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San Joaquin County Environmental Health Department 1868 East Hazelton Avenue, Stockton, California 95205-6232 Telephone: (209) 468-3420 Fax: (209) 468-3433 Web: www.sjgov.org/ehd Aboveground Petroleum Storage Act Inspection Report Facility Name: Facility Address: Date: Penske Truck Leasing Co., LF 3663 Petersen Rd, Stockton March 20 2015 SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) Item # Remarks 605 CFR 112.7(a)(3) Plan failed to address facility layout, operations discharge prevention methods and containers. The Plan did not include the drums of waste oil and oil/water separator sludge in the hazardous waste storage area. The Plan did not discuss disposal of recovered materials. The contact list did not include the San Joaquin County Environmental Health Department. The Plan did not discuss the concrete containment area for piping located between the two 10,000 gallon diesel tanks. The following shall be addressed in the Spill Prevention, Control, and Countermeasure (SPCC) Plan: - type of oil in each fixed container and it's storage capacity. For mobile or potable containers, the type of oil and storage capacity for each container or an estimate of the potential number of mobile or portable containers, the types of oil, and anticipated storage capacities - discharge prevention measures including procedures for routine handling of products - discharge or drainage controls such as secondary containment, equipment, and procedures for the control of a discharge - countermeasures for discharge discovery, response, and cleanup - methods of disposal of recovered materials - contact list and phone numbers for the facility response coordinator, National Response Center, cleanup contractors, and all appropriate Federal, State, and local agencies. Immediately amend the SPCC Plan to include all required information. This is a Class II violation. 608 CFR 112.7(b) Plan failed to include a description of potential equipment failure or provide equivalence. Potential equipment failure and the resulting spill for drums of waste oil and oil/water separator sludge in the hazardous waste storage area was not addressed in the Spill Prevention, Control, and Countermeasure (SPCC) Plan. The SPCC Plan must include a prediction of the direction, rate of flow, and total quantity of oil which could be discharged from the facility as a result of major equipment failure. Immediately amend the SPCC Plan to include this information and submit a copy of the revision to the EHD, or provide equivalence as allowed by 40 CFR 112.7(a)(2). This is a minor violation. 713 CFR 112.8(c)(6) Failed to perform scheduled tank tests and inspections by appropriately qualified personnel. The SPCC Plan states that integrity testing is to be conducted every 20 years for the 10,000 gallon diesel tanks, with the first test to take place after the Plan was written and implemented. No integrity testing records were provided at the time of inspection. 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 conduct the necessary testing and submit a copy of the test results to the EHD, or provide equivalence as allowed by CFR 112.7(a)(2). This is a repeat violation, Class Il. Received by Inspector: Phone: Date: (initial): STACY RIVERA, Senior REHS (209) 468-3440 03/20/2015 Page 4 of 5