SIDNEY MT SPCC PLAN - VERSION 1 - Page 1 of 32 TRANSYSTEMS SPILL, PREVENTION, CONTROL, AND COUNTERMEASURES (SPCC) PLAN Great Falls Service Center 1901 Benefis Court Great Falls, MT 59405-4373 CONTACT: Director of Training 1.0 SPCC Plan Requirements 1.1 General Company Policy 1.2 Purpose The purpose of this program is to inform interested persons, including employees that the Transystems facilities are in compliance with EPA requirements for preparing and maintaining a Spill Prevention Control and Countermeasure (SPCC) Plan under the Oil Pollution Prevention regulations, Title 40 Code of Federal Regulations (CFR) Sections 112.1.15, by providing a written plan that describes the equipment, manpower, procedures, and adequate countermeasures for preventing and controlling oil discharges. 1.3 Applicability This program applies to all work operations in our facilities where employees may be exposed to potential oil discharge situations under normal working conditions or during an emergency situation. 1.4 Responsibility Director of Training is responsible for this plan and for making sure that the plan is available to the EPA Regional Administrator for on-site review during normal working hours. The written plan is located at each project office and on the Transystems web site. The Director of Training is responsible for developing and maintaining the plan. The facility owner, address, and telephone are as follows: Transystems, 1901 Benefis, Court Great Falls, Montana 59405-4373, Phone 406-7277500. 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 2 of 32 Facility project manager’s names, addresses, and telephone numbers can be found in the facility information sections of this plan. 1.5 Introduction Spill Prevention, Control, and Countermeasure plans for facilities are prepared and implemented as required by U.S. Environmental Protection Agency (U.S. EPA) regulations contained in Title 40, Code of Federal Regulations, Part 112 (40 CFR 112). A non-transportation related facility is subject to SPCC regulations if: 1) due to its location, the facility could reasonably be expected to discharge oil into or upon the navigable waters of the United States; 2) the total aboveground storage capacity exceeds 1,320 gallons (calculated total of containers with capacity of 55 gallons or more); or 3) the completely buried storage capacity exceeds 42,000 gallons. The SPCC plan is not required to be filed with U.S. EPA, but a copy must be available for on-site review by the Regional Administrator during normal working hours if the subject facility is attended at least 4 hours a day. The SPCC plan must be submitted to the U.S. EPA Region 10, Regional Administrator and the state agency in charge of oil pollution control along with the other information specified in 40 CFR if either of the following occurs: The facility discharges more than 1,000 gallons of oil into or upon navigable water of the United States or adjoining shorelines in a single event; or The facility discharges more than 42 gallons of oil in each of two discharge events within any 12 month period. Discharge information must be reported to U.S. EPA Region 10 and the state agency within 60 days if either of the above thresholds is reached. The report is to contain the following information: Name of facility; Name(s) of the owner or operator of the facility; Location of the facility; Maximum storage or handling capacity of the facility and normal daily output; Corrective actions and/or countermeasures taken, including a description of equipment repairs and/or replacements; An adequate description of the facility, including maps, flow diagrams, 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 3 of 32 topographical maps as necessary, and diagrams which show the location of exempted tanks; The cause of the discharge, including a failure analysis of the system or subsystem that failed; Additional preventative measures taken or contemplated to minimize the possibility of recurrence; and such other information the Regional Administrator may require pertinent to the plan or discharge. The cause of the discharge, including a failure analysis of the system or subsystem that failed; Additional preventative measures taken or contemplated to minimize the possibility of recurrence; and such other information the Regional Administrator may require pertinent to the plan or discharge. The SPCC plan shall be amended within 6 months there is a change in facility, design, construction, operation, or maintenance that materially affects the facility’s discharge potential. The plan must be reviewed once every 5 years and amended to include more effective prevention and control technology, if such technology will significantly reduce the likelihood of a discharge event and has been proven in the field. All technical amendments must be certified by a registered professional engineer. Owners and operators failing or refusing to comply with these federal regulations are liable to a Class I civil penalty of $10,000 per violation (up to a maximum assessment of $25,000) or a Class II penalty of up to $10,000 per day of violation (up to a maximum assessment of $125,000) plus a 10% increase assessed cap for Class I and Class II penalties. The facility cannot self certify because it stores more than 10,000 gallons and this is the threshold for self certification. A signed certification is included in the Appendix, Ref: 40CFR 112 App C. 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 4 of 32 2.0 40 CFR 112, Subpart A - General Requirements for All Facilities and All Types of Oils 2.1 SPCC PLAN REVIEW - 40 CFR 112.5(b) The owner or operator must complete a review and evaluation of the SPCC plan at least once every 5 years. Evidence of these reviews shall be recorded in the plan. Signature Date ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ ________________________________________________________________ * Amended to reflect installation of: ** Next review and evaluation of the plan in 5 years unless changes occur. 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 5 of 32 2.2 PAST DISCHARGE HISTORY - (40 CFR 112.7 (a) -required under previous rule) 2.2.1 Written Description of Discharge No discharges as of the current plan. ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ 2.2.2 Corrective Actions Taken ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ 2.2.3 Plan for Preventing Recurrence ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ ________________________________________________________________________ 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 6 of 32 3.0 GENERAL FACILITY INFORMATION: Address, Contacts, Locations, Description, Storage Volumes & Diagrams 3.1 Facility Name: Sidney (Project 144) Street Address: 1120 East Main, Sidney MT 59270 Mailing Address: Same as street address Telephone: (406) 433-5522 Owner: Transystems Contact: Project Manager 1120 East Main, Sidney MT 59270 Telephone: (406) 489-1518 Personnel: Supervisors, maintenance, line drivers and loader operators (55 seasonal employees) Location: The facility is located in Richland County at 1120 East Main, Sidney MT 59270. The facility coordinates are 47° 42' 35.84" north latitude and 104° 08' 34.59" west longitude. Description: Transystems, Sidney project is the base terminal for trucking operations in Richland County, MT. The operation stores and consumes petroleum products and diesel fuel. Diagram 1 depicts the property boundaries and adjacent streets, drainage ditches, canal, buildings on site and fuel tank location. A maintenance shop is positioned on the north/west end of the property where petroleum products are stored and used to service equipment. Fixed Storage: (1) 15,000-gallon horizontal tank (diesel fuel) see appendices for physical description. Shop Storage: (1) 100-gallon tot for new oil storage (1) 100-gallon tot for used oil (disposed of monthly) Portable Tanks: (1) 500-gallon trailer mounted horizontal tank (diesel fuel) for fueling loaders at outside pile grounds stored empty during off season months. 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 7 of 32 Diagram 1: Sidney MT Site Map Location of present office and shop facility, bldg. is 120’ X 50’ Shop New employee temporary lodging facilities Flow direction is to the East Diesel above ground fuel tank and containment 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 8 of 32 3.2 Containment, Clean Up and Disposition of contaminated materials: Dikes and containments are provided around tank. The fuel tanker unloading valve is within the containment area to prevent any leakage from escaping, tanker will be positioned on a concrete pad designed to capture and leakage. Shop facility is engineered so that oil discharged on the floor will drain into a containment pit at the center of the facility. Absorbent materials are provided in the emergency discharge equipment lockers located strategically throughout the project property or shop facilities. Contaminated materials will be collected, stored and removed from the site by authorized clean up contractors identified in the “Petroleum Release Response Checklist, paragraph 9” in Appendices. 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 9 of 32 3.3 POTENTIAL DISCHARGE VOLUMES AND RATES - 40 CFR 112.7(b) Sidney MT Project, Fuel Tank Potential Event Discharge Direction Volume Released Complete failure of full tanks & containment East toward grassy area 15,000 gallons Partial failure of full tanks Retained in containment 1 to 15,000 gallons Gradual to instantaneous Tank overfill Retained in tank containment 1 to many gallons Up to 5 gallons per minute Pipe failure East toward grassy area Up to 15,000 gallons 5 gallons per minute Discharge Rate Instantaneous Leaking pipe or valve East toward grassy area Several ounces to several gallons Up to 1 gallon per minute Tank truck leak or failure East toward grassy area 1 to 15,000 Gallons Gradual to instantaneous Pump rupture or failure East toward grassy area 1 to several gallons Up to 5 gallon per minute Over-flow while fueling Remain on pad or flow east toward grassy area 1 to several gallons Up to 5 gallon per minute 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 10 of 32 3.4 CONTAINMENT AND DIVERSIONARY STRUCTURES - 40 CFR 112.7(c) Dikes and containments are provided around tanks which store oil products. The loading and unloading area for tanker truck is curbed to provide secondary containment. Surface drainage at the facility is engineered so that oil discharged from containments will be diked or curbed to prevent drainage into water ways. Weirs, booms, or other barriers are available from the local cleanup contractor. Absorbent materials are provided in emergency discharge equipment lockers located throughout the project’s property or shop facilities. 4.0 DEMONSTRATION OF PRACTICABILITY – 40 CFR 112.7(d) Facility management has determined that use of the containment and diversionary structures or readily available equipment to prevent discharge oil from reaching navigable water is practicable and effective at this facility. 5.0 INSPECTIONS, TESTS, AND RECORDS - 40 CFR 112.7(e) The Project Manager or designated representative is responsible for conducting facility inspections and tests and maintaining inspection records (signed by the appropriate supervisor or inspector) with the SPCC Plan for a period of three years. Records of inspections and tests should be maintained in accordance with company records retention directives. The daily inspection consists of visual inspections of the storage site, a complete walkthrough of the facility property to check for tank damage or leakage, stained or discolored soils, excessive accumulation of water in diked areas. The inspections will ensure the dike or containment drain valves are closed. The checklist provided in appendices is used during monthly inspections. These inspections are performed in accordance with written procedures such as API standards and engineering specifications. 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 11 of 32 Monthly inspections are signed by the inspector and are maintained in the project office for 3 years, with the SPCC Plain. Division Safety Manager will audit program compliance and records maintenance. 6.0 FACILITY INSPECTION CHECKLIST Printable checklist form located in appendices. Instructions: This inspection record will be completed every month. Place an X in the appropriate box for each item. If any response requires elaboration, do so in the descriptions and comments space provided. Further descriptions or comments should be attached on a separate sheet of paper if necessary. 7.0 PERSONNEL, TRAINING, AND DISCHARGE PREVENTION PROCEDURES 40 CFR 112.7(f) Transystems is committed to providing proper and regular instruction for oilhandling personnel in: the operation and maintenance of equipment to prevent discharges of oil, discharge procedures protocols, general facility operations, and the contents of the facility SPCC Plan. All employees receive instruction on how to fuel the trucks and what to do in case of a spill. This is done when the person is hired and on an ongoing bases. In addition, we are committed to providing proper and regular instruction of oilhandling personnel in applicable pollution control laws, rules, and regulations. The Project Manager and Division Safety Manager instruct all employees on proper fueling procedures prior to fueling the trucks. The Project Manager is responsible for ensuring that oil-handling employees are properly instructed in the operation and maintenance of equipment to prevent oil discharges, discharge procedures protocols, general facility operations, the contents of the facility SPCC Plan, and applicable pollution control laws, rules, and regulations. The Project Manager and Safety Manager are responsible for overseeing discharge prevention activities. The Project Manager is responsible for reporting on the progress of discharge prevention activities to the Division Office and Great Falls Service Center (GFSC). During start up and safety orientations the Project Manager and Safety Manager 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 12 of 32 are responsible for conducting discharge prevention briefings for oil-handling personnel to ensure adequate understanding of the facility SPCC Plan. 8.0 EMERGENCY CONTACTS AND TELEPHONE NUMBERS Refer to Petroleum Release Response Checklist of emergency contact listing and telephone numbers. See Actions paragraph 3, response checklist. 9.0 SECURITY - 40 CFR 112.7(g) The facilities are not fenced and public access may occur. During beet/coal hauling operations the facility is manned 24 hours a day by employees and supervisors and checked frequently. Managers and supervisors routinely check the facilities during the off season Monday through Friday. The master flow and drain valves are locked in the closed position when beet/coal hauling operations are not in progress. The electrical starter controls for the pumps are locked at their source when the pumps are not in use. The loading and unloading connections the fuel pipelines are capped when not in service or when in standby service for an extended time. Area lighting is located in such a position so as to illuminate the office and storage areas. - 10.0 Consideration was given to discovering discharges at night. Lighting may prevent discharges occurring through acts of vandalism. TANK TRUCK LOADING/UNLOADING - 40 CFR 112.7(h) Curbing should be installed at the vehicle unloading point to prevent any run off if a leak should occur. Absorbent materials are provided in emergency discharge equipment lockers located strategically throughout the project property and shop facility. 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 13 of 32 Containment, Clean Up and Disposition of contaminated materials instructions are located in paragraph 9, Petroleum Release Response Checklist in Appendices. Warning signs and chock blocks are required at the unloading location to prevent premature vehicular departure. The lower most drain and all outlets on tank trucks are inspected and tightened prior to filling and disconnection of fuel transfer lines, and prior to vehicle departures. 11.0 BRITTLE FRACTURE EVALUATION - 40 CFR 112.7(i) If a field-constructed aboveground container undergoes a repair, alterations, reconstruction, or a change in service that might affect the risk of a discharge or failure due to brittle fracture failure or other catastrophe, the container will be evaluated for risk of discharge or failure due to brittle fracture or other catastrophe, and corrective action will be taken as necessary. 12.0 CONFORMANCE TO APPLICABLE GUIDELINES - 40 CFR 112.7(j) Communication with the State agency in charge of oil pollution control has indicated that the requirements of 40 CFR 112 are in conformance with all State agency requirements and are the most stringent rules, regulations, and guidelines. This SPCC plan was written in conformance with the requirements of 40 CFR 112. 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 14 of 32 13.0 REQUIREMENTS FOR PETROLEUM OILS AND NON PETROLEUM OILS (40CFR 112, SUBPART B) 13.1 FACILITY DRAINAGE - 40 CFR 112.8(b) Drainage from diked storage areas is restrained by containment walls to prevent a discharge or other excessive leakage of fuel into the facility’s drainage system. Fluid buildup within containment areas will be removed by vacuum devices and transported in approved tanks/containers and disposed of in accordance with 40 CFR112. In the event of a discharge from a tank, the oil should be contained within a dike. If a discharge occurs during transfer or in a manner that cannot be contained in a dike, the material will be temporarily diked and absorbent pads will be used to collect the spilled oil and then disposed of the oil socked pads in accordance with CFR 112 and this plan. Facility drainage systems are adequately engineered to prevent oil from leaving the facility. In the event of equipment failure, discharged oil terminates at secondary dike systems or if within a building at the interior collection point at the center of the building. Facility drainage systems are adequately engineered to prevent a discharge in the event of equipment failure or human error. No drainage waters are allowed to escape from the facility. 13.2 BULK STORAGE CONTAINERS - 40 CFR 112.8(c) Each aboveground container is compatible with the oils it contains and conditions of storage. All aboveground container tanks have concrete dikes or steel sides for secondary containment with a volume that can hold the contents of the largest single container, plus adequate freeboard to contain precipitation. The containment volume is adequate to hold 110% of the tanks capacity, plus 4.5 inches of rainwater which could occur in a 24-hour period of a 25year storm event. Drainage of rainwater from dike area is prohibited. All rainwater will be removed by authorized contractors with vacuum devices and transported in authorized containers for disposition in accordance with 40 CFR 112. Usual and customary business records are kept for recording drainage and disposal of the containment fluids (maintain copies of service invoices 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 15 of 32 for verification and file with the record of dike drainage for three years). There are no partially buried tanks at this facility. Buried tanks will be avoided in the future. Aboveground containers are periodically tested using a system of visual inspection combined with non-destructive shell thickness testing, including inspection of container supports and foundations. Comparison records are maintained. Each container is equipped with a direct-reading level gauge. Venting capacity is suitable for the fill and withdrawal rates. Oil leaks that result in a loss of oil from container seams, gaskets, rivets, and bolts are promptly corrected. 13.3 TRANSFER OPERATIONS & PUMPING- 40 CFR 112.8(d) All pipe supports are properly designed to minimize abrasion and corrosion and to allow for expansion and contraction. All aboveground pipelines, valves and appurtenances are examined monthly to assess their condition. Also on a monthly basis, all flange joints, expansion joints, valve glands and bodies, catch pans, pipeline supports, locking of valves, and metal surfaces are inspected. Integrity and leak testing for piping is conducted as warranted by modification construction, relocation, or replacement. Warning signs are posted as needed to prevent vehicles from damaging aboveground pipelines. 14.0 NON APPLICABLE SECTIONS SPILL PREVENTION, CONTROL, AND COUNTERMEASURES PLAN REQUIREMENTS FOR ONSHORE OIL PRODUCTION FACILITIES (40 CFR 112.9) This section is not applicable to this facility. SPILL PREVENTION, CONTROL, AND COUNTERMEASURES PLAN REQUIREMENTS FOR ONSHORE OIL DRILLING AND WORKOVER FACILITIES (40 CFR 112.10) This section is not applicable to this facility. 