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Stantec • • Mr. Matthew Belair May 23,2012 Page 4 of 5 Upon detection of a spill, Delicato would contact their 24-hour Response Contractor, whose typical response time is one (1) hour from the time of notification, weather and traffic permitting. The quick response and the slow percolation rate at the Site (4-inches per hour) would ensure cleanup of a potential discharge of oil before it could reach navigable waters via percolation. Factor #2: Whether the facility is adjacent to navigable water and a discharge to the navigable waters could be reasonable expected. Given the 3,000-foot distance between the oil storage areas and the closest tributary to a navigable waterway, Lone Tree Creek; the relatively small size of the worst case discharge planning volume (4,000 gallon) in relation to the distance; the fact that only a portion of the worst case discharge planning volume would likely flow towards Lone Tree Creek, the majority of which would flow over hard surfaces towards Sump #1; and the uneven terrain (comprised of vegetation, multiple roadways and railroad tracks several feet above the level of the Site) over which the oil would need to travel to reach Lone Tree Creek, it is not reasonable to expect that the Site could discharge oil to a navigable water. Factor#3: Whether on-site conduits, such as sewer lines, storm drains, and certain underground features (e.g., power or cable lines, or groundwater), could facilitate the transport of discharged oil offsite to navigable waters. There are no conduits of this nature in the flow path of a potential spill in the direction of Lone Tree Creek. Conduits that do exist (fiberoptic and power cables, running along the dirt road) are located 70- feet west of the Oil Storage Area #2, and do not extend beyond the property boundary, thereby making it impossible for discharges to reach Lone Tree Creek. Factor #4: Whether a unique geological or geographic feature would facilitate the transport of discharged oil off-site to navigable waters. There are no such features that would facilitate the transport of discharged oil off-site to navigable waters. Factor#5: Whether the facility is near a watercourse and intervening natural drainage. There are no watercourses or intervening drainage systems that would facilitate the transport of discharged oil off-site to navigable waters. Factor#6: Whether precipitation runoff could transport to the navigable waters. The weather website: http://www.idcide.comAveathedca/manteca.htm, indicates the annual rainfall in Manteca, California is approximately 13.8 inches, which is not sufficient to cause a deluge of rainwater that would transport discharged oil off-site to navigable waters. Factor#7: The quantity and nature of oil stored. The total volume of oil stored at the Site is 6,380 gallons, for which the worst case discharge planning volume is 4,000 gallons, only a portion of which has the potential to flow in the direction of Lone Tree Creek. This volume of oil is not sufficient to cover the distance and obstructions necessary to reach navigable waters of the United States. Storage Volume. According to the April 18, 2005 SPCC Plan for the Delicato Family Vineyard, the volume of oil stored at the Site is 6,380 gallons. If the potential were to exist for a discharge of oil to navigable waters, SPCC Plan requirements would apply under this requirement(total oil storage greater than 1,320 gallons). Container Size. The largest container at the facility is 4,000 gallon tanker truck. If the potential were to exist for a discharge of oil to navigable waters, SPCC Plan requirements would apply under this requirement (oil storage containers with capacity equal to or greater than 55 gallons).