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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 # 614 CFR 112.7(c) Failure to provide appropriate secondary containment, diversionary structures or equipment. OBSERVATION: The facility failed to provide adequate general containment for the elbow/union fill connection to the 15,000 gallon diesel tank. A crack was observed on the floor of the concrete berm. 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 provide adequate general containment measures for the piping capable of containing oil and constructed so that any discharge will not escape the containment system before cleanup occurs. Submit proof of correction to the EHD. This is a Class II violation. 620 CFR 112.7(f)(1) Failed to train personnel on all discharge prevention details listed in this section. OBSERVATION: It appears that the oil handling personnel were not adequately trained, as required. Section 3.5 states "this facility is required to train employees in compliance with OSHA and EPA requirements." The plan has Appendix J as the training policy. Per Environmental Manager Matt Lewis, a different training form is used and the criteria required in the plan is different. REGULATION GUIDANCE: (f)(1) At a minimum, train your oil-handling personnel 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 facility SPCC Plan. CORRECTIVE ACTION: Immediately update the training plan and ensure that all oil handling personnel are properly trained. Submit a copy of the SPCC plan corrections and proof of current training 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 8 of 9 1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjgov.org/EHD