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Environmental Health Department CP22 - AST Non-Qualified Inspection Report Date: August 30, 2024 Facility Address: 12550 S Harlan RD, Lathrop Facility Name: HEARTLAND EXPRESS INC SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) RemarksItem # Code of Fed Regulations 112.5(b) 4010009 - 5 year review performed on SPCC and documented. OBSERVATION: The facility failed to document the 5-year review of the SPCC plan. According to Nick Stamm, the Spill Prevention, Control, and Countermeasure (SPCC) Plan was reviewed/changed during November 2020 after a change of ownership/management of the facility. REGULATION GUIDANCE: (b) Notwithstanding compliance with paragraph [112.5] (a) of this section, complete a review and evaluation of the SPCC Plan at least once every five years from the date your facility becomes subject to this part; or, if your facility was in operation on or before August 16, 2002, five years from the date your last review was required under this part. As a result of this review and evaluation, you must amend your SPCC Plan within six months of the review to include more effective prevention and control technology if the technology has been field -proven at the time of the review and will significantly reduce the likelihood of a discharge as described in § 112.1(b) from the facility. You must implement any amendment as soon as possible , but not later than six months following preparation of any amendment. You must document your completion of the review and evaluation , and must sign a statement as to whether you will amend the Plan, either at the beginning or end of the Plan or in a log or an appendix to the Plan. The following words will suffice, “I have completed review and evaluation of the SPCC Plan for (name of facility) on (date), and will (will not) amend the Plan as a result.” CORRECTIVE ACTION: Immediately document the 5-year review of the SPCC Plan. Submit proof of correction to the EHD. This is (Class 2) Violation. 10 Code of Fed Regulations 112.7 4010012 - SPCC in writing, follows code seq/cross ref, good eng practice, mgt approval, items not in place. OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) Plan reviewed at the time of inspection, dated 8/30/24, did not follow the order or requirements of 40 CFR Part 112.7. The plan doesn’t follow the required SPCC rule sequence and doesn’t include adequate cross-reference. One example of this: -112.8(c) references section 2.2.1, however parts of 112.8(c)(1-11) are found in multiple sections throughout the plan, cited under the titles of the sections and subsections, which is not accurately reflected in the cross reference (e.g. 112.8(c)(10) found in section 5.3) Multiple other examples were found during the inspection. REGULATION GUIDANCE: If you are the owner or operator of a facility subject to this part you must prepare a Plan in accordance with good engineering practices. The Plan must have the full approval of management at a level of authority to commit the necessary resources to fully implement the Plan. CORRECTIVE ACTION: Ensure that your SPCC Plan complies with the following requirements: 1. It follows the required SPCC rule sequence and/or includes adequate cross-reference. Provide proof of correction to the EHD. This is (Minor) Violation. 11 Code of Fed Regulations 112.7(a)(3), 25270.4.5(a) 4010015 - SPCC contains an adequate facility diagram. OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) Plan failed to include an adequate facility diagram. -Failed to include the location and contents of EACH fixed oil storage container AND storage area of portable 16 FA0021911 PR0537957 SC001 08/30/2024 EHD Rev. 12/06/2021 CP22 - AST Non-Qualified OIRPage 6 of 9 1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD