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• • rt r pnr,jy The following is an itemized list of aboveground petroleum storage act violations that have not been addressed for GEMCO RIPON TRUCK PLAZA INC as of Apri124, 2017. Open violations from March 17, 2016 inspection Violation#601 -Plan that does not follow the sequence specified in this section lacks a cross-referencing section. The Spill Prevention, Control, and Countermeasure (SPCC) Plan does not follow the order or requirements in 40 CFR Part 112, and a cross-reference was not provided. If you do not follow the sequence specified in 40 CFR 112 for the Plan, you must prepare an equivalent Plan and supplement it with a section cross-referencing the location of requirements in 40 CFR 112 and the equivalent Plan. Immediately amend the SPCC Plan to include a cross-reference or to follow the required sequence. Violation#605- Plan failed to address facility layout, operations discharge prevention methods and containers. The storage capacity of the existing AST's is listed as 15,000 gallons in the general facility description section and as 20,000 gallons in the oil fuel potential discharge volumes table. The following shall be addressed in the Spill Prevention, Control, and Countermeasure(SPCC) Plan: -type of oil in each fixed container and its storage capacity. For mobile or potable containers, the type of oil and storage capacity for each container or an estimate of the potential number of mobile or portable containers, the types of oil, and anticipated storage capacities -discharge prevention measures including procedures for routine handling of products -discharge or drainage controls such as secondary containment, equipment, and procedures for the control of a discharge -countermeasures for discharge discovery, response, and cleanup - methods of disposal of recovered materials -contact list and phone numbers for the facility response coordinator, National Response Center, cleanup contractors, and all appropriate Federal, State, and local agencies. Immediately amend the SPCC Plan to include all required information. Violation#612 -Failed to provide secondary containment,diversionary structures, or equipment to prevent discharge. Several large cracks were noted in the secondary containment structure that surrounds the four existing ASTs These cracks were also observed during the 2015 facility inspection. No discussion on the adequacy of the secondary containment was provided in the reviewed SPCC plan dated October 2015. A facility shall provide appropriate containment and/or diversionary structures or equipment to prevent a discharge. The entire containment system, including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system will not escape the containment system before cleanup occurs. Immediately provide adequate secondary containment for all aboveground petroleum storage containers larger than 55 gallons. Submit proof of correction to the EHD. Violation#618 - Failed to conduct inspections or maintain records for 3 years. Copies of inspection and testing records were not found on site. Visible seem separation was noted on at least one of the bulk storage tanks (Tank 1). Mr. Johal indicated that their plan is to use all four tanks and that they don't plan on permanently closing any of them at this time. Inspections and tests must be conducted in accordance with the written procedures developed in the Spill Prevention, Control, and Countermeasure(SPCC) Plan. Records of these inspections and tests must be signed by the appropriate supervisor or inspector and kept on site with the SPCC Plan for a period of three years. Immediately locate a copy of all inspection and testing records for the last three years, maintain them on site, and submit copies to the EHD. Violation #619 - Failed to train personnel on discharge prevention. Oil handling personnel were not trained. At a minimum, oil handling personnel shall be trained in the operation and maintenance of equipment to prevent discharges; discharge procedure protocols; applicable pollution control laws, rules, and regulations; general facility operations; and the contents of the Spill Prevention, Control, and Countermeasure Plan. Immediately provide this training to all oil handling personnel and submit a copy of the training log to the EHD. Page 1 of 6