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SPILL PREVENTION,CONTROL AND COUNTERMEASURE DISCHARGE PREVENTION MEASURES,CONTROLS,AND PLAN(SPCC) COUNTERMEASURES Pacific Ethanol,Stockton. tank volume. A worst-case spill in this area would be the total release of one of the denatured ethanol storage tanks. As the rail offload has containment pans for each offloading station (4 total)that drain directly to the tank farm containment, the tank farm containment is adequate for loss of the biggest container which would be an entire railcar. Ethanol tank farm containment calculations can be found in Appendix E. In the event that secondary containment of the tank farm failed, a release would likely travel west, entering the PES storm water drainage system and potentially reach the facility's discharge point located at the east end of PES' property. A release would most likely be contained within the storm water drainage system and cleaned up with the use of onsite and contracted equipment, depending on the spill amount, prior to reaching the unnamed tributary. There are no automatic drainage valves or pumps located in the tank farm. Storm water accumulated in the tank farm containment is only emptied via a manual pump when it has been verified that the storm water has not been contaminated with oil or oil containing product. Storm water(oil free), with and without trace ethanol, will only be released from the tank farm to the process condensate tank when the following have been verified: there are no visual signs of oil (e.g. sheen). Deviation from this process must undergo management review. When such transfers are necessary, storm water is manually pumped from the containment area into a"sump water" poly tank that is then pump back to the process or to the drainage area west of the tank farm containment. . Storm water releases, if any, diverted to the storm drain system must be documented in accordance with PES's Industrial SWPPP as a NSWD 6.1.2 Process/Fermentation Area Storage Process Building includes the facility's two 10,000 gallon corn oil tanks. The process/fermentation area has an indoor drainage system connected to a sump that would collect any spills from the corn oil tanks. The worst case spill scenario would involve the rupture of the corn oil storage tanks. If secondary containment failed, a spill from corn oil loadout would travel east/southeast toward the concrete berm, where it travels southeast toward the Port of Stockton's Storm Water Pond. Corn oil is highly viscous, therefore if a spill occurred, PES employees would be able to contain prior to exiting the loadout area. 6.2 Contingency Planning [112.7(D)] As described above, the Facility has provided adequate secondary containment structures, with the exception of the three transformers south of the boiler building and discharge response procedures and equipment(see Section 5.0). Spill kits are stored near transformers: TRF-D01, TRF-D07 and are ready for deployment in the event of an oil discharge. 6.3 Inspections, Tests, And Records [112.7(E)] Frequent observations of the storage tanks, valves, pumps, and piping will be made by employees. Records will not be made of such observations. All valves and piping will be subject to regular examinations by operation personnel at which time the general condition of items, such as flange joints, expansion joints, valve glands and bodies, piping supports, and metal surfaces will be assessed. A monthly visual inspection of each tank's exterior and associated pumps, valves, piping, and secondary containment will be made by the Responsible Person (identified in Section 4.1) or a designee on a monthly basis using the form shown in Appendix C. Deficiencies noted during informal or formal www erm corn Project No:0453993 Pacific Ethanol 28 September 2018 Page 21