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Received on 10/28/2019 SJC EHD - CR The following is an itemized list of aboveground petroleum storage act violations that have not been addressed for NORTHERN CALIF POWER- LODI as of October 22, 2019. Open violations from March 27, 2019 inspection Violation#301 -Failed to amend Plan as necessary. The 100 gallon diesel starter tank on the generator is addressed in the SPCC plan as operational equipment. Based on description given by facility personnel of what the tank function and operation is,the tank does not meet the definition of operational equipment. Based on the details provided by facility personnel,the tank qualifies as a bulk storage container. The Spill Prevention, Control, and Countermeasure(SPCC) Plan must be amended when there is change in the facility design, construction., operation,or maintenance that materially affects Its potential for a discharge, within 6 months of the change, and implemented as soon as possible, not later than 6 months following preparation of the amendment.The SPCC Plan should accurately represent the procedures and policies currently in place at the facility. This violation was corrected ❑ This violation will be corrected by(date): ❑ Supporting documents included Describe actions taken or will be taken to correct violation: c Violation#710-Plan failed to adequately discuss procedures to test or inspect each container for integrity. ��, The SPCC plan fails to discuss qualifications of personnel performing tests and inspections, frequency and type of testing and inspections required by the industry standards mentioned in the Plan. The SPCC plan references API 66; standard and Steel Tank Institute(STI) SP-001 standard.The SPCC plan does not discuss the qualifications of personnel performing tests and inspections, frequency and type of testing and inspections required to be performed either by th facility or certified inspectors,as required by the standards. 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. The SPCC plan should discuss requirements of the selected industry standards, or provide equivalence as allowed by CFR 11Z7(a)(2). Note:API 653 and STI SP-001 reports by certified inspectors were reviewed onsite. Inspections conducted in 2016. W-This violation was corrected ❑This violation will be corrected by(date): ❑ Supporting documents included / Describe a�ct1ions taken ��orr�will be taken to correct violation: Page 1 of 1