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Environmental Health Department AMENDED 12/9/2024 CP22 - AST Non-Qualified Inspection Report Date: December 03, 2024 Facility Address: 1905 S MCHENRY AVE, ESCALON Facility Name: ESCALON PREMIER BRANDS SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) RemarksItem # CORRECTIVE ACTION: Ensure the SPCC Plan includes the correct EHD phone number, has all numbers in one section to allow easy access for reporting a discharge (or reference section 2D and 8B so those numbers can be found) and all required items in the discharge procedure (Oil Spill History Form). Submit proof of correction to the EHD. This is (Minor) Violation. Code of Fed Regulations 112.7(b) 4010019 - SPCC predicts direction, rate of flow, total quantity of oil that could be released from a discharge. OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) Plan failed to predict the direction, rate of flow, and the total quantity of the oil that could be discharged for each type of major equipment failure. Section 4 A discusses equipment discharge scenarios but does not discuss direction, rate of slow or total quantity that could be discharged from all petroleum containing bulk storage on site. REGULATION GUIDANCE: (b) Where experience indicates a reasonable potential for equipment failure (such as loading or unloading equipment, tank overflow, rupture, or leakage, or any other equipment known to be a source of a discharge), include in your Plan a prediction of the direction, rate of flow, and total quantity of oil which could be discharged from the facility as a result of each type of major equipment failure. CORRECTIVE ACTION: Ensure the SPCC Plan discusses prediction of the direction, rate of flow, and total quantity of oil which could be discharged from the facility as a result of each type of major equipment failure (specifically: bulk new oil, used oil and diesel fuel). Submit proof of correction to the EHD. This is (Minor) Violation. 22 Code of Fed Regulations 112.7(f)(1), 112.7(f)(3) 4010023 - Employee training and spill prevention briefings discussed in SPCC plan. OBSERVATION: Failure to include in the Spill Prevention, Control, and Countermeasure (SPCC) Plan a discussion, or adequate description of all required employee training including annual spill prevention briefings provided to oil-handling personnel. - Section 6 references Detailed Training Plans are in Appendix B but Appendix B is blank and does not include detailed training. - Section 6 does not discuss how often training is conducted REGULATION GUIDANCE: 112.7(f)(1) At a minimum, train your oil-handling personnel in the operation and maintenance of equipment to prevent discharges; discharge procedure protocols; applicable pollution control laws, rules, and regulations; general facility operations; and, the contents of the facility SPCC Plan. 112.7(f)(3) Schedule and conduct discharge prevention briefings for your oil-handling personnel at least once a year to ensure an adequate understanding of the SPCC Plan for that facility. Such briefings must highlight and describe known discharges as described in § 112.1(b) or failures, malfunctioning components, and any recently developed precautionary measures. CORRECTIVE ACTION: Ensure the SPCC Plan includes an adequate description of employee training. Training shall address, at a minimum: operation and maintenance of equipment to prevent discharges; discharge procedure protocols; applicable pollution control laws, rules, and regulations; general facility operations; content of the facility 29 FA0004254 PR0523373 SC001 12/03/2024 EHD Rev. 12/06/2021 CP22 - AST Non-Qualified OIRPage 7 of 10 1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD