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Stantec Consulting Services Inc. 15575 Los Gatos Boulevard, Building C Los Gatos CA 95032 Tel: (408)356-6124 Fax: (408)356-6138 Stantec May 23, 2012 Mr. Matthew Belair Director of Technical Operations Delicato Family Vineyards 12001 South Highway 99 Manteca, California 95336 Reference: Evaluation of the Applicability of Spill Prevention, Control, and Countermeasure (SPCC) Plan Requirements to the Delicato Family Vineyards, 12001 South Highway 99, Manteca, California Dear Mr. Belair: Stantec Consulting Services Inc. (Stantec) is pleased to present this evaluation of the applicability of the Spill Prevention, Control and Countermeasure (SPCC) Plan requirements, codified in Section 112 of Title 40 of the Code of Federal Regulations (40 CFR 112), to the Delicato Family Vineyards (Delicato) located at 12001 South Highway 99, Manteca, California (the Site, see Figure 1). An SPCC Plan was prepared for the Site in June 2005. During the required 5-year review process, consideration was given to the applicability of the requirements to the Site, the criteria for which are listed below: • Discharge Potential. Any owner or operator of a non-transportation-related onshore or offshore facility engaged in drilling, producing, gathering, storing, processing, refining, transferring, distributing, using, or consuming oil and oil products, which due to its location, could reasonably be expected to discharge oil in quantities that may be harmful, into or upon the navigable waters of the United States or adjoining shorelines [40 CFR 112.1(b)]; • Storage Volume. The aggregate aboveground storage capacity of the facility is 1,320 U.S. gallons [40 CFR 112.1(d)(2)(ii)]; and • Container Size. Only containers with a capacity of 55 U.S. gallons or greater are counted. [40 CFR 112.1(d)(2)(ii)] In addition, owners or operators of facilities subject to these requirements must notify the EPA whenever the facility discharges more than 1,000 U.S. gallons of oil in a single discharge to navigable waters of the United States, or discharged more than 42 U.S. gallons of oil to navigable waters of the United States in each of two discharges, occurring within any twelve month period [40 CFR 112.4(a)]. Stantec's evaluation of the applicability of the above criteria and related requirements to the Site is presented in the following paragraphs. BACKGROUND The Delicato Family Winery began operation as a working vineyard and winery in 1936. Personnel at the facility include the Plant Manager, production workers, bottling and warehouse workers, maintenance workers and an office staff. The facility is manned during hours of operation [24 hours a day, 7 days a week during months of production (typically August to November), and 24 hours a day, 5 days a week (Monday through Friday) the rest of the year]. A security officer, trained to observe petroleum spills, is on-site 24 hours a day on weekends and holidays. Site Location. The Site located in the San Joaquin Valley approximately 4 miles north of the City of Manteca, California. According to the Regional Water Quality Control Board, Central Valley Region (the