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Environmental Health Department AMENDED 1/28/2025 CP22 - AST Non-Qualified Inspection Report Date: January 17, 2025 Facility Address: 19400 N HWY 99 , ACAMPO Facility Name: J S G TRUCKING COMPANY SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) RemarksItem # adequate SPCC plan review completion to the EHD. This is (Class 2) Violation. Code of Fed Regulations 112.7 4010012 - SPCC in writing, follows code seq/cross ref, good eng practice, mgt approval, items not in place. OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) Plan reviewed at the time of inspection, dated revised October 29, 2019, did not follow the order or requirements of 40 CFR Part 112.7. The SPCC Plan doesn’t follow the required SPCC rule sequence and doesn’t include adequate cross-reference. For example: The Cross-Reference in section 1.7, Table 1-2, indicates that the Professional Engineer Certification for part of 112.3(d) is located in Section 2.2. Section 2.2 of the plan is titled "Wastewater Treatment " and the "Professional Engineer Certification" is found in section 1.3. REGULATION GUIDANCE: If you are the owner or operator of a facility subject to this part you must prepare a Plan in accordance with good engineering practices. The Plan must have the full approval of management at a level of authority to commit the necessary resources to fully implement the Plan. CORRECTIVE ACTION: Ensure that your SPCC Plan complies with the following requirements: 1. It follows the required SPCC rule sequence and/or includes adequate cross-reference. Provide proof of correction to the EHD. This is (Minor) Violation. 11 Code of Fed Regulations 112.7(a)(3) 4010016 - Physical layout of the facility is adequately and accurately described in SPCC. OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) Plan failed to adequately describe the physical layout of the facility and failed to include an adequate facility diagram. The facility diagram was inaccurate and the physical layout description was inaccurate. Trailer offices are indicated as present on the facility in both the description and the facility diagram. Per Derek Crusenberry, these trailers have been removed for multiple years. REGULATION GUIDANCE: (3) Describe in your Plan the physical layout of the facility and include a facility diagram, which must mark the location and contents of each fixed oil storage container and the storage area where mobile or portable containers are located. The facility diagram must identify the location of and mark as “exempt” underground tanks that are otherwise exempted from the requirements of this part under § 112.1(d)(4). The facility diagram must also include all transfer stations and connecting pipes, including intra-facility gathering lines that are otherwise exempted from the requirements of this part under § 112.1(d)(11). CORRECTIVE ACTION: Ensure that the SPCC plan includes a complete facility diagram. Provide proof of correction to the EHD. This is a repeat violation (Class 2) Violation. 14 Code of Fed Regulations 112.7(f)(1) 4020001 - Training provided for op/maint of equip, discharge procedures, laws/regs, general fac ops, and SPCC. OBSERVATION: It appears that the oil handling personnel were not adequately trained, as required. Derek Crusenberry, Vice President, is assigned as the person responsible for the SPCC Plan and relevant procedures and training. Derek was unfamiliar with some requirements and elements of the SPCC plan when questioned during the inspection. Facility failed to provide training to Derek Crusenberry, Vice President, and the oil-handling personnel 30 FA0003748 PR0536577 SC001 01/17/2025 EHD Rev. 12/06/2021 CP22 - AST Non-Qualified OIRPage 6 of 8 1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD