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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 # 613 CFR 112.7(c) Plan failed to discuss general secondary containment, equipment, or structures to prevent discharge. OBSERVATION: The Spill Prevention, Control, and Countermeasure (SPCC) Plan failed to discuss the appropriate general containment, diversionary structures, or equipment to prevent discharge, including typical failure mode and most likely quantity of discharge for the 55 gallon drums that are stored on site. Inconsistencies were noted in the plan. Per Table G-3 and Table 3-1, secondary containment is stated as "N/A." Section 4.2.1 of the plan states "55-gal drums in use with liquid petroleum are to sit on a containment pallet." REGULATION GUIDANCE: (c) Provide appropriate containment and/or diversionary structures or equipment to prevent a discharge as described in § 112.1(b), except as provided in paragraph (k) of this section for qualified oil-filled operational equipment, and except as provided in § 112.9(d)(3) for flowlines and intra-facility gathering lines at an oil production facility. The entire containment system, including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system, such as a tank, will not escape the containment system before cleanup occurs. In determining the method, design, and capacity for secondary containment, you need only to address the typical failure mode, and the most likely quantity of oil that would be discharged. Secondary containment may be either active or passive in design. At a minimum, you must use one of the following prevention systems or its equivalent: (1) For onshore facilities: (i) Dikes, berms, or retaining walls sufficiently impervious to contain oil; (ii) Curbing or drip pans; (iii) Sumps and collection systems; (iv) Culverting, gutters, or other drainage systems; (v) Weirs, booms, or other barriers; (vi) Spill diversion ponds; (vii) Retention ponds; or (viii) Sorbent materials. CORRECTIVE ACTION: Immediately correct the Inconsistencies and ensure that the SPCC plan addresses the general containment, diversionary structures, and equipment in use at the facility to prevent discharge, including typical failure mode and most likely quantity of potential discharge. Submit 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 7 of 9 1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD