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DEFENSE LOGISTICS AGENCY <br /> ILA INSTALLATION SUPPORT AT SAN JOAQUIN <br /> P.O. BOX 960001 <br /> STOCKTON, CALIFORNIA 95296-0001 <br /> February 21, 2019 <br /> Cesar Ruvalcaba, REHS <br /> San Joaquin County Environmental Health Department <br /> 1868 E. Hazelton Ave. <br /> Stockton, CA 95205 <br /> Mr. Ruvalcaba, <br /> DLA Installation Management-Operations San Joaquin, Environmental Office, DF-FJEE has reviewed <br /> the San Joaquin County Environmental Health Department's Aboveground Petroleum Storage Act <br /> (APSA) Inspection Report dated January 24, 2019. The following is our comment in response to the three <br /> violations noted on your report. Routine Inspection was conducted for Program 2832-AST FAG 10 K- <br /> <1=100 K GAL CUMULATIVE. Our response to the inspection report findings are as follows: <br /> I. #203 CFR 112.3 Failure to implement the SPCC Placa (minor violation). The SPCC plan <br /> calls for spill kit to be located in the mobile refueler.The mobile refueler was observed a <br /> spill pad and some spill booms. This would not be sufficient to address potential spill <br /> containment mentioned in the plan and for which the mobile refueler spill kit is referenced. <br /> The SPCC plan calls out locations of spill kits throughout the facility,According to facility <br /> personnel there are no spill kits. The owner or operator or an onshore or offshore facility <br /> subject to this section must prepare in writing and implement a Spill Prevention Control and <br /> Countermeasure Plan(hereafter"SPCC Plan" or"Plan")," in accordance with § 112.7 and <br /> any other applicable section of this part. Implement the SPCC plan as written. <br /> Corrective Action: A complete adequate spill kit was installed on the mobile refueler. <br /> 2. ##519 CFR 112.7(f)(1)Failed to train personnel on all discharge prevention details listed in <br /> this section (Class II violation). Oil handling personnel were not trained.The personnel <br /> responsible for the operation of the mobile refueler had not been trained,according to a <br /> discussion between facility personnel and personnel of mobile refueler.At a minimum,oil <br /> handling personnel shall be trained in the operation and maintenance of equipment to <br /> prevent discharges; discharge procedure protocols; applicable pollution control laws, rules, <br /> and regulations; general facility operations; and the contents of the Spill Prevention, Control, <br /> and Countermeasure Plan. Immediately provide this training to all oil handling personnel <br /> and submit a copy of the training log to the EHD. <br /> Corrective Action: Immediately trained personnel responsible for the operation of the <br /> mobile refueler on site's Spill Contingency and Countermeasures and spill response <br /> procedures. Documentation of the training was accomplished and is provided as an <br /> attachment. Please not all operators of the refueler has a Class A California Driver License <br /> with Hazardous Material Endorsement. <br /> 3. 9717 CFR 112.8(c)(10)Failed to promptly correct visible discharges andr'or remove <br /> accumulations of oil in diked areas. A dispenser on the 12,000 gallon diesel tank was <br /> observed to have a small leak from piping or the hose. Visible discharges which result in a <br /> loss of oil from a container, including but not limited to seams,gaskets, piping,pumps, <br />