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analyze/discuss with our PE's and get back to you. I am currently on page 16 of an 86-page spcc plan template, dated 2020, which SPC Corp is using. 2. DEF---while I do not find specific guidelines in the MSDS for Diesel Exhaust Fluid (DEF)---see attachment, I remain concerned about some of the comments regarding storage "migrating into storm drains, sewer, etc." as well as the comment that proximity to such chemicals as bleach, ammonia, etc. can create combustible events. Some jurisdictions (e.g., Santa Clara, San Bernadino, etc.) require we prescribe 2ndary containment (in the form of a pallet below the primary container) for this material. Please allow me to submit some language into the DRAFT spcc plan and submit it for your review. We may consider the adage: "recommended, not required." Will review with our PE's. Please note I intend on completing the DRAFT for the Powell spcc plan by c.o.b. this Friday, 4/24. Please confirm this meets your deadline targets---this was originally delayed from 12/15/2017.....SPC Corp wants this project to be finished ASAP. I will also look forward to coordinating the compliance efforts of: a) Haley Flying Service, Inc. b) Maxim Crane Service (being reviewed by Capt. Martel of Stockton FD currently-----would like your input as well to insure we are following guidelines). Thank you for your quick response. D. Paul McWhorter, CEO SPC Corporation From: Baker, Lydia <Ibaker@sigov.org> Sent: Wednesday,April 22, 2020 10:28 AM To: DPaul McWhorter<spccorp@hotmail.com> Subject: RE:A.L. Powell Trucking, Inc./Escalon, CA Hello Paul, I have not received your voicemails yet. I've been working from home. Just to clarify I have not referred A.L. Powell Trucking to the District Attorney. I simply reminded Sandy Bomer that they are being charged for all time spent on bringing their facility back into compliance and the next step would be a referral to the DA. Cesar conducted the inspection on August 21, 2018. The facility was required to come into compliance within 30 days. If that was not feasible then the facility is required to notify EHD and keep us updated on the progress. Cesar last emailed the facility on 12/26/2019 and as far as our records show the facility never responded. Cesar is no longer in the CUPA unit so I am following up on all the outstanding violations. 2. For the 12,000 gallon diesel tank there are two options for secondary containment. Either you must provide secondary containment that holds 12,000 gallons plus sufficient freeboard for precipitation (if it is exposed to the weather) or you must provide an explanation of impracticability in the SPCC plan. The reason for impracticability can be due to cost but that cannot be the only reason secondary containment is impracticable. If the facility decides to go this route this is what is required: 40CFR112.7(d): If you determine that the installation of any of the structures or pieces of equipment listed in paragraphs (c) and (h)(1) of this section, and §§ 112.8(c)(2), 112.8(c)(11), 112.9(c)(2), 112.10(c), 112.12(c)(2), 112.12(c)(11), 112.13(c)(2), and 112.14(c)to prevent a discharge as described in § 112.1(b)from any onshore or offshore facility is not practicable,you must clearly explain in your Plan why such measures are not practicable; for bulk storage containers, conduct both periodic integrity testing of the containers and periodic integrity and leak testing of the valves and piping; and, unless you have submitted a response plan under§ 112.20, provide in your Plan the following: (1)An oil spill contingency plan following the provisions of part 109 of this chapter. 2