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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 # 610 CFR 112.7(a)(3vi), 112.7(a4) Plan failed to adequately detail information and procedures for reporting a discharge. OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) Plan does not adequately discuss procedures for reporting a discharge. The plan references Appendix H and is titled Agency Notification List. The notification list had the incorrect phone number listed for the San Joaquin County Environmental Health Department. The number listed was (209) 468-4400 and the correct number is (209) 468-3420. REGULATION GUIDANCE: The SPCC plan shall include: (vi) Contact list and phone numbers for the facility response coordinator, National Response Center, cleanup contractors with whom you have an agreement for response, and all appropriate Federal, State, and local agencies who must be contacted in case of a discharge as described in § 112.1(b). (4) Unless you have submitted a response plan under § 112.20, provide information and procedures in your Plan to enable a person reporting a discharge as described in § 112.1(b) to relate information on the exact address or location and phone number of the facility; the date and time of the discharge, the type of material discharged; estimates of the total quantity discharged; estimates of the quantity discharged as described in § 112.1(b); the source of the discharge; a description of all affected media; the cause of the discharge; any damages or injuries caused by the discharge; actions being used to stop, remove, and mitigate the effects of the discharge; whether an evacuation may be needed; and, the names of individuals and/or organizations who have also been contacted. CORRECTIVE ACTION: The phone number was corrected during the inspection. The violation was corrected on site. This is a Class II violation. 612 CFR 112.7(b) Plan doesn't have discharge prediction, including direction, rate of flow, and quantity of oil. OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) Plan failed to predict the direction, rate of flow, and the total quantity of the oil that could be discharged for each type of major equipment failure. The potential equipment failure and the resulting spill from the 55 gallon drums stored on site were not adequately addressed in the SPCC Plan. Inconsistencies were noted in the plan. Per Table G-3, direction of flow states that a release will pool. Per Table 3-1 direction of flow for the drums is listed as "N/A." REGULATION GUIDANCE: (b) Where experience indicates a reasonable potential for equipment failure (such as loading or unloading equipment, tank overflow, rupture, or leakage, or any other equipment known to be a source of a discharge), include in your Plan a prediction of the direction, rate of flow, and total quantity of oil which could be discharged from the facility as a result of each type of major equipment failure. CORRECTIVE ACTION: SPCC Plan shall be updated so that portions describing procedures to be used when a discharge occurs (for each type of major equipment failure, specifically the 55 gallon drums) will be readily usable in an emergency. Submit proof of correction of the inconsistencies 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 6 of 9 1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD