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SAN x] OAQU -; Environmental Health Department <br /> � <br /> C0L.IJT`o' <br /> Aboveground Petroleum Storage Act Inspection Report <br /> Facility Name: Facility Address: Date: <br /> FRANK C ALEGRE TRUCKING INC 5100 W HWY 12 , LODI March 10, 2022 <br /> SUMMARY OF VIOLATIONS <br /> (CLASS I,CLASS II,or MINOR-Notice to Comply) <br /> Item# Remarks <br /> 602 CFR 112.7(a)(2)Failed to state reasons and detail nonconformance if claiming equivalent environmental <br /> protection. <br /> OBSERVATION: The Spill Prevention, Control, and Countermeasure(SPCC)Plan reviewed at the time of <br /> inspection, (dated August 2018)failed to state reasons for nonconformance and describe in detail alternate <br /> methods used to achieve environmentally equivalent protection when claiming environmental equivalence for <br /> SPCC requirements. Specifically, page 30, of the SPCC plan listed environmental equivalence for integrity testing, <br /> but failed to state the reasons for nonconformance and describe in detail how the alternative measures achieve <br /> equivalent protection. <br /> REGULATION GUIDANCE: (2)Comply with all applicable requirements listed in this part. Except as provided in § <br /> 112.6 (Qualified Facilities Plan Requirements), your Plan may deviate from the requirements in paragraphs(g), (h) <br /> (2)and (3), and (i)of this section and the requirements in subparts B and C of this part, except the secondary <br /> containment requirements in paragraphs(c)and (h)(1)of this section, and§§ 112.8(c)(2), 112.8(c)(11), 112.9(c)(2), <br /> 112.9(d)(3), 112.10(c), 112.12(c)(2), and 112.12(c)(11),where applicable to a specific facility, if you provide <br /> equivalent environmental protection by some other means of spill prevention, control, or countermeasure.Where <br /> your Plan does not conform to the applicable requirements in paragraphs(g), (h)(2)and (3), and (i)of this section, <br /> or the requirements of subparts B and C of this part, except the secondary containment requirements in paragraph <br /> (c)and (h)(1)of this section, and§§ 112.8(c)(2), 112.8(c)(11), 112.9(c)(2), 112.10(c), 112.12(c)(2), and 112.12(c) <br /> (11),you must state the reasons for nonconformance in your Plan and describe in detail alternate methods and <br /> how you will achieve equivalent environmental protection. If the Regional Administrator determines that the <br /> measures described in your Plan do not provide equivalent environmental protection, he may require that you <br /> amend your Plan,following the procedures in § 112.4(d)and (e). <br /> CORRECTIVE ACTION: Since the SPCC Plan does not conform to the applicable requirements, the reasons for <br /> nonconformance must be stated, and the alternate methods to achieve equivalent environmental protection must <br /> be described in detail. Ensure that the SPCC Plan includes an adequate discussion of equivalent environmental <br /> protection. Submit a copy of pertinent revised SPCC plan pages for review. <br /> This is a Class II violation. <br /> FA0010619 PR0526956 SCO01 03/10/2022 <br /> EHD 28-01 Rev.12/06/2021 Page 7 of 9 Aboveground Petroleum Storage Act OIR <br /> 1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjgov.org/EHD <br />