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Environmental Health Department CP22 - AST Non-Qualified Inspection Report Date: February 19, 2025 Facility Address: 2720 Wilcox RD, Stockton Facility Name: California Highway Patrol - Stockton SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) RemarksItem # REGULATION GUIDANCE: (b) Where experience indicates a reasonable potential for equipment failure (such as loading or unloading equipment, tank overflow, rupture, or leakage, or any other equipment known to be a source of a discharge), include in your Plan a prediction of the direction, rate of flow, and total quantity of oil which could be discharged from the facility as a result of each type of major equipment failure. CORRECTIVE ACTION: Ensure the SPCC Plan includes descriptions for procedures to be used when a discharge occurs complete tank failure for the secondary containment for the aboveground tanks. Submit proof of correction to the EHD. This is (Minor) Violation. Code of Fed Regulations 112.7(e), 112.8(c)(6) 4010021 - Written Inspection/testing procedures kept, inspection/testing records signed, kept for 3 years. OBSERVATION: The facility failed to keep written procedures and records of inspections and tests, including integrity tests, for at least three years. Per the SPCC Plan, annual and monthly inspections were to be recorded on the aboveground tanks. Copies of inspection and testing records for the following were not found on site. - 2024 12,000-gal gasoline tank annual tank inspection (per David Rodriguez, the 2024 4,000-gal diesel tank annual tank inspection on site is actually for the 12,000-gal and was not recorded appropriately by vendor. He has already contacted the vendor prior and is waiting on correct records to be sent) - 2022, 2023, 2024 monthly tank inspections for the 12,000-gal gasoline tank, 4,000-gal diesel tank, 250-gal waste oil tank - 2022, 2023, 2024 annual tank inspections for the 250-gal waste oil tank 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. Records of inspections and tests kept under usual and customary business practices will suffice for purposes of this paragraph. 112.8(c)(6) Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs. CORRECTIVE ACTION: Immediately locate a copy of all inspection and testing records for the last three years, maintain them on-site, and submit copies to the EHD. For any monthly/annual inspections that have not been being conducted, submit the first monthly/annual inspection record to EHD. This is (Class 2) Violation. 57 Code of Fed Regulations 112.8(c)(8)(v) 4030022 - Liquid level sensing devices regularly tested to ensure proper operation. OBSERVATION: Liquid level sensing devices for the following tanks have not been tested. - Annual tank inspections were only being conducted on the 12,000-gal gasoline and 4,000-gal diesel tank. Annual tank inspection checklist item #15 page 2 of 4 asks "Is interstial leak detection equipment in good condition? Are windows on sight gauges clear? Are wire connections intact? If equipment has a test function, does it activate to confirm operation?”. The answers were marked as yes but alarm history from the Veeder Root attached to the 2023 annual inspection checklist shows the last time the sensor was triggered for interstitial space for both tanks was in February 16, 2016. All Functions Normal status on the Veeder Root indicates that there are no current alarms not 61 FA0023343 PR0540837 SC001 02/19/2025 EHD Rev. 12/06/2021 CP22 - AST Non-Qualified OIRPage 6 of 8 1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD