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SAN JOAQUIN COUNTY ENVIRONMENTAL HEALTH DEPARTMENT 600 East Main Street, Stockton, California 95202-3029 Telephone:(209)468-3420 Fax:(209)468-3433 Web:www.sjgov.org/ehd/unitiii.htmi ABOVEGROUND PETROLEUM STORAGE ACT (APSA) PROGRAM INSPECTION REPORT CONTINUED Facility Inland Paperboard & Packs Facility 400 West Valpico Road, Tracy DateInspe: Packaging on Name: p 9 g Address: Sep 7, 2011 VIOLATIONS # C1 C2 M Code Section HSC=CA Health and Safety Code;CFR=Code of Federal Regulations C1=Class 1 violation;C2=Class 2 violation;M=Minor violation General Requirements for SPCC Plans(continued) 509 CFR 112.7(a)(3)(v) SPCC Plan failed to address disposal methods for recovered materials 510 CFR 112.7(a)(3)(vi) SPCC Plan failed to include required contact list and phone numbers of the facility's response coordinator,cleanup contractors,and agencies to notify in case of discharge 511 CFR 112.7(a)(4) Failed to provide information and procedures to enable a person to adequately report discharges if a response plan was not submitted to the Regional Administrator RA 512 CFR 112.7(a)(5) Failed to organize emergency procedures for discharges in a readily useable way if a response plan was not submitted to the RA 513 X CFR 112.7(b) SPCC Plan failed to include a description of potential equipment failure(direction,flow rate,quantity), or provide equivalence as allowed by CFR 11 2.7 a 2 514 CFR 112.7(c) Failed to provide secondary containment and/or diversionary structures that are capable of containing discharge from primary containment until it is cleaned u Failed to provide explanation,conduct periodic integrity testing of containers and/or periodic integrity 515 CFR 112.7(d) and leak testing for valves and piping if containment or discharge prevention structures were determined to be impracticable on an SPCC Plan or sections of one that is PE certified If a response plan was not submitted to the RA,and containment or discharge prevention structures 516 CFR 112.7(d) were determined to be impracticable,the SPCC Plan failed to provide: (1)an oil spill contingency plan; 2 written commitment of manpower,equipment,materials to control and remove oil discharge 517 X CFR 112.7(e) Failed to conduct inspections and tests in accordance with written procedures and/or maintain signed records of inspections and tests as required by the facility's SPCC Plan on site for 3 years 518 X CFR 112.7(f) Failed to:(1)train personnel on discharge prevention;(2)designate a person to be accountable for dischargeprevention;or 3 schedule prevention discharge prevention briefings at least annual) Failed to describe how the oil handling,processing and storage areas are secured and controlled; how 519 X CFR 112.7(g) master flow and drain valves are secured; how unauthorized access to starter controls on oil pumps are prevented;how out-of-service and loading/unloading connections are secured;the appropriateness of security lighting;or provide equivalence as allowed by CFR 112.7(a)(2) Failed to provide sufficient secondary containment capacity for tank car or tank truck loading and 520 CFR 112.7(h)(1) unloading area if drainage area is not designed to flow into a catchment basin designed to handle discharges 521 CFR 112.7(h)(2) Failed to provide methods to prevent vehicles from departing loading and unloading areas before complete disconnection of transfer lines or provide equivalence as allowed by CFR 11 2.7 a 2 Failed to inspect lower-most drains and all outlets of vehicles for discharge prior to filling and departure 522 CFR 112.7(h)(3) and take appropriate measures to prevent liquid discharge while in transit or provide equivalence as allowed by CFR 11 2.7 a 2 Failed to evaluate field-constructed container for risk of discharge or failure due to brittle facture or 523 CFR 112.7(i) other catastrophe after repair,alteration,reconstruction,or change in service,or provide equivalence as allowed by CFR 11 2.7 a 2 SPCC Plan failed to include a complete discussion of conformance to discharge prevention and 524 CFR 112.70) containment procedures as listed in part 112 and any applicable more stringent State rules,regulations, and guidelines If a response plan was not submitted to the RA,and secondary containment is not provided for qualified 525 CFR 112.7(k)(2) oil-filled equipment,the SPCC Plan failed to:(i)establish and document procedures for inspection or a monitoring program to detect equipment failure and/or discharge;(ii)provide oil spill contingency plan and/or written commitment of manpower,equipment,materials to control and remove oil discharge SPCC Plan Requirements for Onshore Facilities(excluding production facilities) 601 CFR 112.8(b)(1) Failed to prevent discharge into the drainage system from diked storage areas and/or inspect accumulation prior to drainage,or provide equivalence as allowed by CFR 112.7(a)(2) 602 CFR 112.8(b)(2) Failed to use manual,open-and-closed design valves for the drainage of diked areas,or provide equivalence as allowed by CFR 112.7(a)(2) Failed to design facility drainage system from undiked areas to flow into appropriate ponds, lagoons,or 603 CFR 112.8(b)(3) catchment basins(in areas not subject to flooding)designed to retain oil or return it to the facility,or provide equivalence as allowed by CFR 112.7(a)(2) Failed to equip the final discharge of all ditches with a diversion system that would retain oil in the 604 CFR 112.8(b)(4) facility in the event of an uncontrolled discharge if CFR112.8(b)(3)is not met,or provide equivalence as allowed by CFR 112.7(a)(2) Inspector Reved By: Title Thuy Tran (209) 468-8257 t� EHD 28-02 Rev 09/01/11 Page 2 APSA INSPECTION REPORT