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Environmental Health Department <br />Aboveground Petroleum Storage Act Inspection Report <br />Date: <br />February 22, 2022 <br /> Facility Address: <br /> 20451 MCHENRY AVE, ESCALON <br /> Facility Name: <br /> LIONUDAKIS FIREWOOD <br />SUMMARY OF VIOLATIONS <br />(CLASS I, CLASS II, or MINOR - Notice to Comply) <br />RemarksItem # <br /> 624 CFR 112.7(g) Plan failed to address security of site and valves, lock out/tag out, and lighting. <br />OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) Plan did not include a discussion of <br />required security measures. Lighting was not discussed as a security measure in the SPCC plan. <br />REGULATION GUIDANCE: <br />(g) Describe in your Plan how you secure and control access to the oil handling, processing and storage areas; <br />secure master flow and drain valves; prevent unauthorized access to starter controls on oil pumps; secure <br />out-of-service and loading/unloading connections of oil pipelines; and address the appropriateness of security <br />lighting to both prevent acts of vandalism and assist in the discovery of oil discharges. <br />CORRECTIVE ACTION: Ensure that the SPCC plan adequately addresses the following security measures: <br />lighting. Provide proof of correction to the EHD. <br />This is a repeat violation, Class II. <br /> 712 CFR 112.7(e), 112.8(c)(6) Failed to perform scheduled tank tests or inspections by appropriately qualified <br />personnel. <br />OBSERVATION: Facility failed to ensure that tanks are inspected and tested by an appropriately qualified person in <br />accordance with industry standards. <br />- Monthly Inspection are not being done on portable containers. <br />- Monthly and annual inspection are not being done on fixed storage containers. <br />- The external formal inspection for the two 20,000 gallons diesel tanks were due in 2020 and were not performed. <br />REGULATION GUIDANCE: 112.8(c)(6) Test or inspect each aboveground container for integrity on a regular <br />schedule 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 <br />recordkeeping requirements of this paragraph. <br />112.7(e) Inspections, tests, and records. Conduct inspections and tests required by this part in accordance with <br />written procedures that you or the certifying engineer develop for the facility. You must keep these written <br />procedures and a record of the inspections and tests, signed by the appropriate supervisor or inspector, with the <br />SPCC Plan for a period of three years. Records of inspections and tests kept under usual and customary business <br />practices will suffice for purposes of this paragraph. <br />CORRECTIVE ACTION: Immediately ensure that all tanks are inspected and tested by an appropriately qualified <br />person in accordance with industry standards. Submit proof of correction/ test results to the EHD. <br />This is a Class II violation. <br />FA0010254 PR0523036 SC001 02/22/2022 <br />EHD 28-01 Rev. 12/06/2021 Aboveground Petroleum Storage Act OIRPage 7 of 9 <br />1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD