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Environmental Health Department <br />CP22 - AST Non-Qualified Inspection Report <br />Date: <br />March 11, 2025 <br /> Facility Address: <br /> 15453 N THORNTON RD, LODI <br /> Facility Name: <br /> PROFLEET TRUCK LUBE (LUBEZONE INC) <br />SUMMARY OF VIOLATIONS <br />(CLASS I, CLASS II, or MINOR - Notice to Comply) <br />RemarksItem # <br />CORRECTIVE ACTION: Discharge prevention briefings for oil handling personnel must be scheduled and conducted at <br />least once a year to assure adequate understanding of the SPCC Plan for that facility. Conduct all required spill <br />prevention briefings. Provide compliance verification to the EHD. <br />This is (Minor) Violation. <br />Code of Fed Regulations 112.20(e) 4010044 - Substantial Harm Criteria certification maintained at the facility as <br />required. <br />OBSERVATION: The facility failed to complete and maintain (at the facility) the Substantial Harm Criteria certification <br />form. <br />- When SPCC was initially reviewed in office , the page titled "Certification of the Applicability of the Substantial Harm <br />Criteria" was not completed. While on site, Lee Burdick was asked if a signed copy of this page was available and it <br />was not. Lee then printed the page, reviewed it and signed it. <br />REGULATION GUIDANCE: (e) If the owner or operator of a facility determines pursuant to paragraph (a)(2) of this <br />section that the facility could not, because of its location, reasonably be expected to cause substantial harm to the <br />environment by discharging oil into or on the navigable waters or adjoining shorelines, the owner or operator shall <br />complete and maintain at the facility the certification form contained in appendix C to this part and, in the event an <br />alternative formula that is comparable to one contained in appendix C to this part is used to evaluate the criterion in <br />paragraph (f)(1)(ii)(B) or (f)(1)(ii)(C) of this section, the owner or operator shall attach documentation to the certification <br />form that demonstrates the reliability and analytical soundness of the comparable formula and shall notify the Regional <br />Administrator in writing that an alternative formula was used. <br />CORRECTIVE ACTION: Lee Burdick signed the Certification of the Applicability of the Substantial Harm Criteria , no <br />further action needed. <br />This was corrected on site. <br />This is (Class 2) Violation. <br /> 78 <br />CA Health and Safety Code 25404(e)(4) 4010 - Administration/Documentation - General. <br />OBSERVATION: The submission to the California Environmental Reporting System (CERS) for the Aboveground <br />Petroleum Storage Act (APSA) program is not current. <br />- Currently the APSA Facility Information in CERS shows that the "Date of SPCC Plan Certification" is 3/20/2019 and <br />this is inaccurate. Based on the SPCC provided by the facility the date of Certification is 12/13/2024. <br />REGULATION GUIDANCE: 25404(e)(4) No later than three years after the statewide information management system <br />is established, each CUPA, PA, and regulated business shall report program data electronically. The secretary shall <br />work with the CUPAs to develop a phase -in schedule for the electronic collection and submittal of information to be <br />included in the statewide information management system, giving first priority to information relating to those <br />chemicals determined by the secretary to be of greatest concern. The secretary, in making this determination shall <br />consult with the CUPAs, the California Emergency Management Agency , the State Fire Marshal, and the boards, <br />departments, and offices within the California Environmental Protection Agency . <br /> 79 <br />FA0015491 PR0523476 SC001 03/11/2025 <br />EHD Rev. 12/06/2021 CP22 - AST Non-Qualified OIRPage 7 of 8 <br />1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD