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SANJ D A � U I LIll�l, Environmental Health Department U u I Y Aboveground Petroleum Storage Act Inspection Report Facility Name: Facility Address: Date: NORTHERN CALIF POWER-LODI 2131 W TURNER RD, LODI March 27, 2019 Other Violations 4050 See below Unlisted Abandonment/Illegal Disposal/Unauthorized Treatment violation V E R -COS SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Notice to Comply) Item# Remarks 301 CFR 112.5(a) Failed to amend Plan as necessary. The 190 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 a 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 is a minor violation. 710 CFR 112.8(c)(6)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 653 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 112.7(a)(2). Note:API 653 and STI SP-001 reports by certified inspectors were reviewed onsite. Inspections conducted in 2016. This is a Class II violation. 4010 CFR 112.20(e)-Substantial Harm Criteria form (appendix C in CFR 112)was not found on site. If the owner or operator of a facility determines pursuant to paragraph (a)(2)of this section that the facility could not, because of its location, reasonably be expected to cause substantial harm to the environment by discharging oil into or on the navigable waters or adjoining shorelines, the owner or operator shall complete and maintain at the facility the certification form contained in appendix C to this part. Complete and maintain form on site. This was corrected on site. This is a minor violation. Overall Inspection Comments: FA0009893 PR0535925 SCO01 03/27/2019 EHD 28-01 Rev.09/27/2018 Page 4 of 5 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