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Concrete, Inc. DBA Knife River Clements Plant APSA Inspection Report—COPA Findings Lodi Facility lune 6,2019 711 CFR 1128(c)(6):Failed to perform scheduled tank tests or inspections by appropriately qualified personnel. The tanks on the mobile refueler have not been tested per the inspection frequency in the SPCC plan-. The SPCC plan states that the tanks on the mobile refueler(1,000, 71, 70 and 85 gallon tanks)will be tested every 11 years per DOT standards.According to tank information in the SPCC plan, the tanks were brought into service in 1989. Each aboveground container shall be tested and inspected far integrity on a regular schedule and whenever repairs are made. The qualifications of personnel performing tests and inspections,frequency and type of testing and inspections that take into account container size, configuration, and design shall be determined in accordance with industry standards. Examples of these integrity tests include,but are not limited to:visual inspection,hydrostatic testing, radiographic testing,ultrasonic testing, acoustic emissions testing, or other systems of non-destructive testing. Comparison records and other records of inspections and tests must be maintained on site. Immediately conduct the necessary testing and submit a copy of the test results to the EHD,or provide equivalence as allowed by CFR 111.7(a)(1). 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. 718 CFR 1128(c)(11):Failed to locate properly or provide sufficient secondary containment for mobile/portable containers. The SPCC plan does not discuss the secondary containment for the 55 gallon drums. The two locations of the drums,one in the shop area and another by the 550 gallons tanks and the 175 gallon tanks was not discussed in the SPCC plan. Portable ail storage containers must be positioned or located to prevent a discharge and shall be furnished with a secondary means of containment sufficient to contain the capacity of the largest single container with sufficient freeboard to contain precipitation. The SPCC plan should include a discussion on the secondary containment of all portable tanks,or provide equivalence as allowed by CFR 111.7(a)(1). This is a Class II 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 to address both the tanks and the drums. KN01-SPCC_ResponwLUP-rnl.doa 4 SESPE Consulting,Inc.