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APSA Inspection December 5, 2018 STATEMENT OF CORRECTIVE ACTIONS APSA Inspection Report Item #303 - Failed to have a PE certify technical amendments The Professional Engineer(PE) certification is dated 12/28/2015 with an addendum attachment certified by a PE on 02/17/2017 addressing secondary containment. The Spill Prevention, Control, and Countermeasure (SPCC) Plan was amended on 08/19/2016 to include the following changes: demolition and removal of what is referred to as tank#20, which at the time stored gasoline. These amendments are technical changes, requiring a PE certification within six months of amendment. A technical amendment is a change to the facility, tanks, procedures, materials, construction, design, or maintenance that materially increases or decreases the facility's potential for oil discharge. Immediately obtain a complete PE certification for the facility's SPCC plan. Submit a copy of the completed, certified SPCC plan to the EHD for review. The Technical Amendment February 2017 addresses the demolition of Tank 20 in August 2016 and the resulting adequacy of the secondary containment. A modification of the secondary containment wall for the tank farm was completed in August 2018 to accommodate the construction of new storage tanks and address the containment volume deficiency. The upcoming update to the SPCC plan will be submitted to the SJCEHD for review by March 2019. APSA Inspection Report Item #626 - Load_inq/unloading rack containment system not adequate to contains ill The SPCC plan describes secondary containment for the loading rack as a 6,000-gallon underground tank. The tank is described in the SPCC plan as also having the capability of being pumped into tank#420. The SPCC plan describes the maximum capacity of any single compartment of a truck loaded to be 5,000 gallons. Facility personnel stated that trucks with a single compartment of over 9,000 gallons have been loaded in the past. It was also stated by facility personnel that the underground 6,000-gallon tank has an automatic pump, activated by a float when the level of the tank reaches approximately 24 inches, which transfers the contents to tank#420. This is not addressed in the SPCC plan and the capacity of storage tank #420 is not discussed as secondary containment. Tank#420 is described as a "transmix"storage tank in the SPCC plan. The 6,000-gallon underground tank also receives liquid from other drains throughout the facility. A facility must provide sufficient secondary containment capable of holding at least the maximum capacity of any single compartment of a tank car or truck loaded or unloaded at the facility. Immediately begin implementing the necessary procedures, as described in the Spill Prevention, Control, and Countermeasure Plan, to provide sufficient secondary containment in all tank car and tank truck loading and unloading areas. Effective January 1, 2019, the Stockton Terminal truck rack will be limited to loading single compartments with a maximum volume of 6,000 gallons. Trucking companies with the larger-capacity trailers have been notified of the new size limit. A sign notifying drivers of the size limit has been posted at the truck rack.