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Environmental Health Department <br />CP22 - AST Non-Qualified Inspection Report <br />Date: <br />September 26, 2024 <br /> Facility Address: <br /> 26292 E RIVER RD, ESCALON <br /> Facility Name: <br /> MUNN & PERKINS <br /> □ OUT □ R □ COS4045 - Release/Leaks/Spills - General Local Ordinance 86 <br /> □ OUT □ R □ COS4050 - Abandonment/Illegal Disposal/Unauthorized Treatment - General See below 87 <br /> □ OUT □ R □ COS4055 - Abandonment/Illegal Disposal/Unauthorized Treatment - General Local Ordinance 88 <br />SUMMARY OF VIOLATIONS <br />(CLASS I, CLASS II, or MINOR - Notice to Comply) <br />RemarksItem # <br />Code of Fed Regulations 112.7(a)(3)(i) 4010041 - SPCC Plan addresses the type of oil and storage capacity for all <br />fixed and portable containers. <br />OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) Plan failed to address the type of oil and <br />storage capacity for each fixed container. The following was observed on site but was not addressed in the SPCC <br />Plan: <br />- 550-gallon used oil tank in the lubricant storage area <br />REGULATION GUIDANCE: The SPCC plan shall include: (i) The type of oil in each fixed container and its storage <br />capacity. For mobile or portable containers, either provide the type of oil and storage capacity for each container or <br />provide an estimate of the potential number of mobile or portable containers, the types of oil, and anticipated storage <br />capacities. <br />CORRECTIVE ACTION: The SPCC Plan shall properly address the type and storage capacity of all fixed and portable <br />and/or mobile containers, as required. Submit proof of correction to the EHD. <br />This is (Minor) Violation. <br /> 15 <br />Code of Fed Regulations 112.7(b) 4010019 - SPCC predicts direction, rate of flow, total quantity of oil that could be <br />released from a discharge. <br />OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) Plan failed to predict the direction, rate <br />of flow, and the total quantity of the oil that could be discharged for each type of major equipment failure. The potential <br />equipment failure and the resulting spill from 550-gallon used oil tank in the lubricant storage area was not addressed <br />in the SPCC Plan. <br />REGULATION GUIDANCE: (b) Where experience indicates a reasonable potential for equipment failure (such as <br />loading or unloading equipment, tank overflow, rupture, or leakage, or any other equipment known to be a source of a <br />discharge), include in your Plan a prediction of the direction, rate of flow, and total quantity of oil which could be <br />discharged from the facility as a result of each type of major equipment failure. <br />CORRECTIVE ACTION: SPCC Plan shall be updated so that portions describing procedures to be used when a <br />discharge occurs (for each type of major equipment failure, specifically 550-gallon used oil tank in the lubrication <br />storage area) will be readily usable in an emergency. Submit proof of correction to the EHD. <br />This is (Minor) Violation. <br /> 22 <br />Code of Fed Regulations 112.7(c) 4010020 - SPCC addresses the appropriate general containment/diversionary <br />structures/equipment. <br />OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) Plan failed to discuss the appropriate <br />general containment, diversionary structures, or equipment to prevent discharge, including typical failure mode and <br />most likely quantity of discharge for the following containers: 550-gallon used oil tank in the lubricant storage area <br />REGULATION GUIDANCE: (c) Provide appropriate containment and/or diversionary structures or equipment to prevent <br /> 23 <br />FA0009335 PR0516200 SC001 09/26/2024 <br />EHD Rev. 12/06/2021 CP22 - AST Non-Qualified OIRPage 5 of 7 <br />1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD