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1.0 INTRODUCTION AND PLAN ADMINISTRATION Geosyntec has prepared this Spill Prevention, Control, and Countermeasure Plan (SPCC) for Wilbur-Ellis Company. In an effort to develop a more user-friendly document for field personnel, this Plan follows a consolidated template that consists of a front section containing general company policies and facility practices, and an Appendix section (Appendix A) that contains site specific SPCC information for each SPCC regulated facility listed in Table 1. The intention of this approach is to implement a more sustainable Spill Prevention Program by developing a Plan that includes standardized policies and procedures which are consistent across all Wilbur-Ellis locations. The goal is to improve the current program so that field personnel are better trained on how to prevent spills, and in the event of an incident are able to act more quickly while still following appropriate protocols and procedures. This document references several Wilbur-Ellis Environmental Health and Safety (EHS) programs currently in place that comply with SPCC protocol. In an effort to reduce document repetition and volume, while still meeting SPCC requirements, Wilbur-Ellis programs that are applicable to the SPCC plan are referenced and kept on file at the branch. 1.1 INTRODUCTION This SPCC Plan has been prepared and implemented in accordance with the SPCC requirements contained in Title 40 Part 112 of the Code of Federal Regulations (40 CFR 112). This plan is intended to describe the measures implemented by Wilbur-Ellis to prevent discharges of oil products from occurring, and to prepare facilities to respond in the event of a spill in a safe, effective, and timely manner to mitigate the impacts of a discharge. Additionally,this SPCC Plan is intended to serve as a guide for Wilbur-Ellis employees and contractors to: • Review oil/petroleum product storage information and testing records; • Implement best management practices(BMPs); • Prevent and respond to spills; • Complete facility SPCC inspections; and • Provide information for emergency response. When properly implemented, this SPCC Plan can reduce potential environmental impacts to navigable waters of the United States related to the storage and distribution of oil and other petroleum products. 1.2 CROSS-REFERENCE SPCC REQUIREMENTS (40 CFR 112.7) Table 2 presents a cross-reference for the SPCC Plan sections relative to applicable parts of 40 CFR 112. 1.3 CONFORMANCE WITH STATE APPLICABLE REQUIREMENTS (40 CFR 112.7[j]) Additional state requirements (if applicable) are included in the facility-specific site plans provided in Appendix A. 1.4 LOCATION OF SPCC PLAN (40 CFR 112.3[e]) An electronic copy of this SPCC Plan is maintained on the Wilbur-Ellis WEconnect website. Site specific information and supporting documentation (i.e., tank inventory, secondary containment dimensions, facility drainage, emergency contacts, inspections, and training) are maintained at each branch. 1.5 SUBSTANTIAL HARM CRITERIA (40 CFR 112.20[e]) The facilities covered by this SPCC plan do not meet any of the substantial harm criteria, and therefore are 8 June 07,2019