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Spill Prevention Control and Countermeasure Plan Food Express, Inc. 1250 Madruga Road FOOD EXPRESS, INC. Lathrop, California 95330 May 2020 Page 23 favor the refill operator, engineers often add oil fill prevention devices (OFPDs) such as automatic float valves, spill buckets, overfill alarms as appurtenances to the container to minimize the probability of overfill situations. In addition, oftentimes OFPDs are added as secondary or tertiary layer of protection against overfilling. The original SPCC regulation specifies that one of four different types of over fill prevention devices (OFPDs)10 be added to each container. However the USEPA's SPCC Guidance for Regional Inspectors11 allows for use of a simpler overfill prevention procedure for a small container (e.g., relatively small containers that can be readily monitored) when the filling procedure is documented in the SPCC Plan. In general, there are four general procedures for filling/refilling of the containers at the facility. Prefilled - The majority of DOT drums and IBC totes arrive pre-filled from the factory facility eliminating the possibility of overfilling the container at the facility. No OFPD are required when the containers are not filled on site. Hand Filled — Some bulk oil containers are "hand-filled" in that the refill operator continuously monitors the oil level in the container and has immediate instantaneous control the flow of oil into the container. The US EPA has determined the refill operator's instantaneous control the flow of oil into the oil storage container is considered environmentally equivalent to a container outfitted with an actual physical or electronically controlled overfill prevention device. In general, the immediate instantaneous control the flow of oil into the container by the refill operator is commonly achieved in a couple of different ways. The first method involves the refill operator hand-pouring the contents of a physically small, easily manipulated, transfer container into the oil storage container. Used motor oil and other spent lubricating oils refreshed during vehicle/equipment maintenance are commonly transferred in this manner. The second common method that allows the refill operator instantaneous control involves the refill operator using a pressure charged flexible oil transfer hose outfitted with ROCHELSOPN nozzle (Refill Operator Controlled Hose End Level Sensing Overfill Prevention Nozzle). In addition to the instantaneous manual control of the ROCHELSOPN valve, the ROCHELSOPN nozzle is equipped with an automatic level sensing mechanism that monitors the fill level of the receiving oil container. When the level reaches the ROCHELSOPN nozzle, the ROCHELSOPN nozzle senses backpressure and automatically valves off the flow of oil, instantaneously. Semi-Autonomous Fill System — These containers are similarly connected and filled to those that use true autonomous filled except physical overfill protection device is not present. During semi-automated filling, the refill operator and a facility employee remain within close view of AST 10 High liquid level alarms with an audible or visual signal at a constantly attended operation or surveillance station.In smaller facilities (i) an audible air vent may suffice, (ii) High liquid level pump cutoff devices set to stop flow at a predetermined container content Ievel,(iii)Direct audible or code signal communication between the container gauger and the pumping station,or(iv)A fast response system for determining the liquid level of each bulk storage container such as digital computers,telepulse,or direct vision gauges. If you use this alternative,a person must be present to monitor gauges and the overall filling device at all but a directive that states any OFPD used must be tested regularly. 11 SPCC Guidance for Regional Inspectors. USEPA December 2013, https://www.epa.gov/oil-spills-prevention-and- preparednessregulations/spcc-guidance-regional-inspectors IATc Page 23