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1 j i I The following is an itemized list of aboveground petroleum storage act violations that have not been addressed for ESCALON UNIFIED SCHOOL DIST as of May 10, I 2019. Open violations from July 16, 2018 inspection Violation#203 -Failure to implement the SPCC Plan. The SPCC plan states that Appendix E of the plan will be posted next to loading areas. Appendix E, describing unloading/loading procedures was not seen posted near the loading/unloading areas. The SPCC plan calls for spill kits to be placed near the dispensers, spill kits were not observed near the dispensers. The owner or operator or an I onshore or offshore facility subject to this section must prepare in writing and implement a Spill Prevention Control and Countermeasure Plan (hereafter"SPCC Plan"or"Plan")," in accordance with § 112.7 and any other applicable I section of this part. Implement the SPCC plan as written or amend the plan to reflect actual facility procedures. i Violation#301 -Failed to amend Plan as necessary. The 500 gallon used oil aboveground storage tank described as being in the diked area next to the 10,000 gallon diesel tank is no longer at the site and a square blue used oil tank outside of the diked area, near the oil water separator is not mentioned in the SPCC plan. The Spill Prevention, Control, and Countermeasure (SPCC) Plan must be amended when there is a change in the facility design, construction, operation, or maintenance that materially affects its potential for a discharge, within 6 months of the change, and implemented as soon as possible, not later than 6 months following preparation of the amendment. Immediately make all necessary amendments to the SPCC Plan to accurately represent the procedures and policies currently in place at the facility. Violation#302- Failed to review Plan once every five years and/or implement any resulting amendments. The Spill Prevention, Control, and Countermeasure (SPCC) Plan was last reviewed on April 9, 2011 . A review and evaluation of the SPCC Plan must be conducted at least once every 5 years. As a result of this review and evaluation, the SPCC Plan must be amended within 6 months of review, and recertified by a Professional Engineer i if any technical amendments were made. Immediately conduct a review of the facility SPCC Plan and make any necessary amendments. Violation #601 - Failure of Plan to fulfill basic requirements including a cross-referencing section. The Spill Prevention, Control, and Countermeasure (SPCC) Plan does not follow the order or requirements in 40 CFR Part 112, and a cross-reference was not provided. If you do not follow the sequence specified in 40 CFR 112 for the Plan, you must prepare an equivalent Plan and supplement it with a section cross-referencing the location of requirements in 40 CFR 112 and the equivalent Plan. Immediately amend the SPCC Plan to include a cross-reference or to follow the required sequence. Violation#612 - Plan failed to include secondary containment, diversionary structures, or equip to prevent ? discharge. The SPCC plan failed to discuss secondary containment for all tanks besides the 10,000 gallon diesel and the used oil tank that was within the diked area. The 1,000 gasoline tank was partially addressed with the oil water separator f but portions of the tank are over soil that does not slope towards the oil water separator. Secondary containment for petroleum containers over 55 gallons in the shop were not addressed in the SPCC plan. The secondary containment for the new waste oil tank and the 55 gallon drums of used oil outside of the diked area was not i addressed in the SPCC plan. A facility shall provide appropriate containment and/or diversionary structures or equipment to prevent a discharge. The entire containment system, including walls and floor, must be capable of 3 containing oil and must be constructed so that any discharge from a primary containment system will not escape the containment system before cleanup occurs. Immediately provide adequate secondary containment for all III aboveground petroleum storage containers larger than 55 gallons. I I i i Page 1 of 3 r