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SAN J 0 A Q I I I Irl Environmental Health Department CCUN r Aboveground Petroleum Storage Act Inspection Report Facility Name: Facility Address: Date: ESCALON UNIFIED SCHOOL DIST 1 1176 STANISLAUS ST, ESCALON August 06, 2021 SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Notice to Comply) Item# Remarks 711 CFR 112.8(c)(6)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. This is a repeat violation, Class II. 715 CFR 112.8(c)(8), 25270.4.5(a)Failed to have a high level monitoring and to engineer or update containers to avoid discharge. OBSERVATION: The SPCC plan states that all tanks are equipped with with direct reading level gauges and high level alarms. Only the 10,000 gallon diesel tank was observed with a direct reading level guage and high level alarm. The gasoline, used oil,transmission oil and motor oil tanks were observed with only direct reading level gauges. REGULATION GUIDANCE: (c)(8)Engineer or update each container installation in accordance with good engineering practice to avoid discharges.You must provide at least one of the following devices: (i) High liquid level alarms with an audible or visual signal at a constantly attended operation or surveillance station. In smaller facilities, an audible air vent may suffice. (ii)High liquid level pump cutoff devices set to stop the flow at a predetermined container content level. (iii)Direct audible or code signal communication between the container gauger and the pumping station. (iv)A fast response system for determining the liquid level of each bulk storage container such as digital computers, telepulse, or direct vision gauges. If you use this alternative, a person must be present to monitor gauges and the overall filling of bulk storage containers. CORRECTIVE ACTION: Ensure the SPCC plan accurately describes the high liquid level monitoring devices for each tank and provide proof of correction to the EHD. This is a repeat violation, Class II. FA0003822 PR0528253 SCO01 08/06/2021 EHD 28-01 Rev.9/16/2020 Page 9 of 11 Aboveground Petroleum Storage Act OIR 1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjgov.org/EHD