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Ruvalcaba, Cesar From: Ruvalcaba,Cesar Sent: Friday,August 2,2019 11:56 AM To: 'Dana Schmidt' Subject: STI certified inspector concern - Not identifying UST as AST- San Joaquin County Environmental Health Department- CA- PR0523161 Attachments: Periodic Integrity Test Certificate.pdf, DSCF1504.1PG; DSCF 1505.1PG; DSCF1506.1PG; DSCF1507.1PG; DSCF1508.JPG Hi Dana, I was working with our Aboveground Petroleum Storage Act Technical Advisory Group(APSA TAG)in California to see if there was a formal process to report suspected STI certified inspectors who may be certifying tanks that should not be certified.The response I received was that I should contact you only for this instance,since you will be retiring and that the general STI email should be used in the future. Here is what I have encountered. During an APSA inspection of the SPCC plan a 10,000 gallon diesel tank was observed at the facility. What was said to be an STI certified inspection report was presented. The presented report is attached.The report states that the there was no UL serial 11 on the tank.After the inspection, I called the testing company SPC Corporation. It was stated that the report was a STI report generated by a STI certified inspector. During later conversations it was stated by SPCC Corp that there was another inspection conducted on the 10,000 gallon tank in 2016,and that the tank was observed to not have issues under the STI standard.The 2016 report was requested but has not been provided.As specified in Chapter 7 section 7.1.2 of the STI standard "The inspector or the inspection company shall develop detailed checklists that identify,record,and document all aspects of each inspection.",the checklist was requested but none have been provided. As can be seen from the attached pictures,the 10,000 gallon tank was suspected of being a recycled UST or at least not meeting the venting requirements required by fire codes.The matter was referred to the local fire district.The local fire district conducted an inspection on the tank and found that the tank had a UL listing which identified it as an UST. SPC Corp has inspected that tank again,during the last couple of months,and has now alerted the tank owner that the tank cannot be used saying they concur with the findings of the fire inspection. The concern is that the SPC Corp inspected the tank twice before,according to them under STI standards,by a STI certified inspector and never identified any issues to the tank owner.Speaking to Paul McWhorter,CEO of the company, he stated that no issues were identified since the APSA regulations had allowed the use of the tank at the time. Paul was reminded that APSA regulations do not touch on this subject matter,it is found in fire code. From what I can gather the STI certified inspector in question would be Todd W. McWhorter AST-135013.As you can see the provided"STI Report"is not certified by an inspector. I will continue to ask for the detail on the 2013 report and request the 2016 report as well as the 2019 report. I am not sure what other information you would need,feel free to contact me for what you may need. I was hoping to have more information by now,but none has been provided. 1