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SPILL PREVENTION,CONTROL AND COUNTERMEASURE DISCHARGE PREVENTION MEASURES,CONTROLS,AND PLAN(SPCC) COUNTERMEASURES Pacific Ethanol,Stockton. inspections will be acted upon in a manner consistent with environmental, safety, and good management practices. Records of the formal inspections and tests will be maintained for a minimum of 3 years. Inspection reports shall be signed and dated by the inspector and discrepancies must be noted. If a problem is found, the designee will review and sign the report and shall act on the identified problems. These reports shall be maintained by the Facility Coordinator or its designee along with this SPCC Plan, which must be available for review for at least 3 years. The internal floating roof ASTs at PES are required to undergo integrity tests on a regular basis, and whenever material repairs are made. The container size and design should be used to determine the frequency and type of test to be performed. Containers smaller than 55 gallons are not subject to integrity testing. Testing techniques such as hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or another system of non-destructive testing may be used. PES has opted to perform the 5 year integrity tests and will complete according to API 653.. A copy of inspection and testing results should be available for federal and state inspectors upon request and the presentation of proper credentials. Prior to the start-up of operations, hydrostatic testing was performed on the denatured ethanol, 190 and 200 proof ethanol, and denaturant tanks at PES. In addition, visual inspections of aboveground tanks are performed on a regular basis, including inspection of the ASTs' supports and foundations for signs of failure or leakage, and the exterior should be inspected for signs of deterioration, and discharges. Records of all tank inspections and tests are kept under a separate file. Diked areas should also be inspected for accumulation of liquids per PES's Industrial SWPPP. 6.4 Personnel, Training, And Discharge Prevention Procedures [112.7(F)] 6.4.1 Personnel Training and Discharge Prevention Briefings[112.7(0(1) and(3)] Personnel Instructions: Affected personnel at the Facility will be trained, at least annually, on the requirements and purpose of this Plan. The Responsible Person (identified in Section 4.1) or a designee is responsible for properly instructing personnel in the operation and maintenance of equipment to prevent the discharge of stored material and applicable pollution control laws, rules, and regulations. Each person associated with the Facility will be given the general inspection requirements and will be at least partially responsible for some of the requirements on a daily basis. All personnel shall be instructed in the following Plan requirements: 1. Tank volumes will be checked prior to filling to prevent overflow. 2. There will be no loading/unloading operations unless the equipment is attended. The specific requirements are: 1. No tanks or compartments will be filled without a prior review of the reserves. Reserves will be checked with the material coordinator and the current gauge reading will be recorded. 2. Physical spot checks will be conducted of all aboveground valves and pipelines on such items as flange joints, expansion joints, valve glands and bodies, and pipeline supports. 3. All storage tanks will be visually examined for oil leaks that result in a loss of oil from tank seams, gaskets, rivets, and bolts. Such examination will include the foundation and supports of tanks that are above the ground surface. (Responsible Person will be notified of any defects.) 4. All pump operations, loading and unloading will be attended continuously. A mat or cap will be placed over the drain in the parking lot during tank truck unloading. www.erm.com Project No:0453993 Pacific Ethanol 28 September 2018 Page 22