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SAN JOAQUIN Environmental Health Department Aboveground Petroleum Storage Act Inspection Report Facility Name: ESCALON UNIFIED SCHOOL DIST Facility Address: 1 1176 STANISLAUS ST, ESCALON Date: July 16, 2018 SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) Item # Remarks 618 CFR 112.7(e), 112.8(c)(6) Failed to keep records of procedures, inspections, or integrity tests for three years. The inspection forms being used are not the forms provided by Spill Prevention, Control, and Countermeasure (SPCC) Plan, and in some instances, do not contain the same information. The forms presented as inspections meeting the SPCC requirements were labeled as Vapor Recovery Inpections. Inspections and tests must be conducted and stored in accordance with the written procedures developed for this facility in the SPCC Plan. Immediately begin conducting all inspections and tests in accordance with the procedures in the SPCC Plan, or amend the Plan and have it recertified by a Professional Engineer to accurately reflect the inspection procedures currently followed at the facility. This is a Class II violation. 619 CFR 112.7(0(1) Failed to train personnel on all discharge prevention details listed in this section. Oil handling personnel were not trained or logs of trainings were not kept as described in the SPCC plan. At a minimum, oil handling personnel shall be trained in the operation and maintenance of equipment to prevent discharges; discharge procedure protocols; applicable pollution control laws, rules, and regulations; general facility operations; and the contents of the Spill Prevention, Control, and Countermeasure Plan. Immediately provide this training to all oil handling personnel and submit a copy of the training log to the EHD. This is a Class II violation. 622 CFR 112.7(0(3) Failure to conduct complete annual discharge prevention briefings for oil -handling personnel. Discharge prevention briefings are not scheduled at least once a year. Discharge prevention briefings for oil handling personnel must be scheduled and conducted at least once a year to assure adequate understanding of the SPCC Plan for that facility. Such briefings must highlight and describe known discharges or failures, malfunctioning components, and any recently developed precautionary measures. Immediately schedule and conduct a discharge prevention briefing, ensure that they are scheduled and conducted at least once a year. This is a minor violation. 710 CFR 112.8(c)(6) Plan failed to adequately discuss procedures to test or inspect each container for integrity. The referenced industry standard STI SP001 frequency of formal inspections is not mentioned in the SPCC plant. The the size, configuration, or design of the tank must be taken into consideration for formal inspections under industry standards. Each aboveground container shall be tested and inspected for integrity on a regular schedule and whenever repairs are made. The qualifications of personnel performing tests and inspections, frequency and type of testing and inspections that take into account container size, configuration, and design shall be determined in accordance with industry standards. 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. Comparison records and other records of inspections and tests must be maintained on site. Immediately conduct the necessary testing and submit a copy of the test results to the EHD, or provide equivalence as allowed by CFR 112.7(a)(2). This is a Class II violation. FA0003822 PR0528253 SCO01 07/16/2018 EHD 28-01 Rev. 11/07/2017 Page 6 of 8 Aboveground Petroleum Storage Act OR 1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjcehd.com