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The following is an itemized list of aboveground petroleum storage act violations that have not been addressed for RIPON USD-MAINT/OPERATIONS DEPT as of June 17, 2019. Open violations from December 27,2018 inspection Violation#601 -Failure of Plan to fulfill basic requirements including a cross-referencing section. The Spill Prevention, Control, and Countermeasure(SPCC) Plan does not follow the order or requirements in 40 CFR Part 112, and a cross-reference was not provided. If you do not follow the sequence specified in 40 CFR 112 for the Plan,you must prepare an equivalent Plan and supplement it with a section cross-referencing the location of requirements in 40 CFR 112 and the equivalent Plan. Immediately amend the SPCC Plan to include a cross-reference or to follow the required sequence. Violation#612-Plan failed to include secondary containment,diversionary structures,or equip to prevent discharge. Secondary containment for the 55 gallon drums is not discussed in the SPCC plan and does not certify secondary containment as sufficient.The 55 gallon drums were observed on spill pallets that seemed to not be able to hold the entire capacity of the tank. A facility shall provide appropriate containment and/or diversionary structures or equipment to prevent a discharge. The entire containment system, including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system will not escape the containment system before cleanup occurs. Immediately provide adequate secondary containment for all aboveground petroleum storage containers larger than 55 gallons. Violation#618-Failed to keep records of procedures, inspections,or integrity tests for three years. The inspection forms being used are not the forms provided by Spill Prevention, Control, and Countermeasure (SPCC) Plan, and in some instances, do not contain the same information. The forms being used are"Coxial 2-Point Phase 1 and Balance Phase II Vapor Recovery Checklist'along with Throughput records. Inspections and tests must be conducted and stored in accordance with the written procedures developed for this facility in the SPCC Plan. Immediately begin conducting all inspections and tests in accordance with the procedures in the SPCC Plan, or amend the Plan and have it recertified by a Professional Engineer to accurately reflect the inspection procedures currently followed at the facility. Violation#622-Failure to conduct complete annual discharge prevention briefings for oil-handling personnel. Discharge prevention briefings are not scheduled at least once a year. Discharge prevention briefings for oil handling personnel must be scheduled and conducted at least once a year to assure adequate understanding of the SPCC Plan for that facility. Such briefings must highlight and describe known discharges or failures, malfunctioning components, and any recently developed precautionary measures. Immediately schedule and conduct a discharge prevention briefing, ensure that they are scheduled and conducted at least once a year. Violation#710-Plan failed to adequately discuss procedures to test or inspect each container for integrity. The SPCC plan does not set a frequency of inspection for formal inspections under the referenced STI SP-001 industry standard. The plan states that an SP-001 certified inspector must be contacted to determine inspection schedule. Each aboveground container shall be tested and inspected for integrity on a regular schedule and whenever repairs are made. The qualifications of personnel performing tests and inspections, frequency and type of testing and inspections that take into account container size, configuration, and design shall be determined in accordance with industry standards. Examples of these integrity tests include, but are not limited to:visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other systems of non-destructive testing. Comparison records and other records of inspections and tests must be maintained on site. Immediately conduct the necessary testing and submit a copy of the test results to the EHD, or provide equivalence as allowed by CFR 112.7(a)(2). Page 1 of 2