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S b N J 0 A Q U I N Environmental Health Department COUNTY Aboveground Petroleum Storage Act Inspection Report Facility Name: Facility Address: Date: OWENS-BROCKWAY GLASS CONTAINER INC 1 14700 W SCHULTE RD,TRACY June 05, 2019 SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Notice to Comply) Item# Remarks 706 CFR 112.8(c)(2)Failed to provide and maintain adequate secondary containment. The 195 gallon emergency generator and the 140 gallon emergency generator were observed with insufficient secondary containment. The 195 gallon emergency generator and the 140 gallon emergency generator are single wall tanks. The SPCC plan states that the secondary containment is the operational oil-filled alternatives. Generators do not meet the definition of operational oil-filled equipment. All bulk storage tanks must be provided with a secondary means of containment for the entire capacity of the tank and sufficient freeboard to contain precipitation. Immediately provide sufficient secondary containment for this and all other tanks at this facility. This is a repeat violation, Class II. 712 CFR 112.8(c)(6)Failed to test or inspect each container for integrity based on industry standards. Page 29 of the SPCC plan states that tanks will be inspected per SP001 standards. Facility is currently only doing monthly inspections. SP001 standard requires annual inspections in addition to the monthly inspections. The monthly inspection checklist is not substantially equivalent to the SP001 checklist. These applicable items are missing: -Are drain valves(secondary containment)closed? -Is interstitial monitoring equipment in good working condition? -Is interstice free of liquid? The SPCC plan did not include an environmental equivalence discussion for deviation from the SP001 standard. 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. Immediately ensure that the industry standard selected in the SPCC plan is fully implemented at the facility and submit proof to the EHD, or provide equivalence as allowed by CFR 112.7(a)(2). If an owner or operator deviates from applicable industry standards to develop an integrity testing program,then a PE must certify an environmentally equivalent alternative in the SPCC Plan.The Plan must provide the reason for the deviation, describe the alternative approach, and explain how it achieves environmental protection equivalent to the applicable industry standard. This is a Class II violation. 717 CFR 112.8(c)(10) Failed to promptly correct visible discharges and/or remove accumulations of oil in diked areas. The 140 gallon emergency generator was observed with visible discharge around the base of the diesel belly tank. Visible discharges which result in a loss of oil from a container, including but not limited to seams,gaskets, piping, pumps,valves, rivets, and bolts, must be promptly corrected. Immediately fix the leak, clean up the discharge and manage according to the California Code of Regulations Title 22 hazardous waste regulations. This is a repeat violation, Class II. FA0006674 PR0516327 SCO01 06/05/2019 EHD 28-01 Rev.09/27/2018 Page 6 of 8 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