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Environmental Health Department AMENDED 12/12/2024 CP22 - AST Non-Qualified Inspection Report Date: December 10, 2024 Facility Address: 11800 S HARLAN RD, LATHROP Facility Name: UPS Lathrop Hub □ OUT □ R □ COS4045 - Release/Leaks/Spills - General Local Ordinance 86 □ OUT □ R □ COS4050 - Abandonment/Illegal Disposal/Unauthorized Treatment - General See below 87 □ OUT □ R □ COS4055 - Abandonment/Illegal Disposal/Unauthorized Treatment - General Local Ordinance 88 SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) RemarksItem # Code of Fed Regulations 112.5(a), 112.5(b) 4010010 - Facility has amended SPCC as necessary. OBSERVATION: The facility failed to amend the Spill Prevention, Control, and Countermeasure (SPCC) Plan within six months of when there was a change in design, construction, operation, or maintenance, which affects the facility’s discharge potential. - The annual review conducted on 8/6/2020 and 6/18/2021 marked "yes" in the table for if PE amendments were needed. The last Professional Engineer certification was 11/22/2019. One of the changes needed in the notes from the 2020 annual review was neoprene storm drain covers needed to be removed from the plan as it does not apply to the facility for spill control. The use of neoprene storm drain covers was still observed in the plan reviewed on site. REGULATION GUIDANCE: (a) Amend the SPCC Plan for your facility in accordance with the general requirements in § 112.7, and with any specific section of this part applicable to your facility, when there is a change in the facility design, construction, operation, or maintenance that materially affects its potential for a discharge as described in § 112.1(b). CORRECTIVE ACTION: Ensure that the SPCC Plan has been amended, as required, and it accurately represents facility design, procedures, and policies currently in place. Provide proof of correction to the EHD. This is (Minor) Violation. 7 Code of Fed Regulations 112.7(a)(3vi), 112.7(a4) 4010017 - SPCC contains procedures for reporting a discharge. OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) Plan is missing information and procedures for reporting a discharge. The form used for spill reporting is missing if damages or injuries occurred because of the discharge. REGULATION GUIDANCE: The SPCC plan shall include: 112.7(a)(4) provide information and procedures in your plan to enable a person reporting a discharge to relate information on the exact address or location and phone number of the facility, the date and time of the discharge, the type of materials discharged; estimates of the total quantity discharged; estimated of the quantity discharged; the source of the discharge; a description of all affected media ; the cause of the discharge; any damages or injuries caused by the discharge, actions being used to stop, remove and mitigate the effects of the discharge ; whether an evacuation may be needed; and, the names of individuals and/or organizations who have also been contacted CORRECTIVE ACTION: Ensure the SPCC Plan to include any damages or injuries caused by the discharge in the form for reporting a discharge. Submit proof of correction to the EHD. This is (Minor) Violation. 20 Code of Fed Regulations 112.7(a)(1), 112.8(c)(8) 4010056 - SPCC adequately describes overfill prevention methods, and devices/systems used for each container. OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) Plan discusses the liquid sensing devices on page 34 Section 4.2.7 but does not discuss how or when the liquid sensing devices are tested. 59 FA0010414 PR0516477 SC001 12/10/2024 EHD Rev. 12/06/2021 CP22 - AST Non-Qualified OIRPage 5 of 7 1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD