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5E5PE <br /> CONSULTING, INC . <br /> 374 Poli Street,Suite 200•Ventura,CA 93001 <br /> Office•(805)2751515 Fax•(805)667-8104 <br /> June 6,2019 <br /> Cesar Ruvalcaba <br /> Registered Environmental Health Specialist <br /> San Joaquin Environmental Health Department <br /> 1868 E. Hazelton Avenue <br /> Stockton,CA 95205 <br /> Re: Aboveground Petroleum Storage Act(APSA) Inspection Report <br /> Concrete,Inc.Knife River Clements Plant—Lodi Facility <br /> COPA Inspection Report Dated April 23,2019 <br /> Dear Mr. Ruvalcaba: <br /> Concrete, Inc. DBA Knife River Clements Plant(Knife River)received your inspection report dated April <br /> 23,2019 outlining the results of the Aboveground Petroleum Storage Act(APSA) Inspection Report that <br /> was conducted at their facility on April 23,2019. <br /> Below is a list of violations identified in your inspection (in italics)followed by Knife Rivers response: <br /> 301 CFR 1125(a):Failed to amend Plan as necessary. <br /> The SPCC plan describes secondary containment far the mobile refueler as a shallow membrane. Facility <br /> personnel were not able to describe what this was and stated that secondary containment far the mobile <br /> refueler was different than what was described in the SPCC plan. The Spill Prevention, Control, and <br /> Countermeasure(SPCC) Plan must be amended when there is a change in the facility design, <br /> construction,operation,or maintenance that materially affects its potential far a discharge, within 6 <br /> months of the change, and implemented as soon as possible,not later than 6 months fallowing <br /> preparation of the amendment. Immediately make all necessary amendments to the SPCC Plan to <br /> accurately represent the procedures and policies currently in place at the facility. <br /> This is a minor violation. <br /> General secondary containment has been implemented at the facility for the mobile refueler moving <br /> forward.As per 40 CFR 112.7(c)the typical failure mode of a hose or piping rupture is considered most <br /> likely.The mobile refueler is stored in the maintenance shop overnight,which meets the requirements <br /> for general secondary containment.The SPCC Plan has been updated to address this change. <br /> KN01-SPCC_Response-CUP-fnl.doa 1 SESPE Consulting,Inc. <br />