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requirements. Since the age of the tanks cannot be determined,per the SPCC plan,integrity tests would have to be conducted immediately,per the selected industry standard. Violation 622—Failure to conduct spill prevention briefing for oil handling personnel: Statement received"Spill prevention briefing is conducted as part of the SPCC training. (See attached training log and outline)." - Page 19 of the SPCC plan,section 5.4.3 titled"Discharge Prevention Briefings" states that"Operations personnel that handle oil-filled equipment or oil containers will take part in discharge prevention briefings at least once a year to ensure adequate understanding of the SPCC Plan." and " Records of these briefings,identifying the topics of discussion, will be maintained as documentation in Appendix G,or an equivalent retrievable paper or electronic recordkeeping system for at least 3 years." The record for appendix G is blank and an equivalent was not submitted.The"Safety Tailgate Meetings" sheet does not meet the once a year requirement,it is dated 12/10/2015. Violation 710—Plan failed to adequately discuss procedures to test or inspect each container for integrity. Statement received: "Visual inspections are conducted weekly and monthly per SPCC. See violation 618. In addition the plan only states that inspections will be conducted monthly. Violation 715—Failed to regularly test liquid level sensing devices to ensure proper operation Statement received"Liquid level sensors previously tested by in-house maintenance crew. Beginning June 2018 liquid level sensors will be tested by third-part test agent Tanknology, annually thereafter." Page 22 of the SPCC plan,section 5.11.7 titled"Good Engineering Practice of Containers"states" ASTs are equipped with high liquid level alarms. Liquid level measuring devices are used to determine the fluid level in the storage tanks prior to filling to prevent overfills.Additionally,the tank trucks that fill the storage tanks with fuel are equipped with fast response gauges that show how much fuel is being dispensed. BMPs for all oil truck loading/unloading operations are implemented(refer to Section 5.6)." The regulations state: "...You must regularly test liquid level sensing devices to ensure proper operation." The plan does not address the regular testing of liquid level sensing devices to ensure proper operation. Procedures and frequency of testing for the liquid level sensing devices needs to be addressed in the plan. Violation 724—Failed to conduct integrity and leak testing on buried piping any time it is worked on. Statement received: " No work has been performed since its construction at which point Filner Construction would have performed pre and post hydrostatic integrity testing on the lines. We do not have those records,however piping at this facility has secondary containment and is continuously monitored.." The regulations state the following,in part: "...You must also conduct integrity and leak testing of buried piping at the time of installation,modification construction,relocation,or replacement." The plan does not address this requirement in the SPCC plan. Feel free to contact me with any questions. Thank you, Cesar Ruvalcaba San Joaquin County Environmental Health Department Environmental Health Specialist 1868 East Hazelton Ave Stockton,CA 95205 4