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Environmental Health Department CP22 - AST Non-Qualified Inspection Report Date: October 17, 2024 Facility Address: 18260 S Harlan RD, Lathrop Facility Name: Tesla Lathrop SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) RemarksItem # 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 failed to adequately describe the overfill prevention methods, including a description of the devices or systems in place for each container to prevent overfills. Section 5.11.6 of the SPCC plan cites section 3.4, which did not adequately describe the overfill prevention methods. REGULATION GUIDANCE: 112.7 (a)(1) Include a discussion of your facility's conformance with the requirements listed in this part [§112.7]. 112.8 (c)(8) Engineer or update each container installation in accordance with good engineering practice to avoid discharges. You must provide at least one of the following devices : (i) High liquid level alarms with an audible or visual signal at a constantly attended operation or surveillance station. In smaller facilities an audible air vent may suffice. (ii) High liquid level pump cutoff devices set to stop flow at a predetermined container content level . (iii) Direct audible or code signal communication between the container gauger and the pumping station. (iv) A fast response system for determining the liquid level of each bulk storage container such as digital computers, telepulse, or direct vision gauges. If you use this alternative, a person must be present to monitor gauges and the overall filling of bulk storage containers. (v) You must regularly test liquid level sensing devices to ensure proper operation . CORRECTIVE ACTION: The SPCC plan shall adequately address overfill prevention methods, including a description of the devices or systems in place for each container to prevent overfills. Provide proof of correction to the EHD. This is (Class 2) Violation. 59 Code of Fed Regulations 112.20(e) 4010044 - Substantial Harm Criteria certification maintained at the facility as required. OBSERVATION: The facility failed to complete and maintain (at the facility) the Substantial Harm Criteria certification form, and the owner/or operator determined that the facility could not be reasonably expected to cause substantial harm to the environment. The certification form was found in the SPCC plan with "no" answered to all questions, but no signature was provided on the form. REGULATION GUIDANCE: (e) If the owner or operator of a facility determines pursuant to paragraph (a)(2) of this section that the facility could not, because of its location, reasonably be expected to cause substantial harm to the environment by discharging oil into or on the navigable waters or adjoining shorelines, the owner or operator shall complete and maintain at the facility the certification form contained in appendix C to this part and, in the event an alternative formula that is comparable to one contained in appendix C to this part is used to evaluate the criterion in paragraph (f)(1)(ii)(B) or (f)(1)(ii)(C) of this section, the owner or operator shall attach documentation to the certification form that demonstrates the reliability and analytical soundness of the comparable formula and shall notify the Regional Administrator in writing that an alternative formula was used. CORRECTIVE ACTION: The Substantial Harm Criteria certification form was certified by the second day of inspection. This was corrected on site. This is (Class 2) Violation. 78 Overall Inspection Comments: Routine APSA Inspection FA0013586 PR0544269 SC001 10/17/2024 EHD Rev. 12/06/2021 CP22 - AST Non-Qualified OIRPage 7 of 8 1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD