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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: CALAVERAS MATERIALS INC-Tracy RMC 28983 S MACARTHUR RD,TRACY May 17, 2019 SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Notice to Comply) Item# Remarks 712 CFR 112.8(c)(6)Failed to test or inspect each container for integrity based on industry standards. The facility's SPCC plan references the SP001 standard for inspections and testing of the aboveground petroleum tanks. SP001 monthly and yearly inspection forms were included at the end of the SPCC plan. On the cover page of the SPCC plan Andrew Bergin, P.E. "amended the SPCC plan to include alternative inspection form"on 11/1/18. The monthly alternative inspection form deviates from the SP001 monthly inspection form. These applicable items were missing from the new alternative inspection form: -Is the tank liquid level gauge legible and in good working condition? -For double-wall tanks or double bottom tanks or CE-ASTs, is interstice free of liquid?(Per Andy Bergin, P.E., the interstitial space is checked yearly on the yearly inspection form. SP001 standard requires monthly inspections of the interstitial space) No alternative yearly inspection forms were available for review during the inspection. 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.You must keep comparison records and you must also inspect the container's supports and foundations. In addition, you must frequently inspect the outside of the container for signs of deterioration,discharges, or accumulation of oil inside diked areas. Records of inspections and tests kept under usual and customary business practices satisfy the record keeping requirements of this paragraph. Ensure that an industry standard is discussed in the SPCC plan and is implemented. 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. 715 CFR 112.8(c)(8)(v) Failed to regularly test liquid level sensing devices to ensure proper operation. Liquid level sensing devices have not been tested for the 10,000 gallon diesel tank. The facility's Spill Prevention, Control, and Countermeasure(SPCC)plan states that the SP001 standard will be followed for testing and inspection frequencies. The SP001 standard requires monthly inspections of the liquid level sensing devices. On 11/1/2018, Andrew Bergin (P.E.), made a technical amendment"to include alternative inspection form". The monthly alternative inspection form does not include testing/inspecting liquid level sensing devices for proper function. Liquid level sensing devices must be installed in accordance with CFR 112.8 and shall be regularly tested to ensure proper operation. Immediately conduct all necessary testing of liquid level sensing devices, or provide equivalence as allowed by CFR 112.7(a)(2). This is a Class II violation. Overall Inspection Comments: An inspection checklist was provided to the facility operator on the day of inspection. The EHD has written the FA0014411 PR0539028 SCO01 05/17/2019 EHD 28-01 Rev.09/27/2018 Page 5 of 6 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