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S i N J O A Q U 14 Ill , Environmental Health Department COUNTY Aboveground Petroleum Storage Act Inspection Report Facility Name: Facility Address: 1 Date: PROFLEET TRUCK LUBE 15453 N THORNTON RD, LODI November 29, 2018 SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) Item # Remarks 706 CFR 112.8(c)(2) Failed to provide and maintain adequate secondary containment. The two 120 gallon new oil tanks, 200 gallon diesel tank, 280 gallon new oil tank and 240 gallon new oil tanks were observed with insufficient secondary containment. The SPCC plan describes secondary containment for the two 120 gallon and 200 gallon tanks as being provided by concrete floor. The secondary containment for the 280 gallon and 240 gallon tanks is not addressed in the SPCC plan. Although some of the drums were near a sloped portion of concrete flooring, the slope lead to an open drain. Facility personnel stated the drain led to an oil/water separator. This is not discussed in the SPCC plan. in some instances tanks were located next a wall and not far from rollup doors. Water from the rain at the time seemed to be coming in under the closed roll up doors, this would allow oil to escape the building the same way.. All bulk storage tanks must be provided with a secondary means of containment for the entire capacity of the tank and sufficient freeboard to contain precipitation. Immediately provide sufficient secondary containment for this and all other tanks at this facility. 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 SPCC plan states on page 9 that non-destructive integrity evaluations are not performed an AST's. It is stated that facility management has deemed that routine AST inspections are sufficient for identifying potential spills. The SPCC plan also stated that inspections are conducted per STI SP -001 standards, which require integrity testing based on the size and condition of the tanks. Table 9 of the SPCC plan contains a frequency of inspections per STI SP -001 standards but contains a note that the frequency is based on implementation of a scheduled inspection/testing program, which is only initialized after shell rpairs are conducted or as directed by the local enforcement agency. This frequency of inspections deviates from the STI-SP001 standard. 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. Amend the SPCC plan to comply with industry standards, or provide equivalence as allowed by CFR 112.7(a)(2). Note: A tank and secondary assessment was conducted on 8/02/2010 for all 8,000 gallon tanks and for the 4,000 gallon tank. this assessment was performed by a professional engineer and not a certified STI SP -001 inspector. At that time the tanks were noted as being 6 years old. This is a Class II violation. FA0015491 PR0523476 SCO01 11/29/2018 EHD 28-01 Rev. 09/27/2018 Page 5 of 6 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