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Environmental Health Department CP22 - AST Non-Qualified Inspection Report Date: August 21, 2024 Facility Address: 3663 Petersen RD, Stockton Facility Name: Penske Truck Leasing Co., LP SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) RemarksItem # 3-The Monthly Safety and Environmental Checklists does not list the name of the AST inspected . 4- Visible corrosion observed on the manifold piping and piping connected from the ASTs to the dispensers . Facility inspections shows photos for the last several years with corroded piping. The inspections checklists answer no to " visible corrosion". The checklists does not list any notes/corrective actions/plan to address this issue. REGULATION GUIDANCE: 112.7(e) Conduct inspections and tests required by this part in accordance with written procedures that you or the certifying engineer develop for the facility. You must keep these written procedures and a record of the inspections and tests, signed by the appropriate supervisor or inspector, with the SPCC Plan for a period of three years. CORRECTIVE ACTION: Immediately ensure that all inspections and tests on all aboveground liquid petroleum containers larger than 55-gallons are conducted in accordance with industry standards by appropriately qualified personnel. Submit proof of correction/plan for correction to the EHD. This is (Class 2) Violation. Code of Fed Regulations 112.20(e) 4010044 - Substantial Harm Criteria certification maintained at the facility as required. OBSERVATION: The facility failed to certify/sign the Substantial Harm Criteria certification form included in the SPCC plan. REGULATION GUIDANCE: (e) If the owner or operator of a facility determines pursuant to paragraph (a)(2) of this section that the facility could not, because of its location, reasonably be expected to cause substantial harm to the environment by discharging oil into or on the navigable waters or adjoining shorelines, the owner or operator shall complete and maintain at the facility the certification form contained in appendix C to this part and, in the event an alternative formula that is comparable to one contained in appendix C to this part is used to evaluate the criterion in paragraph (f)(1)(ii)(B) or (f)(1)(ii)(C) of this section, the owner or operator shall attach documentation to the certification form that demonstrates the reliability and analytical soundness of the comparable formula and shall notify the Regional Administrator in writing that an alternative formula was used. CORRECTIVE ACTION: Complete and maintain at the facility the Substantial Harm Criteria certification form. Submit proof of correction to the EHD. This is (Minor) Violation. 78 Overall Inspection Comments: An inspection checklist was provided to the facility operator on the day of inspection. A complete report was finished on 08/22/2024 and replaces the initial checklist. Complete and submit a copy of the attached Return to Compliance Certification form to the EHD with a statement documenting the corrective actions that have been or will be taken for each violation, and any supporting paperwork, within 30 days of receiving the complete inspection report by 09/20/2024. Notes to consider: -The gauges for the 500 gallons Used Oil Tank, and 10K diesel tanks are not visible. -Observed corroded acetylene cylinder next the drum storage area that was impacted by fire. Dispose of the cylinder properly. -Train employees how to easily access the Online CUPA Compliance Binder and consider a second plan to access documents if the WIFI/phones are disconnected. FA0010627 PR0517463 SC001 08/21/2024 EHD Rev. 12/06/2021 CP22 - AST Non-Qualified OIRPage 8 of 9 1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD