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Environmental Health Department <br />CP22 - AST Non-Qualified Inspection Report <br />Date: <br />December 12, 2024 <br /> Facility Address: <br /> 12745 N THORNTON RD, LODI <br /> Facility Name: <br /> NORTHERN CALIF POWER AGENCY <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 112.3 4030038 - SPCC has been implemented. <br />OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) Plan was not implemented, as required. <br />The SPCC plan indicates that the following inspections listed below are to be done on a regular basis. At time of <br />inspection, the content of the listed inspections are not being inspected on a regular basis. <br />- STI SP001 monthly inspection checklist <br />- STI SP001 Annual inspection checklist <br />- Monthly spill kit inspection log <br />- STI SP001 Portable Container Monthly Inspection Checklist <br />REGULATION GUIDANCE: 112.3: The owner or operator or an onshore or offshore facility subject to this section must <br />prepare in writing and implement a Spill Prevention Control and Countermeasure Plan (hereafter “SPCC Plan” or <br />“Plan”),” in accordance with § 112.7 and any other applicable section. 25270.4.5.(a): An owner or operator shall <br />conduct periodic inspections of the storage tank to ensure compliance with Part 112 (commencing with Section 112.1) <br />of Subchapter D of Chapter I of Title 40 of the Code of Federal Regulations. In implementing the spill prevention control <br />and countermeasure plan, an owner or operator shall fully comply with the latest version of the regulations contained in <br />Part 112 (commencing with Section 112.1) of Subchapter D of Chapter I of Title 40 of the Code of Federal Regulations. <br />CORRECTIVE ACTION: Implement the SPCC plan, as required. Submit proof of correction to the EHD. <br />This is (Class 2) Violation. <br /> 3 <br />Code of Fed Regulations 112.7(e), 112.8(c)(6) 4030015 - Aboveground containers tested or inspected for integrity <br />based on industry standards. <br />OBSERVATION: Facility failed to inspect each aboveground container for integrity based on industry standards, as <br />discussed in the SPCC Plan: <br />The SPCC plan indicates that the following inspections are to be done on a regular basis (or its equivalent): <br />- STI SP001 monthly inspection checklist <br />- STI SP001 Annual inspection checklist <br />- Monthly spill kit inspection log <br />- STI SP001 Portable Container Monthly Inspection Checklist. <br />- Per Michael Fallon, the inspection that is conducted on a monthly basis fulfills all the above inspections. After <br />evaluating the content within the inspection checklists in the above mentioned list to the current questions addressed <br />in the facility's monthly inspection, it appears many aspects of the required inspections are not being addressed. <br />The current inspection log utilized by the facility lacks but is not limited to the following: <br />- no mention of spill kit <br />- interstitial space of double wall tank is not evaluated for water <br /> 56 <br />FA0010481 PR0536087 SC001 12/12/2024 <br />EHD Rev. 12/06/2021 CP22 - AST Non-Qualified OIRPage 5 of 6 <br />1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD