Environmental Health Department
<br />AMENDED
<br />3/30/2023
<br />Aboveground Petroleum Storage Act Inspection Report
<br />Date:
<br />December 08, 2022
<br /> Facility Address:
<br /> 809C SNEDEKER AVE, STOCKTON
<br /> Facility Name:
<br /> CANARY RENEWABLES CORP
<br />SUMMARY OF VIOLATIONS
<br />(CLASS I, CLASS II, or MINOR - Notice to Comply)
<br />RemarksItem #
<br /> 713 CFR 112.7(e), 112.8(c)(6) Failed to test or inspect each container for integrity based on industry standards.
<br />OBSERVATION: Facility failed to test each aboveground container for integrity based on industry standards, as
<br />discussed in the SPCC Plan on a regular schedule. Per SPCC Plan facility is using API653 and SP001 standards.
<br />Per SPCC Plan follows standard API653:
<br />- T-631 did not observe integrity test records on site
<br />- T-632 did not observe integrity test records on site
<br />- T-633 did not observe integrity test records on site
<br />Per SPCC Plan follows standard SP001:
<br />- T-615 did not observe integrity test records on site
<br />- T-616 did not observe integrity test records on site
<br />- T-617 did not observe integrity test records on site
<br />- T-618 did not observe integrity test records on site
<br />- T-100 did not observe integrity test records on site
<br />Tank integrity testing records were not observed for the following tanks. Standards for testing for the following tanks
<br />were not discussed in the SPCC plan and so is unclear what the correct standards to be followed for the below
<br />tanks are:
<br />- T-619 was last tested via API 653 on 10/23/2017 and, if following this standard, was next due by 10/23/2022
<br />- T-127 did not observe integrity testing records on site
<br />- Diesel Tank in the tank farm located in front of T-612, no integrity testing records were observed on site
<br />Additionally, section 2.5 in the SPCC Plan incorrectly cites code 40 CFR 112.7(d) for Aboveground Integrity
<br />Inspections. The correct citation is 112.8(c)(6) and 112.7(e).
<br />REGULATION GUIDANCE: REGULATION GUIDANCE: 112.8(c)(6) Test or inspect each aboveground container
<br />for integrity on a regular schedule and whenever you make material repairs. You must determine, in accordance
<br />with industry standards, the appropriate qualifications for personnel performing tests and inspections, the frequency
<br />and type of testing and inspections, which take into account container size, configuration, and design (such as
<br />containers that are: shop-built, field-erected, skid-mounted, elevated, equipped with a liner, double-walled, or
<br />partially buried). Examples of these integrity tests include, but are not limited to: visual inspection, hydrostatic
<br />testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other systems of non-destructive
<br />testing. You must keep comparison records and you must also inspect the container's supports and foundations. In
<br />addition, you must frequently inspect the outside of the container for signs of deterioration, discharges, or
<br />accumulation of oil inside diked areas. Records of inspections and tests kept under usual and customary business
<br />practices satisfy the 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 conduct the necessary integrity testing or inspections on T-631, T-632, T-633,
<br />T-615, T-616, T-617, T-618, T-100, T-127, T-619, and the diesel tank in the tank farm area based on industry
<br />standards, on a regular schedule, after making material repairs, using non-destructive testing, inspecting each
<br />container’s supports, foundations, and outside for signs of deterioration, discharges, or accumulation of oil inside
<br />FA0018706 PR0528437 SC001 12/08/2022
<br />EHD 28-01 Rev. 12/06/2021 Aboveground Petroleum Storage Act OIRPage 16 of 18
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