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Concrete, Inc. DBA Knife River Clements Plant APSA Inspection Report—COPA Findings Lodi Facility lune 6,2019 609 CFR 1127(a)(3)(i):Plan failed to include oil type and storage capacity for each container. The SPCC plan mentions a total of 15 drums in a section of the plan. There were a total of 21 drums observed in two areas of the facility. For mobile or portable containers,either provide the type of ail and storage capacity for each container or provide an estimate of the potential number of mobile or portable containers, the types of ail, and anticipated storage capacities; The SPCC plan should address the estimated number of potential mobile or portable containers,the types of ail and anticipated storage capacities or provide the type of ail and storage capacity far each container. This is a minor violation. The drums are stored in two locations at the facility,have been accurately listed on the inventory and placed in secondary containment.The SPCC Plan and site map have been updated accordingly. 630 CFR 1127(k):Failure to provide general secondary containment or alternative for oil-filled operational equipment. A 110 gallon heat transfer ail container by the 57"crusher and a 40 gallon heat transfer ail container by the 48"crusher were observed without general secondary containment and general secondary containment was not discussed in the SPCC plan far these containers. These containers appear to meet the definition of operational equipment. If secondary containment is not provided far qualified ail filled operational equipment pursuant to paragraph(c)of this section, the owner or operator of a facility with qualified ail filled operational equipment must: (i)Establish and document the facility procedures far inspections or a monitoring program to detect equipment failure andlar a discharge,and (ii) Unless you have submitted a response plan under§112.20,provide in your Plan the fallowing: (A)An ail spill contingency plan fallowing the provisions of part 109 of this chapter. (8)A written commitment of manpower,equipment, and materials required to expeditiously control and remove any quantity of ail discharged that may be harmful. Provide secondary containment far the containers or meet the requirements allowed in section k of CFR 112.7. This is a minor violation. Oil-filled operational equipment is only required to have general secondary containment according to CFR 112.7(c).As such,active spill countermeasures are in place at the site to meet the requirements for general secondary containment.The SPCC has been updated to reflect this. KN01-SPCC_ResponwLUP-rnl.doa 3 SESPE Consulting,Inc.