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Environmental Health Department Aboveground Petroleum Storage Act Inspection Report Date: February 22, 2022 Facility Address: 20451 MCHENRY AVE, ESCALON Facility Name: LIONUDAKIS FIREWOOD Qualified Facility - Tier I 403 □ V □ R □ COSTier I Plan failed to predict direction/rate of flow/total quantity of oil potentially dischargedCFR 112.6(a)(3)(i) 404 □ V □ R □ COSNo adequate 2CT for bulk containers, or mobile storage containers not located to prevent dischargeCFR 112.6(a)(3)(ii) 405 □ V □ R □ COSFailed to provide systems to prevent overfills or to routinely test them (Tier I facility)CFR 112.6(a)(3)(iii) 406 □ V □ R □ COSTier I Plan failed to adequately describe the overfill prevention methods for each containerCFR 112.6(a)(3)(iii) Qualified Facility - Tier II 501 □ V □ R □ COSTier II Qualified Facility Plan not certified by the owner or a PE, as requiredCFR 112.6(a)(1), 112.6(b) 502 □ V □ R □ COSTier II Qualified Facility Plan technical amendment not certified by the owner or a PECFR 112.6(b)(2) 503 □ V □ R □ COSFailure to have a PE certify in writing alternative measures for a Tier II Qualified FacilityCFR 112.6(b)(3), 112.6(b)(4) 504 □ V □ R □ COSFailure of owner to assure that a PE makes all required attestations in a Tier II PlanCFR 112.6(b)(4)(i) General Requirements for SPCC Plans 601 □ V □ R □ COSFailure of Plan to fulfill basic requirements including a cross-referencing sectionCFR 112.7 602 □ V □ R □ COSFailed to state reasons and detail nonconformance if claiming equivalent environmental protectionCFR 112.7(a)(2) 603 □ V □ R □ COSPlan failed to adequately and accurately describe the physical layout of the facilityCFR 112.7(a)(3) 604 □ V □ R □ COSPlan failed to include oil type and storage capacity for each containerCFR 112.7(a)(3)(i) 605 ■ V ■ R □ COSPlan failed to include an adequate facility diagram, or no facility diagram was includedCFR 112.7(a)(3), 25270.4.5(a) 606 □ V □ R □ COSPlan failed to adequately discuss discharge prevention measures, including routine handling of oilCFR 112.7(a)(3)(ii) 607 □ V □ R □ COSPlan failed to adequately discuss facility drainage or drainage controlsCFR 112.7(a)(3)(iii) 608 □ V □ R □ COSPlan failed to include countermeasures for discharge discovery, response and cleanupCFR 112.7(a)(3)(iv) 609 □ V □ R □ COSPlan failed to address disposal methods for recovered materialsCFR 112.7(a)(3)(v) 610 ■ V □ R □ COSPlan failed to adequately detail information and procedures for reporting a dischargeCFR 112.7(a)(3vi), 112.7(a4) 611 □ V □ R □ COSDischarge procedures are not adequately addressed if the facility has no response planCFR 112.7(a)(5) 612 □ V □ R □ COSPlan doesn't have discharge prediction, including direction, rate of flow, and quantity of oilCFR 112.7(b) 613 □ V □ R □ COSPlan failed to discuss general secondary containment, equipment, or structures to prevent dischargeCFR 112.7(c) 614 □ V □ R □ COSFailure to provide appropriate secondary containment, diversionary structures or equipmentCFR 112.7(c) 615 □ V □ R □ COSPE certified Plan failed to explain impracticability of containment/diversionary structuresCFR 112.7(d) 616 □ V □ R □ COSFailure to perform integrity and leak testing when claiming secondary containment impracticabilityCFR 112.7(d), 25270.4.5(a) 617 □ V □ R □ COSFailed to prepare oil spill contingency plan when claiming containment structure impracticabilityCFR 112.7(d)(1) 618 □ V □ R □ COSNo written commitment of manpower, equipment, and materials to control and remove oil dischargeCFR 112.7(d)(2) 619 □ V □ R □ COSFailure to keep written records of procedures, inspections, and tests for at least three yearsCFR 112.7(e), 112.8(c) (6) 620 □ V □ R □ COSFailed to train personnel on all discharge prevention details listed in this sectionCFR 112.7(f)(1) 621 □ V □ R □ COSFailed to designate a person accountable for discharge preventionCFR 112.7(f)(2) 622 □ V □ R □ COSPlan failed to include an adequate description of employee training and annual briefingsCFR 112.7(f)(1), 112.7(f)(3) FA0010254 PR0523036 SC001 02/22/2022 EHD 28-01 Rev. 12/06/2021 Aboveground Petroleum Storage Act OIRPage 2 of 9 1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD