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Environmental Health Department CP22 - AST Non-Qualified Inspection Report Date: March 11, 2025 Facility Address: 15453 N THORNTON RD, LODI Facility Name: PROFLEET TRUCK LUBE (LUBEZONE INC) □ OUT □ R □ COS4045 - Release/Leaks/Spills - General Local Ordinance 86 □ OUT □ R □ COS4050 - Abandonment/Illegal Disposal/Unauthorized Treatment - General See below 87 □ OUT □ R □ COS4055 - Abandonment/Illegal Disposal/Unauthorized Treatment - General Local Ordinance 88 SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) RemarksItem # Code of Fed Regulations 112.3 4030038 - SPCC has been implemented. OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) Plan was not implemented, as required. - Section 2.14.3 Briefings -- mentions that Oil handling personnel must attend annual discharge prevention briefings/trainings. Additionally, it also mentions that the topics reviewed and the attendance records are retained in the facility training records for a minimum of three years. Lee Burdick mentioned that although the employees have been trained, it does not occur annually and no records were kept. REGULATION GUIDANCE: 112.3: The owner or operator or an onshore or offshore facility subject to this section must prepare in writing and implement a Spill Prevention Control and Countermeasure Plan (hereafter “SPCC Plan” or “Plan”),” in accordance with § 112.7 and any other applicable section. 25270.4.5.(a): An owner or operator shall conduct periodic inspections of the storage tank to ensure compliance with Part 112 (commencing with Section 112.1) of Subchapter D of Chapter I of Title 40 of the Code of Federal Regulations. In implementing the spill prevention control and countermeasure plan, an owner or operator shall fully comply with the latest version of the regulations contained in Part 112 (commencing with Section 112.1) of Subchapter D of Chapter I of Title 40 of the Code of Federal Regulations. CORRECTIVE ACTION: Implement the SPCC plan, as required. Submit proof of correction to the EHD. This is (Class 2) Violation. 3 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 December 13, 2024, did not follow the order or requirements of 40 CFR Part 112.7. -> Doesn’t follow the required SPCC rule sequence and/or doesn’t include adequate cross-reference. - In Section 3.2.8 Effluent Treatment Facilities , it is mentioned that the oil/water separator system in shown in Figure 3. Yet when reviewed, Figure 3 did not showcase the location of the 1,500 gallon oil/water separator. -> It doesn’t have the full approval of management at a level of authority to commit the necessary resources to fully implement the SPCC plan. - When SPCC was initially reviewed in office , the page titled "Management Approval and Designated Person " was not signed by management. While on site, Lee Burdick was asked if a signed copy of this page was available and it was not. Lee then printed the page, reviewed it and signed it. No Further Action needed , this was corrected on site REGULATION GUIDANCE: 40 CFR Part 112.7 If you are the owner or operator of a facility subject to this part you must prepare a Plan in accordance with good cross-reference. The Plan must have the full approval of management at a level of authority to commit the necessary resources to fully implement the Plan. 11 FA0015491 PR0523476 SC001 03/11/2025 EHD Rev. 12/06/2021 CP22 - AST Non-Qualified OIRPage 5 of 8 1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD