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Spill Preotion Control and Countermeastos (SPCC) Annual Training • Background: The SPCC rule provides requirements for oil spill prevention, preparedness, and response to prevent oil discharges to navigable waters and adjoining shorelines. The rule requires specific facilities to prepare, amend, and implement SPCC Plans. The SPCC rule is part of the Oil Pollution Prevention regulation, which also includes the Facility Response Plan (FRP) rule. It was enacted under the Oil Definition of Oil: means oil of any kind or in any form, including, but not limited to: fats, oils, or greases of animal, fish, or marine mammal origin; vegetable oils, including oils from seeds, nuts, fruits, or kernels (CORN); and, other oils and greases, including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with wastes other than dredged spoil. Denaturant, Corn Oil, Lubricants, etc. Reason PES is regulated under SPCC: Total aboveground oil storage capacity greater than 1,320 gallons, which includes tanks, and containers 55 gallons or greater(drums and totes). PES has a reasonable expectation of a discharge into or upon navigable waters of the United States or ad-joining shorelines. (e.g. ground water and surface water— river, creeks [dry included]) Spill Prevention Controls • Documented Plan in the Integrated Contingency Plan (ICP) Located in conference room. • Professional Engineered Certified • Tank Level Indicators(Overfill protection) • Mechanical Integrity o Inspection monthly visual (Inspectors must be trained) o American Petroleum Institute API 653 integrity testing • o Work order system for repairing equipment malfunctioning • Secondary Containment o 100% of largest tank, 10% aggregate tank volume and enough volume capacity for largest storm event in 25 years. Spill Prevention Countermeasures • Facility Response Plan (FRP) Rule: A Facility Response Plan (FRP)demonstrates a facility's preparedness to respond to a worst case oil discharge. • PES may respond to small or easy to remediate spills. (55 gallons or less to paved or concrete surfaces) PES will contract response to spills to water or spills to the soil. Roles and Responsibilities: Commodities, Production and Labs: • Handle Oils in a manner to prevent or contain spills Provide containment when transferring material (e.g. sampling • Report Spills or releases to the environment • Participate in Cleanups as necessary Maintenance: • Handle Oils in a manner to prevent or contain spills Provide containment when transferring material (e.g. sampling • Report Spills or releases to the environment • Participate in Cleanups as necessary • Inspect Tanks visually for the criteria in the inspection form AUG 14 2014 • ENVIRONMENTAL HEALTH DEPARTMENT