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<br />9171 9690 0935 0152 0948 31
<br />May 6, 2017
<br />BUCKEYE TERMINALS LLC
<br />Re: BET STOCKTON TERMINAL
<br />2700 W. Washington St.
<br />Stockton, CA 95203
<br />ILE OP
<br />Environmental Healt epa men
<br />Linda Turkatte, REHS, Director
<br />Kasey Foley, REHS, Assistant Director
<br />PROGRAM COORDINATORS
<br />Robert McClellon, REHS
<br />Jeff Carruesco, REHS, RDI
<br />Rodney Estrada, REHS
<br />Willy Ng, REHS
<br />Muniappa Naidu, REHS
<br />RE: BET STOCKTON TERMINAL
<br />2700 W. Washington St.
<br />Stockton, CA 95203
<br />On January 07, 2016, Stacy Rivera of the San Joaquin County Environmental Health Department (EHD)
<br />performed a routine aboveground petroleum storage act inspection at the above referenced site.
<br />An inspection report was issued identifying information to be submitted to bring this site into compliance.
<br />This information was required to be submitted by February 6, 2016. A follow up was received by email on
<br />February 5, 2016, with the subject "Buckeye Terminals, LLC Stockton Terminal Return to Compliance
<br />Certification and Cover Letter," and by emails on February 6, 2016 with the subjects "RE: Buckeye
<br />Terminals, LLC Stockton Terminal Compliance Certification and Cover Letter Enclosures Item #613," "RE:
<br />Buckeye Terminals, LLC Stockton Terminal Compliance Certification and Cover Letter Enclosures Item
<br />#614," "RE: Buckeye Terminals, LLC Stockton Terminal Compliance Certification and Cover Letter
<br />Enclosures Item #713," and "RE: Buckeye Terminals, LLC Stockton Terminal Compliance Certification
<br />and Cover Letter Enclosures Item #726,". The information submitted did not fully address the issues
<br />noted in the inspection report, resulting in a non-compliant status for this facility.
<br />Note: All EHD staff time associated with failing to comply, including the issuance of this letter,
<br />may be billed at the current hourly rate ($139). Failure to submit the completed information
<br />immediately may result in a re -inspection, additional violations, and/or further legal action.
<br />The missing and incomplete information includes:
<br />• The monthly inspection form submitted is titled "Monthly In -Service, Vertical, Aboveground,
<br />Atmospheric Tank Inspection Form" and is dated 11/14. According to the inspection report, this
<br />form "does not contain everything that the facility SPCC plan contains in Figure 4.1-2-Inspectior
<br />Procedures which itemizes what should be inspected during the routine visual inspection and
<br />annual inspections."
<br />At a minimum, oil handling personnel shall be trained in the operation and maintenance of
<br />equipment to prevent discharges; discharge procedure protocols; applicable pollution control
<br />laws, rules, and regulations; general facility operations; and the contents of the SPCC Plan.
<br />Discharge prevention briefings for oil handling personnel must be scheduled and conducted at
<br />least once a year to assure adequate understanding of the SPCC Plan for that facility. Such
<br />briefings must highlight and describe known discharges or failures, malfunctioning components,
<br />and any recently developed precautionary measures. According to the corrective action
<br />statement submitted, the training received by personnel was in the form of "quarterly spill drill
<br />notifications" and an annual "Spill Management Team Tabletop Exercise." The training records
<br />submitted documented the spill drills and tabletop exercises, but did not document SPCC training
<br />and did not address all of the above SPCC training requirements.
<br />1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjcehd.com
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