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SPCC Plan — E.F. Kludt & Sons, Inc. — Lodi, CA 40 CFR 112.7 The Facility's Conformance with the Requirements of 40 CFR 112.7(a)(1)& (2) E.F. Kludt& Sons, Inc. bas elected to maintain their aboveground oil product storage in several areas within the facility The 15,000 Gallon fuel tanks are contained within a concrete containment structures.E.F.Kludt&Sons,Inc.has taken reasonable steps to comply with 40 CFR 112.7 requirements.In each stage of thew operational growth attention has been taken to account for the effects of the production and steps have been taken to ensure that methods to divert any hazardous material liquid releases to selected areas thus enabling a sensible and manageable clean Lip using procedures that can address the situation allowing for a quick and efficient response.The main fuel storage operation is conducted east of the main building. The fuel tanks are securely mounted on concrete in a concrete containment structure. All fueling is controlled and conducted by personnel from E.F.Kludt& Sons,Inc.staff.There is no public access to the fuel storage area. Containment for Oil Products consists of 40 CFR 112 7(a)(3)(i)- • 15,000 Gallon Single Wall 42 Diesel Fuel Storage Tank UL Certified 142 • 15,000 Gallon Single Wall Gasoline Storage Tank UL Certified 142 • 15,000 Gallon Single Wall#2 Diesel Fuel Storage Tank UL Certified 142 • 15,000 Gallon Single Wall#2 Diesel/91 Octane Storage Tank Certified UL 142 • 12,000 Gallon Split Double Wall for Cardlock services Certified UL 2085 • 3,000 Gallon Double Wall Bio Diesel Fuel Talc Certified 11L 142 • 25-50 275-Gallon totes for Oil products • 75.100 55-Gallon drums for motor Oil and lubrications Total Oil Product storage for E.F.Kludt& Sons,Inc. is approximately 76,000 Gallons. The facility is located along Pine Street and limited access to the facility is established by controlled fencing and controlled roads. Vehicular traffic has limited access in or around the#2 Diesel, Bio Diesel and Gasoline fuel tank areas. The exterior of the fuel storage systems are monitored throughout the operation and any spill will be addressed quickly. Drivers delivering fuel to the#2 Diesel Fuel,Bio Diesel and Gasoline Fuel Storage Tanks understand their obligation in controlling fuel spills.As part of the continuous Release Detection Method for compliance with 40 CRR 112.7 and the Steel Tank Institute monthly inspections of the fuel storage systems are recorded within the SPCC Plan under Appendix B&C.The Fuel tanks are also monitored and the inspections we recorded in Appendix B&C.All shipments ofnew fuels are conducted by certified and trained personnel who understand the delivery requirements and have the training to respond to a release of oil products. A release of oil products into the environment will most likely be through the delivery or dispensing of fuels into or out of the controlled settings. 8