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The following is an itemized list of aboveground petroleum storage act violations that <br /> have not been addressed for Gemco Ripon Truck Plaza Inc. as of September 29, <br /> 2021. <br /> Open violations from February 10, 2020 inspection <br /> Violation#706-Failed to provide and maintain adequate secondary containment. <br /> The secondary containment for the 20,000 gallon tanks appeared to not be sufficiently impervious to contain <br /> discharged oil.The western end of the containment berm appeared to have a circular depression which had a hole <br /> approximately one inch in diameter on the floor of the diked area.The hole seemed to have mud in it. Facility <br /> personnel were unsure what this was for or whether or not this hole was used for drainage. Material around the hole <br /> seemed to suggest liquid pooled around it, but what happened to the liquid is unclear.This hole is not addressed in <br /> the SPCC plan. This may traverse the concrete bottom and it may be a way for liquid to escape the secondary <br /> containment.A pipe that seem to go underground,within the containment dike of the 20,000 gallon tanks was <br /> observed on the western half of the diked area. Facility personnel could not identify where the pipe terminated of <br /> what it was for.The pipe went underground by the pumps that pump the diesel from the tanks to the dispensers. <br /> The other end of the pipe was observed near the loading area of the tanks.The pipe appeared to have an open end <br /> which would allow any liquid release to travel through it.The pipe was between 1 to 2 feet above the ground level, <br /> significantly lower than the top of the dike wall. This pipe was not discussed in the SPCC plan and could potentially <br /> make the secondary containment sufficiently impervious to contain discharged oil.Two other pipes at ground level <br /> were observed near the loading area of the 20,000 diesel tanks. These pipes were within the containment dike, near <br /> ground level.The end of the pipes could not be determined by facility personnel. One of the pipes had a completely <br /> open top and the other had what may have been a cover, but did not appear to be liquid tight.These two pipes may <br /> potentially make the secondary containment sufficiently impervious to contain discharged oil and are not addressed <br /> in the SPCC plan. <br /> Parts of the SPCC plan describe the 20,000 gallon tanks as double walled,other parts of the SPCC plan describe <br /> the tanks as single walled. Per facility manager and observations,the tanks appear to be single walled tanks. The <br /> 20,000 gallons tanks may be permanently manifolded tanks. Four 20,000 gallon tanks were observed and appear to <br /> share common piping and only one pipe travels from the tank farm to the dispensers. The SPCC plan may need to <br /> have a discussion on whether or not the tanks meet the definition of permanently manifolded tanks and if so, how <br /> secondary containment is achieved. <br /> Construct all bulk storage tank installations(except mobile refuelers and other non-transportation-related tank <br /> trucks)so that you provide a secondary means of containment for the entire capacity of the largest single container <br /> and sufficient freeboard to contain precipitation.You must ensure that diked areas are sufficiently impervious to <br /> contain discharged oil. Dikes, containment curbs, and pits are commonly employed for this purpose.You may also <br /> use an alternative system consisting of a drainage trench enclosure that must be arranged so that any discharge will <br /> terminate and be safely confined in a facility catchment basin or holding pond. <br /> Ensure that diked areas are sufficiently impervious to contain discharged oil and that secondary containment is <br /> provided for the entire capacity of the largest single container and sufficient freeboard to contain precipitation, <br /> including the combined capacity of tanks which are deemed to be permanently manifolded. .This may have to be <br /> certified by a Professional Engineer through the SPCC plan. <br /> Note: Permanently manifolded tanks are tanks that are designed, installed,or operated in such a manner that the <br /> multiple containers function as a single storage unit(67 FR 47122, July 17,2002).Accordingly,the total capacity of <br /> manifolded containers is the design capacity standard for the sized secondary containment provisions(plus <br /> freeboard in certain cases). <br /> ❑ This violation was corrected ❑This violation will be corrected by(date): <br /> ❑ Supporting documents included <br /> Describe actions taken or will be taken to correct violation: <br /> Page 8 of 11 <br />