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Environmental Health Department <br />AMENDED <br />12/9/2024 <br />CP22 - AST Non-Qualified Inspection Report <br />Date: <br />December 03, 2024 <br /> Facility Address: <br /> 1905 S MCHENRY AVE, ESCALON <br /> Facility Name: <br /> ESCALON PREMIER BRANDS <br />SUMMARY OF VIOLATIONS <br />(CLASS I, CLASS II, or MINOR - Notice to Comply) <br />RemarksItem # <br />SPCC plan; and annual discharge prevention briefings for oil-handling personnel to assure adequate understanding of <br />the SPCC plan. Provide proof of correction to the EHD. <br />This is (Class 2) Violation. <br />Code of Fed Regulations 112.7(g) 4010024 - SPCC addresses security measures-lighting, access to handling/storage, <br />valves/pumps/transfer equip. <br />OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) Plan did not include a complete <br />discussion of required security measures. Section 7 discusses Security but does not discuss lighting to prevent acts <br />of vandalism and assist in discovery of oil discharges. <br />REGULATION GUIDANCE: 112.7(g) Describe in your Plan how you secure and control access to the oil handling, <br />processing and storage areas; secure master flow and drain valves; prevent unauthorized access to starter controls on <br />oil pumps; secure out-of-service and loading/unloading connections of oil pipelines; and address the appropriateness <br />of security lighting to both prevent acts of vandalism and assist in the discovery of oil discharges. <br />CORRECTIVE ACTION: Ensure that the SPCC plan adequately addresses the following security measures: <br />appropriateness of security lighting. Provide proof of correction to the EHD. <br />This is (Class 2) Violation. <br /> 33 <br />Code of Fed Regulations 112.8(c)(1) 4030012 - Material and construction of all containers are compatible with the <br />material stored. <br />OBSERVATION: The SPCC Plan failed to discuss the compatibility of bulk petroleum containing storage containers <br />with material and construction compatible with material stored and conditions of storage such as pressure and <br />temperature. <br />REGULATION GUIDANCE: 112.8(c)(1) Not use a container for the storage of oil unless its material and construction <br />are compatible with the material stored and conditions of storage such as pressure and temperature. <br />CORRECTIVE ACTION: Ensure that the SPCC plan discusses compatibility of petroleum containing bulk storage <br />containers. Submit proof of correction to the EHD. <br />This is (Minor) Violation. <br /> 47 <br />Code of Fed Regulations 112.8(c)(6) 4010028 - SPCC discusses procedures to test/inspect storage containers for <br />integrity per industry standards. <br />OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) Plan in section 5 discusses inspections <br />but does not discuss what industry standard the SPCC Plan is following. Section 5 does not discuss testing each <br />aboveground container for integrity on a regular schedule and when repairs are made. <br />REGULATION GUIDANCE: 112.8(c)(6) Test or inspect each aboveground container for integrity on a regular schedule <br />and whenever you make material repairs. You must determine, in accordance with industry standards, the appropriate <br />qualifications for personnel performing tests and inspections, the frequency and type of testing and inspections, which <br />take into account container size, configuration, and design. Comparison records must be kept. Container supports <br />and foundations, outside of container for deterioration, discharges or accumulation of oil in dikes areas must be <br />inspected. <br /> 54 <br />FA0004254 PR0523373 SC001 12/03/2024 <br />EHD Rev. 12/06/2021 CP22 - AST Non-Qualified OIRPage 8 of 10 <br />1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD