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SKJ O A Q U I N Environmental Health Department COUNTY— Aboveground Petroleum Storage Act Inspection Report Facility Name: Facility Address: Date: DART CONTAINER CORP 1 1400 E VICTOR RD, LODI August 13, 2018 SUMMARY OF VIOLATIONS (CLASS I,CLASS II, or MINOR-Notice to Comply) Item# Remarks 301 CFR 112.5(a) Failed to amend Plan as necessary. 55 gallon drums of gear oil, totaling up to 165 gallons, are no longer kept at the facility's truck garage based on statements from plant manager. The gear oil is still in the SPCC plan. The Spill Prevention, Control, and Countermeasure (SPCC) Plan must be amended when there is a change in the facility design, construction, operation, or maintenance that materially affects its potential for a discharge, within 6 months of the change, and implemented as soon as possible, not later than 6 months following preparation of the amendment. Immediately make all necessary amendments to the SPCC Plan to accurately represent the procedures and policies currently in place at the facility. This is a minor violation. 623 CFR 112.7(g) Plan failed to address security of site and valves, lock out/tag out, and lighting. The Spill Prevention, Control, and Countermeasure (SPCC) Plan did not include discussion of appropriateness of security lighting to both prevent acts of vandalism and assist in the discovery of oil discharges. The SPCC Plan must include descriptions of how you secure and control access to the oil handling, processing & storage areas, secure master flow& drain valves, prevent unauthorized access to starter controls on oil pumps, secure out-of-service and loading/unloading connections of oil pipelines, and address the appropriateness of security lighting to both prevent acts of vandalism and assist in the discovery of oil discharges. Immediately update the SPCC Plan to include all of the required security information, or provide equivalence as allowed by 40 CFR 112.7(a) (2). This is a Class II violation. 710 CFR 112.8(c)(6) Plan failed to adequately discuss procedures to test or inspect each container for integrity. The inspection frequency and testing methods described in the plan do not reference any industry standards. Current inspections and tests are being conducted as described in the SPCC plan. Each aboveground container shall be tested and inspected for integrity on a regular schedule and whenever repairs are made. The qualifications of personnel performing tests and inspections, frequency and type of testing and inspections that take into account container size, configuration, and design shall be determined in accordance with industry standards. Examples of these integrity tests include, but are not limited to: visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other systems of non-destructive testing. Comparison records and other records of inspections and tests must be maintained on site. Immediately include an industry standard in the SPCC plan for the inspections or testing, or provide equivalence as allowed by CFR 112.7(a)(2). This is a Class II violation. Overall Inspection Comments: Complete and submit a copy of the Return to Compliance Certification form to the EHD with a statement documenting the corrective actions that have been or will be taken for each violation, and any supporting paperwork, by September 12, 2018. Please be aware as of January 1, 2013, all businesses are required to submit all new (or any changes to existing) Aboveground Petroleum Storage Act (APSA) information online to the California Environmental Reporting System (CERS) at http://cers.calepa.ca.gov in addition to any other relevant activities and required FA0003704 PR0529108 SCO01 08/13/2018 EHD 28-01 Rev.11/07/2017 Page 4 of 5 Aboveground Petroleum Storage Act OIR 1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjcehd.com