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SAN JOAQUIN Environmental Health Department -COUNTY Aboveground Petroleum Storage Act Inspection Report Facility Name: CONCRETE INC Facility Address: 1728 LINNE RD, TRACY Date: November 17, 2020 Other Violations 4010 See below Unlisted Administration/Documentation violation oV D R Li COS 4020 See below Unlisted Training violation oV DR o COS 4030 See below Unlisted Operations/Maintenance violation oV DR DCOS 4040 See below Unlisted Release/Leaks/Spills violation 0V DR oCOS 4050 See below Unlisted Abandonment/Illegal Disposal/Unauthorized Treatment violation 111 V .2 R D COS SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) Item # Remarks 710 CFR 112.8(c)(6) Plan failed to adequately discuss procedures to test or inspect each container for integrity. OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) Plan does not adequately discuss procedures to test or inspect each aboveground container for integrity in accordance with industry standards and does not address the following: -In section 15.4 of the SPCC plan a settlement agreement from 2004 between the EPA, API, Petroleum Marketers Association of America and Marathon Oil Company was referenced to demonstrate why integrity testing is not needed. This settlement is no longer applicable as it was based on old regulations and not the updated 2013 regulations. REGULATION GUIDANCE: (c)(6) Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs. You must determine, in accordance with industry standards, the appropriate qualifications for personnel performing tests and inspections, the frequency and type of testing and inspections, which take into account container size, configuration, and design (such as containers that are: shop-built, field-erected, skid-mounted, elevated, equipped with a liner, double-walled, or partially buried). Examples of these integrity tests include, but are not limited to: visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other systems of non-destructive testing. You must keep comparison records, and you must also inspect the container's supports and foundations. In addition, you must frequently inspect the outside of the container for signs of deterioration, discharges, or accumulation of oil inside diked areas. Records of inspections and tests kept under usual and customary business practices satisfy the record keeping requirements of this paragraph. CORRECTIVE ACTION: Ensure that the SPCC Plan adequately discusses facility's procedures to test and inspect aboveground/bulk storage containers in accordance with all applicable industry standards. This discussion must include, but not be limited to, inspection/testing schedule/frequency, and personnel qualifications. Submit proof of correction to the EHD. If an owner or operator deviates from applicable industry standards to develop an integrity testing program, then a PE must certify an environmentally equivalent alternative in the SPCC Plan. The Plan must provide the reason for the deviation, describe the alternative approach, and explain how it achieves environmental protection equivalent to the applicable industry standard. This is a Class II violation. Overall Inspection Comments: Complete and submit a copy of the Return to Compliance Certification form to the EHD with a statement documenting the corrective actions that have been or will be taken for each violation, and any supporting paperwork, by December 17, 2020. FA0009536 PR0540694 SC001 11/17/2020 EHD 28-01 Rev. 9/16/2020 Page 4 of 5 Aboveground Petroleum Storage Act OIR 1868 E. Hazelton Avenue I Stockton, California 95205 I T 209 468-3420 I F 209 464-0138 I www.sjgov.org/EHD