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Environmental Health Department Aboveground Petroleum Storage Act Inspection Report Date: November 27, 2018 Facility Address: 3663 Petersen Rd, Stockton Facility Name: Penske Truck Leasing Co., LP Other Violations 4030 □ V □ R □ COSUnlisted Operations/Maintenance violation See below 4040 □ V □ R □ COSUnlisted Release/Leaks/Spills violation See below 4050 □ V □ R □ COSUnlisted Abandonment/Illegal Disposal/Unauthorized Treatment violation See below SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) RemarksItem # 301 CFR 112.5(a) Failed to amend Plan as necessary. The SPCC plan describes testing procedures for Underground Storage Tanks (UST) and the facility does not have UST at the facility. The SPCC plan also discusses integrity tests for buried piping on an annual basis. The two 10,000 diesel tanks appear to be permanently manifolded, and the SPCC plan does not address the potential of a 20,000 gallon release. 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. Note: Permanently manifolded tanks are tanks that are designed, installed, or operated in such a manner that the multiple containers function as a single storage unit (67 FR 47122, July 17, 2002). Accordingly, the total capacity of manifolded containers is the design capacity standard for the sized secondary containment provisions (plus freeboard in certain cases). This is a minor violation. 604 CFR 112.7(a)(3)(i) Plan failed to include oil type and storage capacity for each container. The SPCC plan does not provide an estimate of the potential number of mobile or portable containers. There were a total of six 55 gallon drums observed at the facility. You must address in your Plan, the type of oil in each fixed container and its storage capacity. For mobile or portable containers, either provide the type of oil and storage capacity for each container or provide an estimate of the potential number of mobile or portable containers, the types of oil, and anticipated storage capacities. Amend the SPCC plan and submit a copy for review by the Environmental Health Department. This is a minor violation. 609 CFR 112.7(a)(3vi), 112.7(a4) Plan failed to adequately contain procedures for reporting a discharge. The Spill Prevention, Control, and Countermeasure (SPCC) Plan does not provide information and procedures to enable a person to adequately report a discharge. The name and phone number of the local Certified Unified Program Agencies (CUPA), in this case the San Joaquin County Environmental Health Department, is not provided in the SPCC plan. If a response plan was not submitted to the Regional Administrator, this information must be included in the SPCC Plan. You must include in the SPCC plan a contact list and phone numbers for the facility response coordinator, National Response Center, cleanup contractors with whom you have an agreement for response, and all appropriate Federal, State, and local agencies who must be contacted in case of a discharge Immediately amend the SPCC Plan to include this information and submit a copy of the revision to the EHD. This is a minor violation. Page 4 of 5 FA0010627 PR0517463 SC001 11/27/2018 EHD 28-01 Rev. 09/27/2018 Aboveground Petroleum Storage Act OIR 1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjcehd.com