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Pacific Ethanol, Inc. Item #103 CCR 66262.40 (c) Failed to retain hazardous waste determination including waste analysis on site for 3 years: On 9/13/2017, Manganese (III) Oxide, defoamer, and asphalt petroleum were disposed of as non-hazardous waste. According to the manager, each waste was profiled for hazardous waste determination. The profile information was not available for review during the inspection. A generator shall make a hazardous waste determination and keep a record of any test results, waste analyses, or other determinations made in accordance with hazardous waste regulations for at least three years from the date that the waste was last disposed of. Immediately locate a copy of the waste analysis conducted for the above listed wastes and submit a copy to the EHD. If a copy is unavailable, immediately make a hazardous waste determination and begin managing the above listed wastes under Title 22 hazardous waste regulations. PES Response: On 9/13/2017, Manganese (111) Oxide, defoamer, and asphalt petroleum were disposed of as a non-hazardous waste. A waste determination was completed between the EHS Manager and the contractor hired to remove the waste based on SDS sheets provided to the contractor. See attached email correspondence noting determination and the SDS sheets in Appendix D for each of the three (3) identified materials listed above. Item # 104 CCR 66262.34(d)(2) No Modified Contingency Plan: The emergency coordinator information needs to be updated. The plan currently lists Joe Teubner as the primary coordinator. According to the manager, Jeff Usinger is the new primary coordinator. There must be at least one emergency coordinator on site or on call to coordinate emergency response measures, and the following information must be posted by a phone: the name and phone number of the emergency coordinator; location of fire extinguishers, spill control equipment, and if present, fire alarm; and the phone number of the fire department, unless the facility has a direct alarm. Immediately update the contingency plan and send in the updated information to the EHD for review. PES Response: Immediately following the change in the Plant Manager position the facility's information on CERS was updated and submitted, however the contingency plan was missed. The original form the facility was working off of and continued to work off of was outdated and did not include that portion. The facility has since updated to the new contingency plan form on CERS and has provided corrected emergency contacts for the facility. Please see the submittal and confirmation of submission of the contingency plan on CERS in Appendix E. The facility has not received approval of the updates plan on CERS as of the date of this response. 209. 851-4070 209.235 .0376 FAX 3028 NAVY DRIVE STOCKTON, CALIFORNIA 95206 www.pacificethanol.com