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SPCC Plan Valley Pacific Petroleum Services Escalon Facility Page 11 Fuel delivery operations are performed by VPPS personnel.Procedures and practices are incorporated into initial driver training and typically include: • Oil product delivery drivers training should include instructions to not damage the oil-containing ASTs pipes and appurtenances. • Oil product transfer operations are performed over an impervious surface (concrete pad), where feasible. • Prior to oil product transfer operations,the brake is to be set on the tanker truck. • Oil product delivery drivers are to visually check tank fluid levels before transfer. • The fitting and product transfer hose are to be visually checked for defects and replaced if necessary. • Drip pans/buckets will be utilized under valve hose connections. • Hose ends for ASTs must be valved to limit spillage. • Monitor tank level during transfer. Specific tank charts are available for driver reference located at the Facility tanker truck connection point. Drivers are instructed not to fill storage tanks over 90- percent capacity. • When the transfer operation is complete, the transfer hose must be returned to its proper storage location and fully cleared from all vehicle drive areas. • Prior to leaving the Facility,the tanker truck driver is to inspect the tanker truck for leaks.All tanker truck leaks are to be repaired before the tanker truck leaves the Facility. • Incidental spills must be cleaned up with absorbent materials, which should then be placed into leak-proof containers (55-gallon drums) for proper disposal in accordance with company policy. Spill cleanup materials must be stored in a readily identified, accessible location. Compliance with Facility loading rack requirements includes the following: • Secondary containment with sufficient freeboard for precipitation(i.e. 110-percent capacity)at the loading rack. The specific secondary containment requirements are described in Section 2.4. • Drivers are to utilize a physical prevention method, installing wheel chocks,to keep vehicles from departing before complete disconnection. • Prior to tank truck departure,drivers are to inspect lower most drains and all outlets of such vehicles and tighten, adjust,or replace as necessary to prevent liquid discharge while in transit. 2.10 CONTAINER FAILURE EVALUATION [40 CFR 112.7(i)] The Facility does not contain any field-constructed oil containers. A failure of any of the oil containing ASTs will be evaluated and the AST repaired or replaced as necessary. 2.11 CONFORMANCE WITH REQUIREMENTS [40 CFR 112.70)] This SPCC Plan has been prepared in general conformance with the requirements of Title 40, Code of Federal Regulations, Part 112 and the California Above-Ground Petroleum Storage Act, Chapter 6.67 of the California Health and Safety Code, Sections 25270 through 25270.13. �al� CN4