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SANJ O 1` Q U I `IA,II, Environmental Health Department COUNTY Aboveground Petroleum Storage Act Inspection Report Facility Name: Facility Address: Date: VALLEY PACIFIC LODI PLANT&CARDLOCK 930 E VICTOR RD, LODI January 30, 2019 Other Violations 4030 See below Unlisted Operations/Maintenance violation ❑V ❑R ❑COS 4040 See below Unlisted Release/Leaks/Spills violation ❑V ❑R ❑COS 4050 See below Unlisted Abandonment/Illegal Disposal/Unauthorized Treatment violation ❑V ❑R ❑COS SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Notice to Comply) Item# Remarks 203 CFR 112.3 Failure to implement the SPCC Plan. The SPCC plan calls for monthly inspections of the transition sump box located in the northeast corner of the 12,000 gallon diesel secondary containment.The SPCC plan calls for the visual inspection to identify the presence of oil accumulations which would indicate potential underground piping failure. Facility personnel stated that the transition sump is not being inspected as per the SPCC plan requirements.The owner or operator or an onshore or offshore facility subject to this section must prepare in writing and implement a Spill Prevention Control and Countermeasure Plan (hereafter"SPCC Plan"or"Plan")," in accordance with§ 112.7 and any other applicable section of this part. Immediately implement the SPCC plan as written or amend the plan to reflect actual procedures as the facility. This is a minor violation. 626 CFR 112.7(h)(1)Loading/unloading rack containment system not adequate to contain spill. Facility has an area that meets the definition of a loading rack and secondary containment is not sufficient to contain the maximum capacity of the largest single compartment of a truck loaded at the facility, per the SPCC plan. Where loading/unloading rack drainage does not flow into a catchment basin or treatment facility designed to handle discharges, use a quick drainage system for tank car or tank truck loading/unloading racks.You must design any containment system to hold at least the maximum capacity of any single compartment of a tank car or tank truck loaded or unloaded at the facility. Provide an interlocked warning light or physical barrier system,warning signs, wheel chocks or vehicle brake interlock system in the area adjacent to a loading/unloading rack,to prevent vehicles from departing before complete disconnection of flexible or fixed oil transfer lines. 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. Note: The SPCC plan has identified the non-compliance and has a proposed secondary containment with sufficient capacity to contain a minimum of 1,800 gallons by May 30, 2019. This is a Class II violation. 705 CFR 112.8(c)(1)Container not compatible with oil stored and/or storage conditions. The SPCC plan states that the five, 12,000 gallon diesel storage tanks are re-purposed Underground Storage Tanks(UST)being used as Aboveground Storage Tanks(AST). The SPCC plan states that the ASTs are constructed as LISTS and are not compatible as aboveground tanks. Containers shall be compatible with the material stored and the conditions of storage such as pressure and temperature. Immediately transfer the contents to a compatible container, or provide equivalence as allowed by CFR 112.7(a)(2). Note: The SPCC plan has identified the non-compliance and has a proposed replacing the tanks with approved tanks by January 2020. This is a Class II violation. FA0005584 PR0528063 SCO01 01/30/2019 EHD 28-01 Rev.09/27/2018 Page 4 of 6 Aboveground Petroleum Storage Act OIR 1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjcehd.com