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Proposal SPCC Plan Update NuCal Foods, Inc. Page 2 The SPCC Plan update prepared by Condor Earth Technologies, Inc. (Condor) will incorporate "good engineering practices including consideration of applicable industry standards." Consequently, the SPCC Plan update may include requirements for improvements to spill prevention and control dictated by the regulations or by "good engineering practices." Task 2 — 2016 SPCC Personnel Training Condor proposes to provide one on-site SPCC Plan training session (approximately 2 hours) that would satisfy the 40 CFR 1 l 2.7 (f) elements highlighted below. A Facility is required, at a minimum, to: • Train oil -handling personnel in the operation and maintenance of equipment to prevent discharges; applicable pollution control laws, rules, regulations; general Facility operations; and, the contents of the Facility SPCC Plan. Schedule and conduct discharge prevention briefings for oil -handling personnel at least once a year to assure adequate understanding of the Facility SPCC Plan. Such briefings must discuss past discharges or failures, malfunctioning components, and any recently developed precautionary measures. Condor recommends updating the SPCC Plan prior to training in order to incorporate Plan changes in the educational material. Cost estimates provided below assume a separate site visit for this task. Task 3 — Small Quantity Hazardous Waste Generator Program Suplmrt A San Joaquin County Environmental Health Department inspection conducted March 4, 2016, revealed several Facility violations. Condor's Senior Principal, Robert Job, is a Certified Professional Environmental Auditor (CPEA), and a licensed Professional Engineer. Mr. Job has been conducting environmental compliance audits for Condor's food processing and packaging clients for nearly 15 years. All audited facilities generated hazardous waste, or used oil, which must be managed as hazardous waste while on site. Mr. Job's past experience is directly applicable to the noncompliance issues faced by NuCal Foods. Continuing education is required to maintain CPEA registration. Mr. Job recently attended a training conference with County inspectors, which included hazardous waste management sessions. Mr. Job offers his knowledge and experience to assist NuCal Foods with hazardous waste and hazardous materials concerns. Work will be conducted concurrently with the SPCC Plan update site activities. Upon completion of inspection Condor will prepare a summary of findings and recommendations letter. LIMITATIONS The SPCC Plan will be written in general conformance with the Federal Oil Pollution Prevention regulations found in Title 40 of the Code of Federal Regulations Part 112 (40 CFR part 112) as of the date of preparation. The SPCC Plan is based on information provided by the Client. No independent mechanical or integrity inspection of the fueling system and its operation, components, and features will be performed. The Scope of Work does not include review of compliance with state and local building, fire, or electrical codes. The Client is solely responsible for implementation of this SPCC Plan. This SPCC Plan will not be complete without full implementation of the requirements of 40 CFR Part 112 and Condor's recommendations. Condor cannot and does not guarantee, assure, or warrant that spills and/or releases will not occur at the Facility. A 1� IL 4) CONDOR