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San Joaquin County Environmental Health Department DEC 0 4 2015 1868 East Hazelton Avenue, Stockton, California 95205-6232 Telephone: (209) 468-3420 Fax: (209) 468-3433 Web: www,sj oq v_org/ehd HEALTH DEPAftiQ!wground Petroleum Storage Act Inspection Deport Facility Name: Facility Address: Date: Lawrence Livermore National Lab - Site 300 15999 W CORRAL HOLLOW RD Tracy September 30 2015 SUMMARY OF VIOLATIONS (CLASS 1, CLASS II, or MINOR- Notice to Comply) Item # Remarks 713 CFR 112.8(c)(6) Failed to perform scheduled tank tests and inspections by appropriately qualified personnel. The Diala oil tank for building 801 was not tested for integrity. According to the SPCC Plan, visual inspections will be used for integrity testing unless problems are detected. The monthly tank inspection records being maintained by Mr. Tom McWilliams, the building APSA "operator", have marked for many months that there is liquid visible in the secondary containment or berm and that the exterior coating is bubbling, cracked, or damaged. When questioned about what kind of "problems" noted during the monthly inspections would trigger additional integrity testing, Mr. McWilliams stated that he monitors the tank inventory levels and would take action if the levels indicated a loss of product. 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. CFR 112.8(c)(8)(v) Failed to regularly test liquid level sensing devices to ensure proper operation. 717 Liquid level sensing devices have not been tested. According to Mr. Tom McWilliams, the APSA "operator" at building 801, the liquid level sensing devices are looked at for determining inventory levels, but are not tested or checked for accuracy. Procedures and frequency of testing for these devices were not addressed in the Spill Prevention, Control, and Countermeasure (SPCC) plan. Liquid level sensing devices must be installed in accordance with CFR 112.8 and shall be regularly tested to ensure proper operation. Immediately conduct all necessary testing of liquid level sensing devices, or provide equivalence as allowed by CFR 112.7(a)(2). This is a Class II violation. Overall Inspection Comments: Complete and submit a copy of the Return to Compliance Certification form to the EHD with a statement documenting the corrective actions that have been or will be taken for each violation, and any supporting paperwork, within 30 days of receiving this report. The inspection was conducted on the following dates: September 30, 2015 October 1, 2015 October 5, 2015 October 15, 2015 October 19, 2015 The final checklist was provided to John Scott on October 19, 2015. The report was completed on October 26, 2015. Received by (initial)mo��d Inspector: STACY RIVERA, Senior REHS Phone: (209) 468-3440 Date: 09/30/2015 Page 5 of 6