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SPCC Plan:Ralph Hayes&Son,Inc., 20177 S.McArthur Dr., Tracy,California(October 2020) 14 oil, and oil will not permeate, drain, or escape from the containment systems and reach navigable waterways before cleanup occurs. Calculations of containment volumes for each of the sized secondary containment structures are provided in Appendix F. 5.1 Containment Systems For bulk storage containers, refer to Table 4 for a description of each tank. Containment systems at the RHS facility and their volumes are described in the following sections. 5.1.1 Bulk Containment Structure Four ASTs and four empty 55-gallon drums are located within the exterior bulk containment structure which is sized to contain the entire volume of the largest tank (10,000 gallons) and additional freeboard for the precipitation from a 24-hour, 25-year rainstorm. The net containment volume of the structure is 15,484 gallons and the remaining containment capacity of the structure is 4,560 gallons. 5.1.2 Double-Walled Tanks Three ASTs constructed with double walls are located within the warehouse. The double-wall tanks have integral secondary containment built in to contain the tank's volume and an additional ten percent volume as a safety factor. 5.1.5 Dispenser Containment (Active) Dispenser systems are connected directly to two of the bulk ASTs located within the bulk containment structure. Active containment in the form of sorbent materials is provided in the immediate vicinity of the dispenser systems. 5.2 Transfer Areas The loading connections associated with the bulk ASTs are located within the bulk containment structure. In addition, the following containment and diversionary structures are used: • Drip Pans:Drip pans are required to have on hand during all filling procedures,whether by an off-site provider or on-site staff. • Sorbent Material: Spill kits that include sorbent material, booms, pads, and other portable barriers are located within close proximity of oil product storage and handling areas for rapid deployment should a spill occur. 6. DETERMINATION OF PRACTICABILITY (REF. 112.7 (d)) Based on the current construction of the facility as discussed herein, all applicable secondary containment structures and pieces of equipment as described in 40 CFR, Part 112, §112.7 and 112.8 have been determined to be practicable. 7. INSPECTIONSITESTS AND RECORDS (REF. 112.7 (e)) RHS has a comprehensive preventive maintenance program.This program is implemented and monitored by the facility's Fleet Manager. Routine visual system inspections of tanks, supports, valves, piping, containment systems, foundations and appurtenances,as well as,periodic inspections of specific facility components are an inherent part of this plan. The AST inspection checklists are provided in Appendix B. These checklists shall be copied and completed during each inspection. Monthly and annual inspections will utilize STI SP001 forms. McGinley Project:RHS001 McGinley&Associates Inc.