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Environmental Health Department CP22 - AST Non-Qualified Inspection Report Date: October 21, 2024 Facility Address: 1002 FRONTAGE RD, RIPON Facility Name: GAS & SHOP SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) RemarksItem # diked areas. Submit proof of correction to the EHD. This is a repeat violation (Class 2) Violation. Code of Fed Regulations 112.7(e), 112.8(c)(6) 4030014 - Tanks inspected and tested by qualified person in accordance with industry standards. OBSERVATION: Facility failed to ensure that tanks are inspected and tested by an appropriately qualified person in accordance with industry standards. Tanks 1-4 have not been tested "as soon as practicable" per engineer as described on page 34 of the March 11, 2022 SPCC Plan. The 2020 APSA inspection report states that the previous SPCC plan calls for integrity testing to be conducted in 2021. Facility personnel stated that the tanks have been in service for over 20 years. REGULATION GUIDANCE: 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 ensure that all tanks are inspected and tested by an appropriately qualified person in accordance with industry standards. Submit proof of correction/ test results to the EHD. This is (Class 2) Violation. 55 Code of Fed Regulations 112.7(e), 112.8(c)(6) 4030015 - Aboveground containers tested or inspected for integrity based on industry standards. OBSERVATION: The 20,000 gallon tanks have not been tested or inspected for integrity on a regular schedule. The SPCC plan calls for the Steel Tank Institute (STI) SP-001 industry standard to be the standard that applies to the tanks. The SPCC plan calls for a twenty year testing cycle, per SP-001 guidelines. The 2020 APSA inspection report states that the previous SPCC plan calls for integrity testing to be conducted in 2021. Facility personnel stated that the tanks have been in service for over 20 years. Per STI SP-001 standards, chapter 5, section 5.1, states, in part, that the interval or the initial inspection shall begin from the AST’s initial service date . This would make the integrity testing under STI SP-001 standards overdue. Facility inspections required by the STI SP-001 are not being conducted by the facility. The SPCC plan and SP-001 standards call for documented monthly and annual inspections of tanks using STI SP-001 standards and checklists, these inspections are not being conducted by the facility at the frequency required by the SPCC plan or the SP-001 standard. REGULATION GUIDANCE: REGULATION GUIDANCE: 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 conduct the necessary integrity testing based on industry standards, on a regular schedule, after making material repairs, using non-destructive testing, inspecting each container’s supports , foundations, and outside for signs of deterioration, discharges, or accumulation of oil inside diked areas. Maintain testing and inspection records. Submit a copy of the test/ inspection results to the EHD. This is a repeat violation (Class 2) Violation. 56 Code of Fed Regulations 112.7(e), 112.8(c)(6) 4010021 - Written Inspection/testing procedures kept, inspection/testing 57 FA0000650 PR0516198 SC001 10/21/2024 EHD Rev. 12/06/2021 CP22 - AST Non-Qualified OIRPage 11 of 16 1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD