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Concrete, Inc. DBA Knife River Clements Plant APSA Inspection Report—COPA Findings Lodi Facility lune 6,2019 602 CFR 1127(a)(2):Plan failed to discuss equivalent environmental protection,if applicable. The Spill Prevention, Control, and Countermeasure(SPCC)failed to discuss alternative environmental protection requirements in detail. The SPCC plan mentions the Steel Stank Institute(57I)SP-001 industry standard and provides an inspection frequency table from the STI-SP-001 standard. The SPCC plan deviates from the requirements of the STI SP-001 standard,it does not mention annual inspections or formal inspections as defined by the STI standard. The SPCC plan states that the tanks are not integrity tested and that visual inspections conducted by the facility meet the environmental equivalence of CFR section 111.8(c)(6). The SPCC plan does not discuss the reasons far non-comformance. If the SPCC Plan does not conform to the applicable requirements,you must state the reasons far non-conformance in your Plan and describe in detail alternate methods and haw you will achieve equivalent environmental protection. Immediately amend the SPCC Plan to include a discussion of equivalent environmental protection. Nate:If an owner or operator deviates from applicable industry standards to develop an integrity testing program, then a PE must certify an environmentally equivalent alternative in the SPCC Plan. The Plan must provide the reason for the deviation,describe the alternative approach, and explain haw it achieves environmental protection equivalent to the applicable industry standard. This is a Class II violation. Concrete, Inc. has adopted the industry standard inspection schedule of the STI SP-001,has eliminated the environmental equivalence wording in the SPCC Plan,and has updated the SPCC with a summary of the tanks at the facility and their inspection frequencies. 603 CFR 1127(a)(3):Failed to adequately describe the physical layout of the facility in the Plan. The facility diagram does not contain the location and contents of the 550 gallon motor ail tank, the 550 gallon hydraulic ail tank, the 110 gallon heat transfer ail container, the 40 gallon heat transfer ail container and the storage area of all drums and mobile refuekr. The Spill Prevention, Control, and Countermeasure(SPCC) Plan shall include o facility diagram which must mark the location and contents of each fixed storage container and the storage area where mobile or portable containers are located. It must identify the location of and mark as"exempt"underground tanks. It must also include all transfer stations and connecting pipes,including intra facility gathering lines. Immediately update the facility diagram to include all of the required information.Submit a legible copy of the updated facility diagram to the EHD far review. This is a repeat violation, Class H. The site map for the facility has been updated to include the information required by CFR 112.7(a)(3). KN01-SPCC_ResponwLUP-rnl.doa 2 SESPE Consulting,Inc.