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i I 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, 2019. i Open violations from July 16,2018 inspection i Violation #613 -Failure to provide appropriate secondary containment, diversionary structures or equipment. The diked area holding the 10,000 gallon diesel tank appears to have potential escape routes for the diesel in the )) event of a release from the primary tank. The seals for the underground pipes appear to be damaged, allowing for liquid to flow into the piped area. A broken cap for an unknown purpose was also observed in the diked area allowing for the possible escape of diesel in the event of a release from the primary containment. 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 containing oil and must be constructed so that i any discharge from a primary containment system will not escape the containment system before cleanup occurs. Immediately provide adequate secondary containment for all aboveground petroleum storage containers larger than 55 gallons. Violation#618 -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. Violation#619 -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 II training to all oil handling personnel and submit a copy of the training log to the EHD. Violation#622 -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 i prevention briefing, ensure that they are scheduled and conducted at least once a year. Violation #710 -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 f 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). 11 k I I Page 2 of 3