Spill Prevention Control & Countermeasures

1. Spill Prevention Control & Countermeasures Compliance and Planning

2. SPCC Plan • 40 CFR 112 • Facilities subject to the rule must prepare and implement a plan to prevent any discharge of oil into or upon navigable waters of the United States or adjoining shorelines.

3. Who is regulated by the Rule? • Must meet 3 Criteria • Must be non-transportation related. • Must have an aggregate AST capacity of greater than 1,320 gallons or a completely buried storage capacity greater than 42,000 gallons. • Must be a reasonable expectation of a discharge into or upon navigable water or adjoining shorelines.

4. Who prepares the plan? • The responsibility of the facility owner or operator but it MUST be certified by a licensed Professional Engineer (PE).

5. Professional Engineer (PE) • Attests to familiarity with the requirements of part 112. • Agent has visited and examined the facility. • The plan has been prepared in accordance with good engineering practices, including consideration of applicable industry standards. • Procedures for required inspections and testing have been established. • The plan is adequate for the facility.

6. What’s in the Plan? • Facility Owner, Operator, and Location • Facility Contacts • Facility Description which includes operations and storage (Tank ID, Volume, and Contents) • Spill History • Prevention Measures Provided Check your State regulations as they may be different from Federal regulations.

7. Prevention Measures Provided • Drainage Control (Dikes, Valves, Plant Drainage Systems, Final Discharge of Drainage, and Facility Drainage Systems and equipment). • Bulk Storage Tanks and Secondary Containment.

8. Testing • AST periodic integrity testing • Must be performed every 5 years for external inspections and every 10 years for internal inspections. • Internal inspections only encompasses AST that hold more than 25,000 gallons of No. 2 and No. 6 Fuel Oil

9. Inspections • Requirements may be different depending on the State. • Weekly inspections shall be conducted in accordance with CFR • Monthly inspections shall also be conducted for AST’s. • Ensure proper training of individuals conducting inspections.

10. Sample Weekly Inspection Weekly AST Inspection ____ (1) Containment dike or berm in satisfactory condition. ____ (2) Containment area free of excess standing water or oil. ____ (3) Gate valves used for emptying containment areas secured. ____ (4) Containment area/base of tank free of high grass, weeds, and debris. ____ (5) Tank shell surface, including any peeling areas, welds, rivets/bolts, seams, and foundation, visually inspected for areas of rust and other deterioration. ____ (6) Ground surface around tanks and containment structures and transfer areas checked for signs of leakage. ____ (7) Leak detection equipment in satisfactory condition. ____ (8) Separator or drainage tank in satisfactory condition. ____ (9) Tank water bottom drawoffs not in use are secured. ____ (10) Tank fill valves not in use are secured. ____ (11) Valves inspected for signs of leakage or deterioration. ____ (12) Inlet and outlet piping and flanges inspected for leakage. ____ (13) All tank gauges have been inspected and are operational. _________________________ ____________ _______ Signature of Inspector Date Time

11. SPCC Review • Review your SPCC/ODCP Plans Annually!! • Stay up to speed in any and all changes made to your requirements by Federal and State regulators. • Make sure that you enter into your plan the following. • Date of review/revision • Revisions made • Signature of reviewer • Up to date PE stamp certifying the SPCC

12. Sample SPCC Review Sheet SPCC / ODCP Plan Annual Review Section Requirements Met Revisions Made • Compliance and Review Page • Management Approval • Owner, Operator, and Location • Facility Contact Information • Facility Description a. Facility Operations b. Facility Storage c. Drainage Pathway to navigable waters • Spill History a. History b. Spill Predictions • Prevention Measures a. Drainage Control b. Bulk Storage Tanks c. Facility Transfer Ops d. Loading/Unloading e. Inspections/Record Keeping f. Site Security g. Personnel Training h. Spill Control Equip. • Emergency Contacts • Spill Contractors • Worst Case Scenario • Figures • Containment Calculations Reviewed By:________________________ Signature: Date:_________________

13. SPCC Maps and Figures • Make sure copies of SPCC maps are kept with your permit and plan! • Insure all maps are up to date, accounting for new construction or facility changes. • Maps shall contain all requirements set forth by Federal and State regulations. • Calculations for figures shall be double checked for accuracy.

14. Spills Happen!That’s why we have an SPCC!

15. DO YOUR INSPECTIONS!

26. Questions or Concerns? • Open to any questions • If you would like to contact me with questions regarding your SPCC compliance or any reference material within this presentation my contact info is • Daniel Noack Environmental Manager, Smithfield Packing Complex (757) 357-1501 danielnoack@smithfield.com