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Spill Prevention Control and Countermeasure Plan Food Express, Inc. 1250 Madruga Road FOOD EXPRESS, INC. Lathrop, California 95330 May 2020 Page 12 4.0 POTENTIAL DISCHARGES, CONTAINMENT, AND CONTAINMENT IMPRACTICABILITY DETERMINATION [40 CFR §112.7(6-D)]: 4.1. POTENTIAL DISCHARGES AND CONTAINMENT [40 CFR§112.7(6) & (C)]: Table 2 provides a prediction of the direction, rate of flow, and total quantity of oil that could be potentially discharged from equipment failure at the facility. In addition, the table provides the containment and/or diversionary structures from each area where there is a potential for a discharge to navigable waters. 4.2. CONTAINMENT IMPRACTICABILITY DETERMINATION [40 CFR §112.7(D)]: The aforementioned containment structures noted in the table above appear adequate and are installed according to 40 CFR 112.7(c) and (h)(1) and 112.8(c)(2) and (c)(11); therefore, no impracticability statement is being made. If the installation of a secondary containment structure is found to be impracticable, this SPCC Plan must clearly explain why such measures are not practicable and conduct periodic integrity testing on bulk containers and associated piping and valves. In addition, an oil spill contingency plan must be developed according to 40 CFR 109 and include a written commitment of labor, equipment, and materials to expeditiously control and remove any quantity of oil discharged. 5.0 INSPECTIONS, TESTS AND RECORDS [40 CFR §112.7(E)]: Oil and chemical storage containers, equipment and related secondary containment structures must be visually examined in accordance with written procedures for signs of deterioration or leaks on a regular and routine basis. Records of visual inspections and tests kept under usual business and customary business practices will suffice for purposes of compliance with 40 CFR §112.7(e). Deficiencies or problems must also be documented on an inspection form along with the corrective action. Records of the inspections and tests, signed by the appropriate supervisor or inspector, must be kept with the SPCC Plan for a period of at least three years. These inspection records are maintained in Appendix F of this SPCC Plan. 6.0 PERSONNEL, TRAINING, AND DISCHARGE PREVENTION PROCEDURES [40 CFR §112.7(F)]: 6.1. TRAINING [40 CFR§112.7(F)(1)]: At a minimum, all oil-handling personnel must be trained within 30 days of hire. Initial training must involve whom to notify if a discharge occurs. Employees must also be trained annually in the following (at a minimum): • Operation and maintenance of equipment to prevent discharges; • Discharge procedure protocols; • Applicable pollution control laws, rules and regulations; • General facility operations; and ATC Page 12