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Baker, Lydia [EHD] From: Baker, Lydia [EHD] Sent: Tuesday, September 28, 2021 3:33 PM To: Mike Eliason Cc: Ed Ward; Vang-Lee, Vicky [EHD] Subject: RE: Valley Pacific Lodi Plant &Cardlock Hi Mike, Vicky Vang-Lee is now the assigned inspector for this site. She is cc'd on this email. There are still three open violations. A copy of the new SPCC plan should be adequate to resolve all the violations. Here are the open violations: -Loading/unloading rack containment system not adequate to contain spills. Facility has an area that meets the definition of a loading rack and secondary containment is not sufficient to contain the maximum capacity of the largest single compartment of a truck loaded at the facility, per the SPCC plan. Where loading/unloading rack drainage does not flow into a catchment basin or treatment facility designed to handle discharges, use a quick drainage system for tank car or tank truck loading/unloading racks.You must design any containment system to hold at least the maximum capacity of any single compartment of a tank car or tank truck loaded or unloaded at the facility. Provide an interlocked warning light or physical barrier system,warning signs, wheel chocks or vehicle brake interlock system in the area adjacent to a loading/unloading rack,to prevent vehicles from departing before complete disconnection of flexible or fixed oil transfer lines. Immediately begin implementing the necessary procedures, as described in the Spill Prevention, Control, and Countermeasure Plan, to provide sufficient secondary containment in all tank car and tank truck loading and unloading areas. Note:The SPCC plan has identified the non-compliance and has a proposed secondary containment with sufficient capacity to contain a minimum of 1,800 gallons by May 30, 2019. -Container not compatible with oil stored and/or storage conditions. The SPCC plan states that the five, 12,000 gallon diesel storage tanks are re-purposed Underground Storage Tanks (UST) being used as Aboveground Storage Tanks (AST). The SPCC plan states that the ASTs are constructed as USTs and are not compatible as aboveground tanks. Containers shall be compatible with the material stored and the conditions of storage such as pressure and temperature. Immediately transfer the contents to a compatible container, or provide equivalence as allowed by CFR 112.7(a)(2). Note:The SPCC plan has identified the non-compliance and has a proposed replacing the tanks with approved tanks by January 2020. -Failed to provide and maintain adequate secondary containment. The SPCC plan states that APSA regulated 55 gallon drums within the warehouse have secondary containment provided by the building walls, doorway berms and floor.The floors appeared to be plywood which was not treated or coated. Small gaps where observed in the wood flooring. Staining and oil soaked in parts of the wood flooring was evident. Wood flooring and possibly the wood walls and berms do not appear to be sufficiently impermeable to the APSA regulated product in the building.A transition box sump for the underground piping was observed within the secondary containment structure of the five 12,000 gallon tanks. A release from a tank may find its way into the sump. Underground piping is double walled and some of the pipes within the sump did not have a boot or cover to prevent liquid from traveling into the interstitial space of the pipes and out of the secondary containment.The SPCC plan calls for the transition box sump to be drainage and point of accumulation for the underground pipes in the event of the primary pipe failure.This would require the interstitial space of the pipes to have an opening into the transition box sump and secondary containment for the 12,000 gallon tanks would be compromised. Although the underground piping may have been installed with a degree of decline to allow any liquid within the interstitial space to drain back to the transition sump,the floor to the secondary containment structure seems to be higher than any part of the underground piping which would defeat the purpose of the decline in the pipe. Construct all bulk storage tank 1