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Spill Prevention Control and Countermeasure Plan Recommendation 7 11 Materials, Inc. Concrete Batch Plant No. 5 2714 Stagecoach Road Stockton, California Page 2 Recommendations (Good Eneineerine Practice): • Maintain sufficient quantities of spill control kits/materials and spill control equipment at all oil storage locations throughout the Facility. These should be stored in locations which are easily accessible by all employees in the event of a spill. • Document fuel delivery compliance with Department of Transportation regulations (Title 49, Code of Federal Regulations, Part 177) and delivery driver qualifications (in the form of a statement from your supplier). • Document all visual inspections/observations of the tanks/petroleum containers at the Facility. • Conduct the monthly inspections as noted in the SPCC Plan (using the form in the SPCC Plan, Appendix 3 or an alternate form) and maintain copies of the inspections for three years at the facility. • Annual training should be provided to all employees to cover spill prevention, control, and countermeasure procedures at the Facility. The Facility will ensure that all training sessions are documented. Training should include, but not limited to, the following items: o General tank operations (for spill prevention) o Visual observations during loading/unloading and reporting leaks to maintenance staff o Spill containment and maintenance staff spill notification. o Institutional controls to prevent oil transfers when visibility is limited by darkness. o Proper use of secondary containment. Secondary containment should be kept clean to quickly and easily determine any release from the oil storage containers. Any liquid accumulation should be removed as soon as possible to maintain the storage capacity of the secondary containment. Implementation of these requirements, recommendations and the revised SPCC Plan does not guarantee that spills or other releases will not occur. However, it will reduce the risk of or the impact from, such an event. Please note that the enclosed revised SPCC Plan requires an Authorized Facility Representative signature on Page iii, and an owner/operator signature on the second page of the Certification of Applicability of the Substantial Harm Criteria in Appendix 5. Respectfully, CONDOR EARTH TECHNOLOGIES, INC. Anthony P. Mazzei, P.E., G.E. Engineering Services Manager Enclosures P:\6000_pp16347 7-11 Materials SPCC Plan Update\Reports\SPCC Rees 20120322 (Rev 20120328).doe ow Nt46 W CONDOR