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PAC1. .v BELL FACILITY — UE656 Potential Spills * opills may occur by a variety of p-ssible failures. These may include tank failure, gasket or connection failure, pipe A* B** Type of Concern Description crack or failure, overfill or filling activity, draining incident or other causes due to equipment failure and/or operator ✓ vandalism error. All other aspects are well protected from potential ✓ Valve Failure spills. This installation uses a supply -return piping system. Fuel is withdrawn from the tank by suction produced by a ✓ Rupture ✓ TruckNehicle Damage fuel pump at the engine. The return line recirculates surplus fuel back to the tank. Any significant supply line failure would cause air to enter the line which would kill the engine ✓ Lightning rotection in lace ✓ overfill(Procedures in place & alarm and stop the fuel pump. The resulting potential loss in this scenario would be the volume of fuel contained in the pipeline. Failure of the return line would probably ✓ Maintenance discharge the recirculated fuel. The portion of the lines below grade are double contained and continuously ✓ Corrosion monitored by a liquid sensor. ✓ Flood ✓ k Pi- r Pk - * A check here indicates that the spill potential is relatively higher from this cause than others. ** A check here indicates that reasonable/standard types of measures are in place to make a spill less likely. Prediction of A spill at the tank would surface flow across the paved yard to a storm drain inlet located just north of the installation. Flow Direction ReceivingI The onsite drainage system ties into the municipal system. The storm drainage in this area flows to the Delta. Water Flow Rate Supply piping failure can be considered to be an instantaneous release of pipe contents. Return piping failure could release all fuel that is recirculated to the tank. The fuel recirculation rate is a function of engine design and generator load. A reasonable planning estimate is that up to 15 gallons per hour could be released from returni mi . Total Potential overfill events could result in loss of tens of gallons or more. Overfill events during delivery would be Potential limited to the contents of the delivery vehicle compartment. However, due to the mechanical and administrative Discharge controls governing delivery operations (see below) the total release anticipated in this scenario would be on the order of a few gallons. Total discharge from supply piping failure is estimated to be on the order of 10 gallons of fuel or less. Total discharge from return piping failure depends on the engine design, generator load, and duration of the engine run. A reasonable estimate is that if the generator is running for an extended time, a Power Maintenance Technician would visit the site within 12 hours. The resulting potential release would then be less than 200 gallons. Although unlikely, more catastrophic release scenarios may result in loss of the contents of the tank. The 3,000 -gallon Enviro-Vault aboveground fuel storage tank is a cylindrical concrete vaulted double wall steel tank. The inner tank is totally enclosed within a bladder to provide corrosion protection as well as an immediate path for an external monitor. The annular space between the primary tank and the secondary is filled with a minimum of six inches of light concrete to provide a minimum two-hour fire protection. All tank penetrations are through the top of the secondary containment. The tank is anchored to the concrete foundation slab. The supply and return piping between the tank and the generator engine are steel piping installed aboveground. The supply and return piping is secondarily contained within clear secondary from the valves on top of the tank to the ells and unions outside of the generator enclosure including the sections of flexible pipe. 4of10