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The following is an itemized list of aboveground petroleum storage act violations that have not been addressed for ESCALON UNIFIED SCHOOL DIST as of September 29, 2021. Open violations from August 06, 2021 inspection Violation#706-Failed to provide and maintain adequate secondary containment for bulk storage tanks. OBSERVATION: The facility failed to provide and maintain secondary containment for bulk storage tank installations sufficient to hold the capacity of the largest container, including adequate freeboard for precipitation. -The 10,000 gallon diesel tank was observed with insufficient secondary containment. In the floor of the dike in the southwest corner there is a hole with a pipe in it. -Secondary containment for the used oil, motor oil,gasoline and transmission oil tanks was not discussed in the SPCC plan. The 1,000 gasoline tank was partially addressed with the oil water separator but portions of the tank are over soil that does not slope towards the oil water separator. REGULATION GUIDANCE: (c)(2)Construct all bulk storage tank installations(except mobile refuelers and other non-transportation-related tank trucks)so that you provide a secondary means of containment for the entire capacity of the largest single container and sufficient freeboard to contain precipitation.You must ensure that diked areas are sufficiently impervious to contain discharged oil. Dikes, containment curbs, and pits are commonly employed for this purpose. You may also use an alternative system consisting of a drainage trench enclosure that must be arranged so that any discharge will terminate and be safely confined in a facility catchment basin or holding pond. CORRECTIVE ACTION: Immediately provide and maintain adequate secondary containment for the following bulk storage tanks: 10,000 gallon diesel tank. Submit proof of correction to the EHD. ❑ This violation was corrected ❑This violation will be corrected by(date): ❑ Supporting documents included Describe actions taken or will be taken to correct violation: Violation#711 -Plan failed to adequately discuss procedures to test or inspect each container for integrity. OBSERVATION: The Spill Prevention, Control, and Countermeasure(SPCC)Plan does not adequately discuss procedures to test or inspect each aboveground container for integrity in accordance with industry standards. The referenced industry standard, STI SP001,frequency of formal inspections is not mentioned in the SPCC plan. REGULATION GUIDANCE: (c)(6)Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs.You must determine, in accordance with industry standards,the appropriate qualifications for personnel performing tests and inspections, the frequency and type of testing and inspections,which take into account container size, configuration, and design (such as containers that are: shop-built,field-erected, skid-mounted, elevated, equipped with a liner, double-walled, or partially buried). 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.You must keep comparison records, and you must also inspect the container's supports and foundations. In addition,you must frequently inspect the outside of the container for signs of deterioration,discharges, or accumulation of oil inside diked areas. Records of inspections and tests kept under usual and customary business practices satisfy the record keeping requirements of this paragraph. CORRECTIVE ACTION: Ensure that the SPCC Plan adequately discusses facility's procedures to test and inspect aboveground/bulk storage containers in accordance with all applicable industry standards. This discussion must include, but not be limited to, inspection/testing schedule/frequency, and personnel qualifications. Submit proof of correction to the EHD. Page 6 of 8