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SAN J 0 A Q I I I Irl Environmental Health Department CCUNTY Aboveground Petroleum Storage Act Inspection Report Facility Name: Facility Address: Date: Pilot Travel Center Lathrop- 1017 345 Roth Rd, FRENCH CAMP July 20, 2021 SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Notice to Comply) Item# Remarks 710 CFR 112.8(c)(6)Plan failed to adequately discuss procedures to test or inspect each container for integrity. OBSERVATION: The Spill Prevention, Control, and Countermeasure(SPCC)Plan does not adequately discuss procedures to test or inspect each aboveground container for integrity in accordance with industry standards and does not address the following: The SP001 standard which was cited in the SPCC Plan requires annual inspections.The SPCC Plan reviewed on site only requires monthly inspections. REGULATION GUIDANCE: (c)(6)Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs.You must determine, in accordance with industry standards,the appropriate qualifications for personnel performing tests and inspections, the frequency and type of testing and inspections,which take into account container size, configuration, and design (such as containers that are: shop-built,field-erected, skid-mounted, elevated, equipped with a liner, double-walled, or partially buried). 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. CORRECTIVE ACTION: Ensure that the SPCC Plan adequately discusses facility's procedures to test and inspect aboveground/bulk storage containers in accordance with all applicable industry standards. This discussion must include, but not be limited to, inspection/testing schedule/frequency, and personnel qualifications. Submit proof of correction to the EHD. 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. OBSERVATION: The SPCC Plan does not discuss regular testing of liquid level sensing devices. REGULATION GUIDANCE: (c)(8)(v)You must regularly test liquid level sensing devices to ensure proper operation. CORRECTIVE ACTION: Liquid level sensing devices must be installed in accordance with CFR 112.8 and shall be regularly tested to ensure proper operation. Ensure the SPCC Plan discusses the schedule of testing of liquid level sensing devices and submit proof to EHD. This is a Class II violation. Overall Inspection Comments: Complete and submit a copy of the Return to Compliance Certification form to the EHD with a statement FA0023459 PR0542166 SCO01 07/20/2021 EHD 28-01 Rev.9/16/2020 Page 9 of 10 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.sjgov.org/EHD