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Environmental Health Department Aboveground Petroleum Storage Act Inspection Report Date: February 17, 2022 Facility Address: 2323 LOVELACE RD, MANTECA Facility Name: LOVELACE TRANSFER STATION SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) RemarksItem # 602 CFR 112.7(a)(2) Failed to state reasons and detail nonconformance if claiming equivalent environmental protection. OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) Plan reviewed at the time of inspection, dated 08/01/2018, failed to state reasons for non conformance and describe in detail alternate methods used to achieve environmentally equivalent protection (other than secondary containment) when claiming environmental equivalence for SPCC requirements. The integrity testing cited in the SPCC plan deviates from the STI SP001 standard cited in the SPCC plan. Section 9.2.3 of the SPCC plan cites a letter from the USEPA regarding integrity testing. This letter is no longer applicable since regulations changed after the letter was written. REGULATION GUIDANCE: (2) Comply with all applicable requirements listed in this part. Except as provided in § 112.6 (Qualified Facilities Plan Requirements), your Plan may deviate from the requirements in paragraphs (g), (h) (2) and (3), and (i) of this section and the requirements in subparts B and C of this part, except the secondary containment requirements in paragraphs (c) and (h)(1) of this section, and §§ 112.8(c)(2), 112.8(c)(11), 112.9(c)(2), 112.9(d)(3), 112.10(c), 112.12(c)(2), and 112.12(c)(11), where applicable to a specific facility, if you provide equivalent environmental protection by some other means of spill prevention, control, or countermeasure. Where your Plan does not conform to the applicable requirements in paragraphs (g), (h)(2) and (3), and (i) of this section, or the requirements of subparts B and C of this part, except the secondary containment requirements in paragraph (c) and (h)(1) of this section, and §§ 112.8(c)(2), 112.8(c)(11), 112.9(c)(2), 112.10(c), 112.12(c)(2), and 112.12(c) (11), you must state the reasons for non conformance in your Plan and describe in detail alternate methods and how you will achieve equivalent environmental protection. If the Regional Administrator determines that the measures described in your Plan do not provide equivalent environmental protection, he may require that you amend your Plan, following the procedures in § 112.4(d) and (e). CORRECTIVE ACTION: Since the SPCC Plan does not conform to the applicable requirements, the reasons for non conformance must be stated, and the alternate methods to achieve equivalent environmental protection must be described in detail. Ensure that the SPCC Plan includes an adequate discussion of equivalent environmental protection. Provide proof of correction to the EHD. This is a Class II violation. FA0001434 PR0523546 SC001 02/17/2022 EHD 28-01 Rev. 12/06/2021 Aboveground Petroleum Storage Act OIRPage 6 of 10 1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD