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Environmental Health Department <br />CP22 - AST Non-Qualified Inspection Report <br />Date: <br />October 30, 2024 <br /> Facility Address: <br /> 1176 STANISLAUS ST, ESCALON <br /> Facility Name: <br /> ESCALON UNIFIED SCHOOL DIST <br />SUMMARY OF VIOLATIONS <br />(CLASS I, CLASS II, or MINOR - Notice to Comply) <br />RemarksItem # <br />discharge occurs (for each type of major equipment failure, specifically 240-gallon used oil tank, 115-gallon <br />transmission/motor oil tank, 80-gallon motor oil tank will be readily usable in an emergency. Submit proof of correction <br />to the EHD. <br />This is (Class 2) Violation. <br />Code of Fed Regulations 112.7(f)(3) 4020002 - Spill prevention briefings are conducted annually. <br />OBSERVATION: Failure to conduct spill prevention briefing for oil-handling personnel at least once a year to assure <br />adequate understanding of the SPCC Plan, including: 1. Known discharges or failures. 2. Malfunctioning components. <br />3. Any recently developed precautionary measures. Per John Lial, training has not been conducted for SPCC Plan in <br />the past couple of years or records cannot be found. <br />REGULATION GUIDANCE: (f)(3) Schedule and conduct discharge prevention briefings for your oil-handling personnel <br />at least once a year to assure adequate understanding of the SPCC Plan for that facility. Such briefings must highlight <br />and describe known discharges as described in § 112.1(b) or failures, malfunctioning components, and any recently <br />developed precautionary measures. <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 a repeat violation (Class 2) Violation. <br /> 32 <br />Code of Fed Regulations 112.8(c)(6) 4010028 - SPCC discusses procedures to test/inspect storage containers for <br />integrity per industry standards. <br />OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) Plan does not adequately discuss <br />procedures to test or inspect each aboveground container for integrity in accordance with industry standards and does <br />not address the following: The frequency and type of testing and inspections based on container size, configuration, <br />and design. The SPCC Plan references on page 12 that a certified inspector periodically evaluates all tanks using the <br />STI Standards but does not define how often "periodically" is. Frequency of formal inspections are not listed in the <br />SPCC Plan. The SPCC Plan also discusses API standard when previously the STI standard was referenced . <br />REGULATION GUIDANCE: (c)(6) Test or inspect each aboveground container for integrity on a regular schedule and <br />whenever you make material repairs. You must determine, in accordance with industry standards, the appropriate <br />qualifications for personnel performing tests and inspections, the frequency and type of testing and inspections, which <br />take into account container size, configuration, and design (such as containers that are: shop-built, field-erected, <br />skid-mounted, elevated, equipped with a liner, double-walled, or partially buried). Examples of these integrity tests <br />include, but are not limited to: visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic <br />emissions testing, or other systems of non-destructive testing. You must keep comparison records , and you must <br />also inspect the container's supports and foundations. In addition, you must frequently inspect the outside of the <br />container for signs of deterioration, discharges, or accumulation of oil inside diked areas. Records of inspections and <br />tests kept under usual and customary business practices satisfy the record keeping requirements of this paragraph. <br />NOTE: PLEASE SEE INSPECTION COMMENTS FOR CORRECTIVE ACTION <br />This is a repeat violation (Class 2) Violation. <br /> 54 <br />FA0003822 PR0528253 SC001 10/30/2024 <br />EHD Rev. 12/06/2021 CP22 - AST Non-Qualified OIRPage 7 of 11 <br />1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD