Annual Briefing:Spill Prevention Control and

Countermeasure Plan (SPCC)

Central Maintenance ServicesFreeport, Texas____________________GHRIS CODE: 281454_365

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Purpose – This training will meet the requirements for the annual Pollution Prevention briefing required of our facility’s Spill Prevention Control and Countermeasures (SPCC) Plan

Desired Outcome – Understanding and knowledge of:

– SPCC rule and applicability – Facility’s SPCC oils, locations, and equipment– Facility’s SPCC LOPCs events (prior 12

months)– Facility’s SPCC Plan Changes

Target Audience – All personnel who work with and/or maintain SPCC oil containers and equipment.

Overview

SPCC Introduction– Spill Prevention Control and

Countermeasure (SPCC) is a Federal Regulation under the Clean Water Act (40 CFR Part 112)

– SPCC regulates the storage of Oil*

– SPCC is to prevent or minimize spills of oil to navigable water ways

*Oil as defined by 40 CFR Part 112

Overview

– Total oil storage capacity for the area is greater than 1320 gallons.

– Potential for oil to get to the water

– The following types of containers do not count toward the 1320 gallon limit:

• Any container whose capacity is less than 55 gallons

• Permanently closed containers

• Mobile Containers that are in DOT service (tank trucks, portable containers, etc.)

CMS Applicability

Dow has a Work Process to determine SPCC Oils.

 

    

Our Facility’s SPCC Oils

SPCC Bulk Oil Containers

Location Total Oil Quantity (Gal.)

Lubrication Oil A-702: Oil Mist System

55 gal drum

Lapping Vehicle Oil B-105 Drum Storage 2 – 55 gal drums

Coolant Cutting Fluid B-105 Drum Storage 55 gal drum

Kerosene B-105 Drum Storage 55 gal drum

Hydraulic Oil B-105 Drum Storage 275 gal tank

Used Oil/Coolant B-105: WT-1 5,000 gal tank

Used Oil/Coolant B-105: WT-2 165 gal tank

New Motor Oil B-203 Garage 4 – 275 gal tanks

Used Oil B-203 Garage 55 gal drum

Bulk Storage (In Service)

Our Plant’s SPCC Oils

Bulk Storage (In Service), continued

SPCC Bulk Oil Containers

Location Total Oil Quantity (Gal.)

Used Oil B-203 Garage: STB-1 2,000 gal tank

Gasoline A-909 Fuel Island: D-101

17,800 gal tank

Diesel A-909 Fuel Island:D-100

17,800 gal tank

Gasoline B-209 Fuel Island:U-1

23,800 gal tank

Diesel B-209 Fuel Island:R-1

10,900 gal tank

Diesel B-209 Fuel Island:D-1

23,800 gal tank

Hydraulic Oil B-412 Tool Room 5 – 55 gal drums

Bulk Storage (In Service), continued

Our Plant’s SPCC Oils

SPCC Bulk Oil Containers

Location Total Oil Quantity (Gal.)

Diesel Exhaust Fluid B-412 Tool Room 55 gal drum

Diesel Fuel B-412 Tool Room 55 gal drum

New Motor Oil B-412 Tool Room 220 gal tank

Used Oil B-412 Tool Room 500 gal tank

Gasoline/Diesel B-412 Tool Room: Mobile Refueler

Baffled:1,800/500 gal tank

truck

Diesel B-412 Tool Room: Mobile Refueler

1,500 gal tank truck

Diesel B-412 Tool Room 55 gal drum

Our Plant’s SPCC Oils

Non-Bulk Storage (In Process), Piping and Transfer Racks

SPCC Piping Location Total Oil Quantity (Gal.)

Gasoline/Diesel A-909 Fuel Island 82 gal/pipe run

Gasoline/Diesel B-209 Fuel Island 75 gal/pipe run

Our Plant’s SPCC Oils

Electrical Equipment (In Service)

Electrical Equipment

Location Total Oil Quantity (Gal.)

T-201-A Transformer B-201 630 gal

T-203 Transformer B-203 90 gal

T-131 Transformer B-105 180 gal

T-130A Transformer B-105 257 gal

T-130B Transformer B-105 257 gal

T-130C Transformer B-105 170 gal

T-292 Transformer OC-403 172 gal

T-709 Transformer A-702 203 gal

Our Facility’s SPCC OilsKey Learning Points –• SPCC Regulates the storage of oil• The CMS facility is required to comply with SPCC

because the total oil storage capacity for the area is greater than 1320 gallons.

• Dow has an existing Work Process to help assess SPCC oil applicability

• You are aware of the Plant’s SPCC bulk containers, in-process and electrical equipment

Lesson Summary

Inspection Requirements:– Inspection for oil sheen or other

contamination before draining the diked area is required.

– Use Rain Water Discharge Checklist

– Assign appropriate WPN as needed

– All valves on containment areas are to be closed unless draining the area

SPCC Plan Requirements

Inspection Requirements: – Oil storage vessels (including

transformers), above ground piping and diked areas are inspected monthly*

– Oil treatment systems are inspected daily (B-412)

– Routine GMISS inspections as applicable

*Inspection frequency at the fuel islands (A-909 and B-209) is weekly

SPCC Plan Requirements

During the past 12 months, we have experienced the following SPCC oil LOPC events:

 

    

Review of SPCC Oil LOPC’s

SPCC Oil LOPC

LOPC Quantity

(Gal)

Location Primary Cause

Compilation of past 12 months SPCC oil LOPC events*: 0 (from GIRD)* While 40 CFR 112.1 only requires reviewing spills that “could reasonably be expected to discharge oil in quantities that may be harmful … into or upon the navigable waters of the United States …”, Dow requires including all oil spills to ensure prevention.

During the past 12 months, we have implemented the following SPCC oil learnings:

 

   Updated figures and flow diagrams Updated inspections Change of weekly to MONTHLY inspections Updated oil storage locations and capacity  

 

Facility’s SPCC Oil Management Learnings

• Developed NEW SPCC Plan including:

Our Facility’s SPCC Oil LOPC’sOur Facility’s SPCC Oil Related Learnings and Changes

Key Learning Points –

• You are aware of the this past year’s SPCC Oil LOPC events in your facility.

• You are aware of the corrective actions to prevent recurrence of SPCC Oil LOPC events.

• You are aware of recently developed precautionary measures to prevent SPCC Oil LOPC events.

Lesson Summary

During the past year, we have changed our Facility’s SPCC Plan:

 

    

Review of SPCC Oil Plan Changes

SPCC Oil Event

Primary Contact

Location Follow-Up Actions

Developed and

implemented new SPCC

plan

Jennifer Hill All CMS Updated SPCC Plan; Revised inspection sheets, figures, training, tables.

Certified by PE, and implemented through

MOC

Our Facility’s SPCC Plan Changes

Key Learning Points –

• You are aware of the significant changes to our Plant’s SPCC Oil Plan

• You are aware of the associated work process updates related to the changes in the Plant’s SPCC Oil Plan.

Lesson Summary

Revision History

Revision history The following information documents at least the last 3 changes to this document, with all the changes listed for the last 6 months.

  Date Revised By Changes

 

6/11/2011 N. Wisby Created training

 

8/11/2011 Anna Rivier Made ready for MyLearning

10/27/2014 Jennifer Hill Revised for SPCC plan updates