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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 />SUMMARY OF VIOLATIONS <br />(CLASS I, CLASS II, or MINOR - Notice to Comply) <br />RemarksItem # <br />a discharge as described in § 112.1(b), except as provided in paragraph (k) of this section for qualified oil-filled <br />operational equipment, and except as provided in § 112.9(d)(3) for flowlines and intra-facility gathering lines at an oil <br />production facility. <br />CORRECTIVE ACTION: Immediately ensure that the SPCC plan addresses the general containment, diversionary <br />structures, and equipment in use at the facility to prevent discharge, including typical failure mode and most likely <br />quantity of potential discharge. Submit proof of correction to the EHD. <br />This is (Minor) Violation. <br />Code of Fed Regulations 112.7(e), 112.8(c)(6) 4010021 - Written Inspection/testing procedures kept, inspection/testing <br />records signed, kept for 3 years. <br />OBSERVATION: The facility failed to keep written procedures and records of inspections and tests, including integrity <br />tests, for at least three years. Copy of inspection and testing records for 2022 Integrity Test for the SS-1 T#2 was not <br />found on site. Per SPCC Plan integrity test was due in 2022. <br />REGULATION GUIDANCE: 112.7(e), Conduct inspections and tests required by this part in accordance with written <br />procedures that you or the certifying engineer develop for the facility. You must keep these written procedures and a <br />record of the inspections and tests, signed by the appropriate supervisor or inspector, with the SPCC Plan for a period <br />of three years. Records of inspections and tests kept under usual and customary business practices will suffice for <br />purposes of this paragraph. 112.8(c)(6) Test or inspect each aboveground container for integrity on a regular schedule <br />and whenever you make material repairs. <br />CORRECTIVE ACTION: Inspections and tests must be conducted in accordance with the written procedures <br />developed in the Spill Prevention, Control, and Countermeasure (SPCC) Plan. Records of these inspections and tests <br />must be signed by the appropriate supervisor or inspector and kept on-site with the SPCC Plan for three years. <br />Immediately locate a copy of all inspection and testing records for the last three years, maintain them on-site, and <br />submit copies to the EHD. <br />This is a repeat violation (Class 2) Violation. <br /> 57 <br />Overall Inspection Comments: <br />Complete and submit a copy of the Return to Compliance Certification form to the EHD with a statement <br />documenting the corrective actions that have been or will be taken for each violation, and any supporting <br />paperwork, by 10/26/2024. <br />To minimize person to person contact EHD is choosing to write the name of person receiving the report instead of <br />having them sign. <br />Starting September 1, 2018, all in-office CERS help will be provided at the EHD hourly rate ($172). To schedule an <br />appointment, please call (209) 468-3420. <br />The following was observed during this inspection: <br />- drag state lube, 275-gal <br />- performance grade asphalt emulsions, 30,000-gal, 15,000-gal/15,000-gal <br />FA0009335 PR0516200 SC001 09/26/2024 <br />EHD Rev. 12/06/2021 CP22 - AST Non-Qualified OIRPage 6 of 7 <br />1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD