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Environmental Health Department AMENDED 2/2/2024 Aboveground Petroleum Storage Act Inspection Report Date: January 18, 2024 Facility Address: 3940 N TRACY BLVD, TRACY Facility Name: H&S ENERGY PRODUCTS, LLC 3084 SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) RemarksItem # 601 CFR 112.7 Failure of Plan to fulfill basic requirements including a cross-referencing section. OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) Plan reviewed at the time of inspection did not follow the order or requirements of 40 CFR Part 112.7. The plan does not include an adequate cross-reference section. In addition, some information was incorrectly referenced such as section 1.6 which states "table 1-2 presents a cross-reference of plan sections relative to applicable parts of 40 CFR part 112." Table 1-2 was not found in the SPCC plan. REGULATION GUIDANCE: If you are the owner or operator of a facility subject to this part you must prepare a Plan in accordance with good engineering practices. The Plan must have the full approval of management at a level of authority to commit the necessary resources to fully implement the Plan. You must prepare the Plan in writing. If you do not follow the sequence specified in this section for the Plan, you must prepare an equivalent Plan acceptable to the Regional Administrator that meets all of the applicable requirements listed in this part, and you must supplement it with a section cross-referencing the location of requirements listed in this part and the equivalent requirements in the other prevention plan. If the Plan calls for additional facilities or procedures, methods, or equipment not yet fully operational, you must discuss these items in separate paragraphs and must explain separately the details of installation and operational start-up. CORRECTIVE ACTION: Ensure that your SPCC Plan follows the required SPCC rule sequence and/or includes adequate cross-reference. Provide proof of correction to the EHD. This is a Class II violation. 605 CFR 112.7(a)(3), 25270.4.5(a) Plan failed to include an adequate facility diagram, or no facility diagram was included. OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) Plan failed to include an adequate facility diagram. The diagram was missing the following information: -Per the SPCC plan, the facility can store up to four 55 gallon steel drums on site for petroleum waste. During the inspection, two 55 gallon drums containing petroleum product was observed on site. One of the drums was labeled "Liquid/Gasoline." The storage location of the drums were incorrectly marked on the map. In addition, the contents of the drums were not labeled. REGULATION GUIDANCE: (3) Describe in your Plan the physical layout of the facility and include a facility diagram, which must mark the location and contents of each fixed oil storage container and the storage area where mobile or portable containers are located. The facility diagram must identify the location of and mark as “exempt” underground tanks that are otherwise exempted from the requirements of this part under § 112.1(d)(4). The facility diagram must also include all transfer stations and connecting pipes, including intra-facility gathering lines that are otherwise exempted from the requirements of this part under § 112.1(d)(11). CORRECTIVE ACTION: Ensure that the SPCC plan includes a complete facility diagram. Provide proof of correction to the EHD. This is a Class II violation. FA0008057 PR0536557 SC001 01/18/2024 EHD 28-01 Rev. 12/06/2021 Aboveground Petroleum Storage Act OIRPage 5 of 9 1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD