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Environmental Health Department AMENDED 9/12/2024 CP22 - AST Non-Qualified Inspection Report Date: September 03, 2024 Facility Address: 2050 E SIKORSKY ST, STOCKTON Facility Name: JC AIR ACADEMY INC SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) RemarksItem # 1.4 Containment, discussed the concrete berm as general containment that is to contain any overfill or hose failure. While on site, drilled holes were observed in the concrete berms. Per Lupe Gonzalez, the holes were drilled into the concrete berm to release the standing water left after a rain storm. By drilling these holes into the concrete berm, the general containment have been compromised. REGULATION GUIDANCE: (c) Provide appropriate containment and/or diversionary structures or equipment to prevent a discharge as described in § 112.1(b), except as provided in paragraph (k) of this section for qualified oil-filled operational equipment, and except as provided in § 112.9(d)(3) for flowlines and intra-facility gathering lines at an oil production facility. CORRECTIVE ACTION: Immediately ensure that the SPCC plan addresses the general containment, diversionary structures, and equipment in use at the facility to prevent discharge, including typical failure mode and most likely quantity of potential discharge. Submit proof of correction to the EHD. This is (Class 2) Violation. Code of Fed Regulations 112.7(i) 4010040 - Documented evaluation of field-constructed tanks for risk of discharge due to brittle fracture. OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) failed to discuss the brittle fracture evaluation of field-constructed aboveground tanks after tank repair, alteration, reconstruction, or change in service that might affect the risk of discharge , and take appropriate action. The cross-reference page listed brittle fracture to be found on page 10 however page 10 did not contain brittle fracture information. REGULATION GUIDANCE: (i) If a field-constructed aboveground container undergoes a repair, alteration, reconstruction, or a change in service that might affect the risk of a discharge or failure due to brittle fracture or other catastrophe, or has discharged oil or failed due to brittle fracture failure or other catastrophe, evaluate the container for risk of discharge or failure due to brittle fracture or other catastrophe, and as necessary, take appropriate action. CORRECTIVE ACTION: Immediately ensure that the SPCC plan addresses the perform the brittle fracture evaluation of 12,000 gallon tank field-constructed aboveground tanks after tank repair, alteration, reconstruction, or change in service that might affect the risk of a discharge , and take appropriate action. Submit proof of correction to the EHD. This is (Class 2) Violation. 38 Code of Fed Regulations 112.7(i), 25270.4.5(a) 4030016 - Brittle fracture evaluation of field-constructed aboveground tanks performed. OBSERVATION: Facility failed to perform a brittle fracture evaluation of field-constructed aboveground tanks after tank repair, alteration, reconstruction, or change in service that might affect the risk of discharge , and take appropriate action. The following tanks were not evaluated: 12,000 gallon tank, 55 gallon drums containing oily solids REGULATION GUIDANCE: (i) If a field-constructed aboveground container undergoes a repair, alteration, reconstruction, or a change in service that might affect the risk of a discharge or failure due to brittle fracture or other catastrophe, or has discharged oil or failed due to brittle fracture failure or other catastrophe, evaluate the container for risk of discharge or failure due to brittle fracture or other catastrophe, and as necessary, take appropriate action. 39 FA0023280 PR0544293 SC001 09/03/2024 EHD Rev. 12/06/2021 CP22 - AST Non-Qualified OIRPage 6 of 9 1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD