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10.2.5 STORMWATER DISCHARGE PROTECTION AND MONITORING The Port of Stockton has been improved with storm drains that receive surface water and convey it to the San Joaquin River. Storm water discharges from the Port of Stockton are currently regulated under the general National Pollutant Discharge Elimination System(NPDES)industrial storm water Permit No.CAS0000001. Although the Facility is located approximately a half-mile from the San Joaquin River,petroleum hydrocarbons spilled at the DTE Stockton,LLC facility could potentially reach the San Joaquin River if the oil entered the Port of Stockton storm drains. As described in Section 9.2.5,the Facility has been designed to contain rainwater that accumulates in the dikes for the above ground storage tanks and to direct rainfall from undiked areas to a 20,000 gallon underground storage area, which is equipped with an oil/water separator,before discharge to the Port of Stockton storm drains and ultimately to the San Joaquin River. The 20,000-gallon underground tank discharge valve is locked closed at all times until discharge is initiated and water will be visually checked for presence of oil prior to discharge. 10.3 EQUIVALENT ENVIRONMENTAL PROTECTION In accordance with 40 CFR Part I I2.7(a)(2),a facility may deviate from certain aspects of the SPCC Plan requirements provided that equivalent environmental protection is achieved through other means of spill prevention,control,or countermeasure. For this facility,the equivalent environmental protection includes: • Equivalent controls in lieu of the specific catch basin/quick-drainage system for loading and unloading areas required by 40 CFR 112.7(h). The facility contracts with suppliers that use tanker/transport trucks to deliver new oil and/or pickup used oil in bulk. A"quick drainage system"is not required in the loading and unloading areas (USEPA states that quick drainage systems are only required at unloading and loading racks/terminals;not unloading and loading areas). The facility personnel and oil delivery/pickup supplier will provide prevention and control measures per 40 CFR 112.7(c)in these loading and unloading areas through the specific procedures mentioned in Appendix B. • Equivalent controls in lieu of manual,open-and-closed design valves for drainage of bermed areas required by 40 CFR 112.8(b)(2). Closed 55-gallon drums of new motor oil will be stored on the floors indoors or in bermed areas. As these are stored indoors,the store floor and walls serve as secondary containment. Floor drains present in or near the designated drum storage area will be blocked using drain plugs or similar devices to prevent discharge of oil to the floor drain should a spill or leak occur. 10-4 202204_DTEStockton-SPCC_RPT.docx