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0 <br /> Pacific Ethanol, Inc. <br /> compartment of a tank car or tank truck loaded or unloaded at the facility. Amend the <br /> SPCC plan to include a discussion of all loading/unloading rack. <br /> PES Response: As noted, the Denatured Ethanol Railcar offloading area was not address <br /> for containment. Please see the highlighted section of page 21 in the SPCC located in <br /> Appendix A, that addresses the containment for the rail offloading and its connection to <br /> the tank farm containment. <br /> Item #710 CFR 112.8(c)(6) Plan failed to adequately discuss procedures to test or <br /> inspect each container for integrity. The SPCC plan states that integrity tests on tanks <br /> are performed per Air Permit 40 CFR 60 subpart Kb, Standards of Performance for VOC <br /> Liquid Storage Vessels. The SPCC plan also mentions STI SP-001 industry standard, <br /> which applies to aboveground storage tanks between 5,000 and 30,000 gallons (per the <br /> SPCC plan), are conducted every 20 years but that facility has opted for the 40 CFR <br /> subpart Kb inspections. The 40 CFR 60 subpart Kb is not an industry standard. The <br /> qualifications of personnel performing tests and inspections is not discussed. The largest <br /> storage tank at the facility regulated under APSA is listed as 582,750 gallons. The <br /> monthly inspections conducted by the facility do not reference an industry standard. Each <br /> aboveground container shall be tested and inspected for integrity on a regular schedule <br /> and whenever repairs are made. The qualifications of personnel performing tests and <br /> inspections, frequency and type of testing and inspections that take into account container <br /> size, configuration, and design shall be determined in accordance with industry standards. <br /> Examples of these integrity tests include, but are not limited to: visual inspection, <br /> hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or <br /> other systems of non-destructive testing. Comparison records and other records of <br /> inspections and tests must be maintained on site. Ammend the SPCC plan to include an <br /> industry standard or standards that apply to all tanks on site, or provide equivalence as <br /> allowed by CFR I I2.7(a)(2). <br /> PES Response: The SPCC plan state that integrity tests on tanks are performed per Air <br /> Permit 40 CFR 60 subpart Kb, Standards of Performance for VOC liquid Storage <br /> Vessels. The facility utilizes API 653 for integrity testing under a corporate mechanical <br /> integrity program and equipment specific SOP'S. The monthly inspections are required <br /> according to the program with standard guidance under API 653. Please see the <br /> highlighted section of page 22 in the SPCC located in Appendix A, that addresses the <br /> correct standard. Please note the storage tanks are, in addition to the API 653 timeline for <br /> testing, are also still inspected under 40 CFR 60 subpart Kb. <br /> 209. 851-4070 <br /> 209 .235 .0376 FAX <br /> 3028 NAVY DRIVE <br /> STOCKrONr CALIFORNIA 95206 <br /> www.pacificethanol .com <br />