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The following is an itemized list of aboveground petroleum storage act violations that have not been addressed for VALLEY PACIFIC LODI PLANT & CARDLOCK as of October 22, 2019. Open violations from January 30, 2019 inspection Violation#706-Failed to provide and maintain adequate secondary containment. The SPCC plan states that APSA regulated 55 gallon drums within the warehouse have secondary containment provided by the building walls, doorway berms and floor. The floors appeared to be plywood which was not treated or coated. Small gaps where observed in the wood flooring. Staining and oil soaked in parts of the wood flooring was evident. Wood flooring and possibly the wood walls and berms do not appear to be sufficiently impermeable to the APSA regulated product in the building.Atransition box sump for the underground piping was observed within the secondary containment structure of the five 12,000 gallon tanks.A release from a tank may find its way into the suml Underground piping is double walled and some of the pipes within the sump did not have a boot or cover to prevent liquid from traveling into the interstitial space of the pipes and out of the secondary containment. The SPCC plan cal for the transition box sump to be drainage and point of accumulation for the underground pipes in the event of the primary pipe failure.This would require the interstitial space of the pipes to have an opening into the transition box sump and secondary containment for the 12,000 gallon tanks would be compromised.Although the underground piping may have been installed with a degree of decline to allow any liquid within the interstitial space to drain back tc the transition sump, the floor to the secondary containment structure seems to be higher than any part of the underground piping which would defeat the purpose of the decline in the pipe. Construct all bulk storage tank installations(except mobile refuelers and other non-transportation-related tank trucks) so that you provide a seconda means of containment for the entire capacity of the largest single container and sufficient freeboard to contain precipitation. You must ensure that diked areas are sufficiently impervious to contain discharged oil. Dikes, containment curbs, and pits are commonly employed for this purpose. You may also use an alternative system consisting of a drainage trench enclosure that must be arranged so that any discharge will terminate and be safely confined in a facility catchment basin or holding pond. Immediately provide adequate secondary containment for this and all other tanks at this facility. R This violation was corrected ® This violation will be corrected by(date): March 30 2020 ❑ Supporting documents included Describe actions taken or will be taken to correct violation:All 55 gallon product storage was removed from the warehouse 2/5/19. Remaining items to be corrected at the installation of new tanks Open violations from January 30, 2019 inspection Violation#715-Failed to regularly test liquid level sensing devices to ensure proper operation. The electronic liquid level gauges connected to a high level audible alarm and all overfill protection equipment are to tested during annual inspection, per the SPCC plan. Facility personnel stated that the overfill protection equipment had not been tested. Procedures of testing for these devices were not addressed in the Spill Prevention, Control, an Countermeasure (SPCC) plan. Liquid level sensing devices must be installed in accordance with CFR 112.8 and sh; 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). Page 2 of 3