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<br />FA0009536 PR0540694 SCOOt 71/17/2020
<br />EHD28-01 Rev. 9/16/2020 Aboveground Petr
<br />Page 4 Of 5
<br />Facility Name: Facility Atltlress: Date:
<br />CONCRETE INC 1728 LINNE RD, TRACY November 17, 2020
<br />.: t "s,Ot�ereYiot�ons
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<br />4070
<br />See below
<br />Unlistetl Administration/Doamentation violation
<br />o V o R o COS
<br />4020
<br />See below
<br />Unlisted Training violation
<br />o Vo R o COS
<br />4030
<br />See below
<br />Unlisted Operations/Maintenanceuiolation
<br />o V o R in COS
<br />4040
<br />See below
<br />Unlisted Release/Leaks/Spills violation
<br />o V o R o COS
<br />4050
<br />See below
<br />Unlisted Abandonment/Illegal Disposal/Unauthorized Treatment violation
<br />mV o R o COS
<br />-SllIV�MdRY OP 1ll�JLATIONS 1
<br />or MINOR No6cefo Comply) F
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<br />Item #
<br />Remarks
<br />710
<br />CFR 112.8(c)(6) Plan failed to adequately discuss procedures to test or inspect each container for integrity.
<br />OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) Plan does not adequately discuss
<br />procedures to test or inspect each aboveground container for integrity in accordance with industry standards and
<br />does not address the following:
<br />-In section 15.4 of the SPCC plan a settlement agreement from 2004 between the EPA, API, Petroleum Marketers
<br />Association of America and Marathon Oil Company was referenced to demonstrate why integrity testing is not
<br />needed. This settlement is no longer applicable as it was based on old regulations and not the updated 2013
<br />regulations.
<br />REGULATION GUIDANCE: (c)(6) Test or inspect each aboveground container for integrity on a regular schedule
<br />and whenever you make material repairs. You must determine, in accordance with industry standards, the
<br />appropriate qualifications for personnel performing tests and inspections, the frequency and type of testing and
<br />inspections, which take into account container size, configuration, and design (such as containers that are:
<br />shop -built, field -erected, skid -mounted, elevated, equipped with a liner, double -walled, or partially buried). Examples
<br />of these integrity tests include, but are not limited to: visual inspection, hydrostatic testing, radiographic testing,
<br />ultrasonic testing, acoustic emissions testing, or other systems of non-destructive testing. You must keep
<br />comparison records, and you must also inspect the container's supports and foundations. In addition, you must
<br />frequently inspect the outside of the container for signs of deterioration, discharges, or accumulation of oil inside
<br />diked areas. Records of inspections and tests kept under usual and customary business practices satisfy the record
<br />keeping requirements of this paragraph.
<br />CORRECTIVE ACTION: Ensure that the SPCC Plan adequately discusses facility's procedures to test and inspect
<br />aboveground/bulk storage containers in accordance with all applicable industry standards. This discussion must
<br />include, but not be limited to, inspection/testing schedule/frequency, and personnel qualifications. Submit proof of
<br />correction to the EHD.
<br />If an owner or operator deviates from applicable industry standards to develop an integrity testing program, then a
<br />PE must certify an environmentally equivalent altemative in the SPCC Plan. The Plan must provide the reason for
<br />the deviation, describe the alternative approach, and explain how it achieves environmental protection equivalent to
<br />the applicable industry standard.
<br />This is a Class II violation.
<br />Overall Inspection Comments:
<br />Complete and submit a copy of the Return to Compliance Certification form to the EHD with a statement
<br />documenting the corrective actions that have been or will be taken for each violation, and any supporting
<br />paperwork, by December 17, 2020.
<br />oleum Storage Act OIR
<br />1868 E. Hazelton Avenue � Stockton, California 95205 � T 209 468-3420 i F 209 464-0138 � www.sjgov.org/EHD
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