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Pacific Ethanol,Inc. <br /> Item #726 CFR 112.8(c)(8) Plan failed to adequately describe overfill prevention <br /> methods for each container: The fails to discuss overfill prevention for all tanks other <br /> the 2 denatured ethanol tanks. Engineer or update each container installation in <br /> accordance with good engineering practice to avoid discharges. You must provide at least <br /> one of the following devices: (i) High liquid level alarms with an audible or visual signal <br /> at a constantly attended operation or surveillance station. In smaller facilities an audible <br /> air vent may suffice. (ii) High liquid level pump cutoff devices set to stop flow at a <br /> predetermined container content level. (iii) Direct audible or code signal communication <br /> between the container gauger and the pumping station. (iv) A fast response system for <br /> determining the liquid level of each bulk storage container such as digital computers, <br /> telepulse, or direct vision gauges. If you use this alternative, a person must be present to <br /> monitor gauges and the overall filling of bulk storage containers. (v) You must regularly <br /> test liquid level sensing devices to ensure proper operation. Amend the SPCC plan to <br /> include a discussion of overfill prevention for all tanks that fall under APSA regulations. <br /> PES Response: The facility does have overfill protection on the other tanks in the form of <br /> visual liquid levels and high liquid level and low liquid level alarms. Please see the <br /> highlighted section of page 28 and 29 in the SPCC located in Appendix A, that addresses <br /> the overfill prevention for tanks. <br /> 209. 851-4070 <br /> 209.235 .0376 FAX <br /> 3028 NAVY DRIVE <br /> STOCKTON, CALIFORNIA 95206 <br /> www.pacificethanol.com <br />