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 16 of 32 SPILL PREVENTION, CONTROL, AND COUNTERMEASURES PLAN REQUIREMENTS FOR OFFSHORE OIL DRILLING AND WORKOVER FACILITIES (40 CFR 112.11) This section is not applicable to this facility. (40 CFR 112, SUBPART C) Requirements for Animal Fats and Oils and Greases, and Fish and Marine Mammal Oils; and for Vegetable Oils, Including Oils from Seeds, Nuts, and Fruits and Kernels This section is not applicable to this facility. (40 CFR 112, SUBPART D) Response Requirements This section is not applicable to this facility. Appendices Petroleum Release Response Checklist Emergency Response for flammable liquids Potential Hazards Fueling Operating Instructions Written Hazard Communication Program “Right to Know” Record of Dike Drainage Form Sidney MT: Containment calculations and dimensions Facility Inspection Check list Form 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 17 of 32 PETROLEUM RELEASE RESPONSE CHECKLIST Situation: Petroleum spill (Gasoline/Diesel/Hydraulic Fluid, Oil, see spill classification below) Definitions: *Class I or minor releases: Release that involves less than (25) gallons and does not cause a sheen on nearby surface water shall be reported to the MT Department of Environmental Quality only if cleanup cannot be accomplished with twenty-four (24) hours. (Ref. MT, PTRCF, ARM 17.56.501) * Class II or medium releases: Release that exceeds (25) gallons or that causes a sheen on nearby surface water shall be report to the MT Department of Environmental Quality within twenty-four (24) hours and owners and operator shall begin corrective actions immediately. (Ref. MT, PTRCF, ARM 17.56.501) * Class III or major releases: Release that is over 100 gallons and extends over 100 feet in any one direction or continues to flow and threaten contamination of ground water systems. Spills of this magnitude may require additional notification to National Response Center (see Actions, paragraph 3, emergency notification phone numbers) Reporting: Class I (minor) spills (less than 25 gallons): Project Manager/Supervisor immediately Class II/III spills requires reporting to local, state and federal agencies: (Note: (Spills exceeding 25 gallons or a spill of any size on or in the presence of groundwater) Reported to: (Contact numbers located in Actions, paragraph 3) Montana Division of Environmental Quality (Within twenty four hours) National Response Center (Within twenty four hours) Actions: 1. Safety Precautions: The emergency supervisor on scene will take immediate action to contain and immediately clean up any above ground spill or overfill of petroleum only after identifying and mitigating any fire, explosion and vapor hazards. Take appropriate safety precautions to protect personnel at the scene and any additional personnel located in close proximity to the release site and probable release route. If evacuation of the area is required, use available personnel to assist in clearing the area until local law enforcement or other qualified first responders arrive. Large Spill - Consider initial downwind evacuation for at least 300 meters (1000 feet). Fire - 900-O-P2-8-12 If tank, rail car or tank truck is involved in a fire, ISOLATE for 800 meters (1/2 mile) in all directions; also, consider initial evacuation for 800 meters (1/2 mile) in all directions. SIDNEY MT SPCC PLAN - VERSION 1 - Page 18 of 32 2. Gather Critical Information: Who: _______________________________________________(Callers Identification) What: Petroleum Spill or Large-scale release Deaths/Injuries: ________________________________________(Describe known deaths/injuries) Where: _______________________________________________ (Exact location: mile marker, exit, site) When: _______________________________________________(Time event started) How Much: ____________________________________________(Classify spill/estimate gallons) Why: _______________________________________________ (Cause of spill) Help Needed: ___________________________________________ (Fire, Police, Ambulance, Etc) Actions Taken: __________________________________________(To control incident) Contact #:_______________________________________________( Phone #, radio call sign/channel) 3. Emergency notifications phone numbers: Primary # Secondary # _____ Transystems Project Manager 406-489-1518 406-433-5522 _____ Medical First Responders: (If required) 911 _____ Fire/Police (If required) 911 _____ Div. Manager 406-899-5247 406-454-7642 _____ Safety Manager 800-548-9864 406-899-5248 _____ Transystems Drivers (if needed) Primary # Radio Secondary # N/A _____ Transystems Safety Department SVC 800-548-9864 406-899-5248 NOTE: If unable to contact local Project Manager or on duty supervisor, call Transystems Service Center at (800) 548-9864, ask for the Vice President of Safety. Customer Notification: (No reporting required facility not on customer property) _______On Call Safety N/A N/A _______On Call Environmental N/A N/A 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 19 of 32 State and Federal Government Offices: _______Montana Division of Environmental Quality 800-457-0568 (Within twenty four hours) _______National Response Center 800-424-8802 (Within twenty four hours) 4. If no other hazard exists: ______ Take action to stop the source of the