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SEN cod Environmental Health Department SAN J O A Q U I N COUN1' Y - Aboveground Petroleum Storage Act Inspection Report Facility Name: T28983 acility Address : joate: CALAVERAS MATERIALS INC - Trac RMC S MACARTHUR RD , TRACY 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 Burgin , 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 Burgin , 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 Burgin ( 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 report was provided to the facility operator. The report was amended by the EHD . The amended 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 F 209 464-0138 1 www. sjcehd . com