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Environmental Health Department CP22 - AST Non-Qualified Inspection Report Date: October 30, 2024 Facility Address: 1176 STANISLAUS ST, ESCALON Facility Name: ESCALON UNIFIED SCHOOL DIST SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) RemarksItem # Code of Fed Regulations 112.7(e), 112.8(c)(6) 4010021 - Written Inspection/testing procedures kept, inspection/testing records signed, kept for 3 years. OBSERVATION: Monthly and annual inspection records as discussed in the SPCC Plan were not observed on site. Per SPCC Plan monthly and annual inspection records are to be conducted on the forms located in appendix C and D. REGULATION GUIDANCE: 112.7(e) Conduct inspections and tests required by this part in accordance with written procedures that you or the certifying engineer develop for the facility. CORRECTIVE ACTION: Immediately begin conducting all inspections and tests in accordance with the procedures outlined in the SPCC Plan and begin using forms provided by the SPCC plan. Keep written inspection procedures and records of inspections and testing signed by the appropriate supervisor/inspector for at least three years. Submit proof of correction to the EHD. This is a repeat violation (Class 2) Violation. 57 Code of Fed Regulations 112.7(a)(1), 112.8(c)(8) 4010056 - SPCC adequately describes overfill prevention methods, and devices/systems used for each container. OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) Plan failed to adequately describe the overfill prevention methods, including a description of the devices or systems in place for each container to prevent overfills. The SPCC Plan discussed all tanks have a direct-reading gauge but also that all ASTs are equipped with high-level alarms that sound at 90% capacity. The high-level alarm was only observed on the diesel tank. REGULATION GUIDANCE: 112.7 (a)(1) Include a discussion of your facility's conformance with the requirements listed in this part [§112.7]. 112.8 (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 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. (v) You must regularly test liquid level sensing devices to ensure proper operation . CORRECTIVE ACTION: The SPCC plan shall adequately address overfill prevention methods, including a description of the devices or systems in place for each container to prevent overfills. Provide proof of correction to the EHD. This is a repeat violation (Class 2) Violation. 59 Code of Fed Regulations 112.8(c)(8)(v) 4030022 - Liquid level sensing devices regularly tested to ensure proper operation. OBSERVATION: Liquid level sensing devices for the all tanks have not been tested. Per the SPCC Plan, the sensing devices are inspected monthly during monthly inspections. Monthly inspections were not observed during the inspection. REGULATION GUIDANCE: (c)(8)(v) You must regularly test liquid level sensing devices to ensure proper operation . 61 FA0003822 PR0528253 SC001 10/30/2024 EHD Rev. 12/06/2021 CP22 - AST Non-Qualified OIRPage 8 of 11 1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD