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State of California Department of Corrections & Rehabilitation Memorandum Date July 22, 2016 JUL 2 2 2L1 ToSan Joaquin County , 1 � ' Environmental Health Department Attn . : Elena Manzo , Senior REHS From : CDCR - Deuel Vocational Institution SUBJECT : Return to Compliance Statement This Statement is to response to the Aboveground Storage Act Inspection Report at Deuel Vocational Institution on several deficiencies that have been noted during facility inspection on May 24 -25 , 2016 , as specified below: The violation identified as # 102 and #720 were corrected and addressed in a certified letter dated June 20 , 2016 . For item # 102 , Prison Industry Authority will be arranging to have the closed tanks shipped or picked up by a metal recycling operation for disposal . For item #720 the single wall portable tank will continue to be maintained on a secondary containment pallet, however it will be recommended that the tank is replaced with a new double wall tank which will also be stored on a secondary spill pallet . Storage of fuel in current and future replacement tank will be limited to 20 gallons when not in use . The SPCC plan will be updated with this information and when the tank is replaced . Violations #201 , 301 , 303 , 604 , 613 & 617 referencing the DVI SPCC plan are being addressed with a revised SPCC plan and is being processed through the Archetictural and Engineering Department of CDCR . Due to the need to provide secondary containment and leak detection systems for single wall tanks , the revised plan will not be completed until secondary containment is developed and leak detection systems purchased . Alternatively , the Environmental and Regulatory Compliance Section , Facility Management , Planning and Construction is developing recommendations to replace tanks with double wall tanks and leak detection systems . Due to the Department of General Services requirements for tank installations , the purchasing , permitting , inspection , approval and installation process may take up to 6 months . DVI will update the San Joaquin County Environmental Health Department on the progress of this action as the status changes . DVI will ensure regular inspections on these tanks to ensure integrity . # 613 — CFR 112 . 7 (e ) — failure to conduct inspections or maintain records for 3 years . Facility has conducted required regular monthly inspections of all ASTs , including 180 gal Flood Control Ditch pump in question . Copies of 3 years inspection check lists are attached to this Statement. However in order to improve our records keeping practices we have trained responsible staff members to utilize inspection form that is specified in our Plan . # 617 — CFR 112 . 7 ( g ) — Plan failed to address lighting provisions . Current Plan is addressing lighting provisions for each tank at Table A- 1 . However as current Plan is under revision and per your recommendations we will address general lighting and security in ° CDC 1617 (3/89)