvalcaba, This letter is in response to the July 12,2018 Aboveground Petroleum Storage Act Inspection Report and associated Summary of Violations issued by the San Joaquin County Environmental Health Department for the above-referenced facility. The following documents AAFES corrective actions for the violations noted in the inspection report: • Item 201:CFR 112.3(d)Failure to have a licensed PE properly review and certify the SPCC Plan.The SPCC Plan for the AAFES facility has been reviewed,revised,and certified by a registered PE.Please see Page i of the attached SPCC Plan for the required PE certification,signature,date and stamp. • Item 603:CFR 112.7(a)(3)Failure to adequately describe the physical layout of the facility in the Plan.The SPCC Plan facility diagrams have been reviewed and revised to accurately depict the location and contents of oil container storage locations and areas,transfer stations,and connecting pipes.Please refer to Appendix A of the SPCC Plan for these figures. • Item 618:CFR 112.7(e),112.8(c)(6)Failure to keep records of procedures,inspections,or integrity tests for three years. Section 3.5 of the SPCC Plan addresses required inspections and tests,and requires that completed inspection records are retained for at least three years.Tank#3 is equipped with a Veeder Root TLS 350 system,which monitors inventory level,provides high-level alarm notification,and provides interstitial monitoring.It performs a tank test and a self-diagnostic every Sunday night.These records are kept for 3 years. In addition,facility personnel began conducting monthly inspections of the ASTs and drum storage areas on DATE,and will conduct and document inspections of these areas using inspection forms found in Appendix a of the SPCC Plan on or around the 51 of each month.Annual inspections of the tanks will be conducted during the month of January each year.All three tanks are Category 1 tanks per STI SP001(they all have spill control and continuous release detection method).As tank#1 and#2 are 350-and 500- gallons respectively,the monthly and annual inspections are all that are required per STI SP001.Tank#3 (12,000 gallons)must be inspected by a certified STI SP001 inspector every 20 years.Tank 3 is due for its first external inspection on IDA Td Commented[GTI]:Need to ask Eddie when the tank was installed–the first certified external inspection needs to be • Item 619:CFR 112.7(f)(1)Failure to train personnel on all discharge prevention details listed in this completed within 20years ofthe install date. section. Section 3.7 of the SPCC Plan addresses personnel training requirements.AAFES is currently working with a contractor to develop a SPCC Plan training module,land will ensure all oil-handling— _ _ Commented[Gi2]:In Eddie'sJune 13 email to Cesar,he personnel receive training by September 2019. mentions 5 people scheduled forthe SPCCclass at the CUPAon 6 August.Is thisjust example language,or are 5 people actually registered?If people are registered,need to add that here.