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Ford Construction Company, Inc. 'A6�L Cluff Maintenance Yard FORD 500 N. Cluff Avenue Mlll Lodi, California 95240 COMPANY, INC Item#710: CFR 112.8(c)(6) Plan failed to adequately discuss procedures to test or inspect each container for integrity. Summary of Violation: • The SPCC plan does not discuss the industry standard to be used or the qualifications for the inspectors. • Environmental Equivalence allowed by Petroleum Marketers Association of America, et al, v. Michael 0 . Leavitt and United States Environmental Protection Agency, Civil Action No. 02- 02249 settlement agreement for the 10,000 gallon tank is discussed. • This environmental equivalence is not used for the other tanks in the SPCC plan. • Furthermore,the US EPA recommends the use of an industry standard be used for the visual inspections when using the environmental equivalence. • 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 Class II violation. Corrective Actions To Be Taken For Each Violation: 1. Will revise the SPCC Plan to include the above referenced information as stated in Item #710. 2. A copy of the revised SPCC Plan will be sent to CUPA. Page 5 of 5