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SANJOARIN Environmental Health Department
<br /> —COUNTY
<br /> Aboveground Petroleum Storage Act Inspection Report
<br /> Facil it,N.. I Facility Address: aae.
<br /> RAMOS OIL CAR D LOCK 8925 WTHORNTON RD,THORNTON January 23, 2020
<br /> SUMMARY OF VIOLATIONS
<br /> (CLASS I,CLASS II,or MINOR-Notice to Comply)
<br /> Item M Remarks
<br /> 710 CFR 112.8(cx8)Plan failed to adequately discuss procedures to test or inspect each container for integrity.
<br /> The SPCC plan references the Steel Tank Institute's SP001 standard.The SPCC plan deviates from the SP-001
<br /> standard and does not require annual inspections by the facility as required by the SP-001 standard.A
<br /> determination on the appropriate qualifications for personnel performing tests and inspections,the frequency and
<br /> type of testing and inspections,which take into account container size,configuration,and design per the industry
<br /> standards has not been addressed in the plan per the SP-001 standard.The SPCC plan states that the age of the
<br /> 20,000 and 30,000 gallon tanks is unknown and integrity testing under SP-001 standards may be due.
<br /> The outside of the 20,000 and 30,000 gallons containers is not being inspected for signs of deterioration,
<br /> discharges,or accumulation of oil inside diked areas.The 20,000 and 30,000 gallons containers are described by
<br /> the facility as being double walled and the interstitial space of the tanks is not being inspected.
<br /> Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material
<br /> repairs.You must determine,in accordance with industry standards,the appropriate qualifications for personnel
<br /> performing tests and inspections,the frequency and type of testing and inspections,which take into account
<br /> container size,configuration,and design (such as containers that are:shop-built,field-erected,skid-mounted,
<br /> elevated,equipped with a liner,double-walled,or partially buried). Examples of these integrity tests include, but are
<br /> not limited to:visual inspection,hydrostatic testing, radiographic testing, ultrasonic testing,acoustic emissions
<br /> testing,or other systems of non-destructive testing.You must keep comparison records and you must also inspect
<br /> the container's supports and foundations.In addition,you must frequently inspect the outside of the container for
<br /> signs of deterioration,discharges,or accumulation of oil inside diked areas. Records of inspections and tests kept
<br /> under usual and customary business practices satisfy the recordkeeping requirements of this paragraph.
<br /> The SPCC plan should describe the selected industrystandard and describe the appropriate qualifications for
<br /> personnel performing tests and inspections and the frequency and type of testing and inspections as required by the
<br /> standard ,or provide equivalence as allowed by CFR 112.7(ax2).If integrity testing of the tanks is due, provide the
<br /> reports required by the insutry standard.
<br /> This is a repeat violation,Class If.
<br /> 718 CFR 112.8(cx11)Failed to locate properly or provide sufficient secondary containment for mobile/portable
<br /> containers.
<br /> The 55 gallon drums were observed with absorbent booms as secondary containment.Part of the the SPCC plan
<br /> states that there should be a 3.5 inch berm around the containment area.It is unclear in the SPCC plan whether or
<br /> not the booms are sufficient to contain the capacity of the largest single compartment or container with sufficient
<br /> freeboard to contain precipitation before the booms become saturated and can can hold more petroleum product.
<br /> Position or locate mobile or portable oil storage containers to prevent a discharge as described in§112.1(b).Except
<br /> for mobile refuelers and other non-transportation-related tank trucks, you must furnish a secondary means of
<br /> containment,such as a dike or catchment basin,sufficient to contain the capacity of the largest single compartment
<br /> or container with sufficient freeboard to contain precipitation.
<br /> The SPCC plan should discuss what is sufficient secondary containment portable containers at this facility,or
<br /> provide impracticability determination pursuant to CFR 112.7(d).
<br /> This is a repeat violation,Class If.
<br /> FM0179U PRODU78 SN01 01Q3202t
<br /> E11)18U1 Rcr.&2N1019 Page 7 of Abaveg JPetro—Stara)e AC OIR
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