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0 <br /> Pacific Ethanol, Inc. <br /> I <br /> Pacific Ethanol Stockton Response & Correction to Violations <br /> Item # 603 CFR 112.7(a)(3) Failed to adequately describe the physical layout of the <br /> facility in the plan: The facility diagram is lacking connecting pipes regulated under <br /> APSA. The Spill Prevention, Control, and Countermeasure (SPCC) Plan shall include a <br /> I <br /> facility diagram which must mark the location and contents of each fixed storage <br /> container and the storage area where mobile or portable containers are located. It must <br /> identify the location of and mark as "exempt" underground tanks. It must also include all <br /> transfer stations and connecting pipes, including intra-facility gathering lines. <br /> Immediately update the facility diagram to include all of the required information. <br /> Submit a legible copy of the updated facility diagram to the EHD for review. <br /> PES Response: EPA SPCC guidance for regional inspectors note: Oil-filled equipment <br /> (such as manufacturing equipment) and associated piping present at an SPCC regulated <br /> facility may be difficult to represent on a facility diagram, due to their relative location, <br /> complexity, or design. Recognizing this, EPA allows flexibility in the way the facility <br /> diagram is drawn. An owner/operator may represent such systems in a less detailed <br /> manner on the facility diagram as long as more detailed drawings are maintained at <br /> the facility and referenced in the SPCC Plan. More detailed drawings may include <br /> blueprints, engineering diagrams, or diagrams developed to comply with other local, <br /> state, or federal requirements. The scale and level of detail of the facility diagram may <br /> make it difficult to show small transfer lines or piping within containment structures. <br /> Schematic representations that provide a general overview of the piping service (e.g., <br /> supply/return) may provide sufficient information when combined with a description of <br /> the piping in the Plan. Alternatively, overlay diagrams showing different portions of the <br /> piping system may be used where the density and/or complexity of the piping system <br /> would make a single diagram difficult to read (73 FR 74248, December 5, 2008). <br /> Although the SPCC rule requires that piping be included on the facility diagram, it is not <br /> necessary to include appurtenances associated with the piping. Please see the highlighted <br /> section of page 11 in the SPCC located in Appendix A, that addresses piping layouts for <br /> the facility. <br /> Item # 625 CFR 112.7(h) Plan failed to adequately discuss facility tank car and tank <br /> truck loading/unloading rack. The SPCC plan failed to discuss the rail <br /> loading/unloading rack and its containment. Where loading/unloading rack drainage does <br /> not flow into a catchment basin or treatment facility designed to handle discharges, use a <br /> quick drainage system for tank car or tank truck loading/unloading racks. You must <br /> design any containment system to hold at least the maximum capacity of any single <br /> 209. 851-4070 <br /> 209 .235 .0376 FAX <br /> 3028 NAVY DRIVE <br /> STOCKTON, CALIFORNIA 95206 <br /> www.pacificethanol.com <br />