release if it is still occurring (Turn off valves or plug holes) ______ Determine cause of release ______ If situation is hazardous, evacuate area to a safe distance (minimum of 500 feet) ______ Control access to prevent unaware persons from being harmed ______ Wait for response from trained first responders (Fire/Police/ HAZMAT team/etc) 5. If the area is safe to enter begin release containment procedures: _____ Primary concern is to confine releases as close to the source as practical _____ If possible prevent releases from exiting established containment areas _____ Emergency Supervisor should refer to the following segments of the SPCC plan: - Diagram one; building and site layout; page 5 - Containment and clean up instructions; paragraph 3.2 - Potential discharge volume rates; paragraph 3.3 - Locations of absorbent materials and secondary containment materials; paragraph 3.2 6. If another agency is responsible for the spill: ______Is there a threat to employees, equipment, public health & welfare or natural resources ______Determine who is responsible for release? ______Emergency Supervisor will: - Contact the responsible party and informed them of the release - Monitor their response actions, containment and cleanup process - If the release is such that it poses imminent danger to human life or to the environment (primarily access to natural watershed, waterway, or drinking water source), the Emergency Supervisor should take all actions within his/her control to mitigate danger to human life or environmental damage until containment action can be implemented by the responsible party. 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 20 of 32 7. Monitor First Responder Activities: Actions Taken: _____ Fire:___________________________________________________________ _____ Police:_________________________________________________________ _____ Ambulance: _____________________________________________________ _____ Local/State Environmental Agency: _________________________________ _____ Other Actions Taken:______________________________________________ _____________________________________________________________________ _____________________________________________________________________ 8. Citations/Warnings: _____ Type of Citation: ___________________________________________________________ _____ Issuing Authority/Individual: __________________________________________________ 9. If Transystems is responsible, initiate cleanup actions as soon as possible: (Ensure personnel wear appropriate PPE and clothing; decontaminate PPE/clothes/tools as required) ____ Petroleum pollutants will be collected to the maximum extent possible and stored as waste oil. Locate and use containers suitable to the size amount of the spill (55 gallon drums, portable fuel tank, etc) ____ Absorbent and similar material will be placed in 55-gallon drums (if available) or double plastic garbage bags, labeled, and placed in a safe location until properly disposed of. (Follow local/state rules for disposal) ____ If size of spill is beyond local capability to totally control, contact local clean up contractor to ensure proper cleanup of spill and any contaminated soil. _____ Restrict access to area by using cones or stakes with yellow safety tape to mark out spill zone _____ Clean-up Contractor: (Note: contact in order) Olympus Technical Services Franz Construction (Note: Small Spills) SeCor International Inc. 900-O-P2-8-12 Boise, ID Helena, MT Billings, MT Sidney, MT 208-562-5500 406-443-3087 406-245-3554 406-482-4760 Carson City, NV 775-884-4561 800-471-4419 SIDNEY MT SPCC PLAN - VERSION 1 - Page 21 of 32 _____ Safety Kleen Regional Office 303-322-2947 Boise, ID 208-342-8882 (Note: Contact only if other agents are not available) Clean-up Resources: (supplies and equipment) Norco Big Sky Fire & Equipment Praxair J.J. Keller Local Livingston, MT Twin Falls, ID Neenah, WS 800-657-6672 800-662-9087 208-733-6270 800-727-7516 10. Providing initial and follow up reports: _____ If spill is not already part of a Vehicular loss investigation, open a loss file and investigate cause and preventability of the incident. ______ Document the incident using a Transystems Loss Reporting Form ______ Take personnel actions and document as required ______ Keep Division Manager, Safety Manager informed of all milestones for clean up/repairs ______ Document costs and provide a final report (include copies of all other reports created because of local/state/federal regulations) ______ Send final report to Division Manager, Safety Manager and Transystems VP of Safety. (NOTE: Advise any cleanup contractors to conduct all State/Federal reporting actions) _____ Spill less than 25 gallons and ground water is not affected: (Only accomplish internal and customer required notifications and reports) _____ Spill of any size is on or in the presence of groundwater or is 25 gallons or larger: (Provide initial spill report as soon as possible but no later than the end of the first working day of the release, to required local, state and federal agencies, through the Division office) _____ Final Close Out Report: Once the spill has been cleaned up, coordinate a final report through the Division office and SVC office prior to submitting to the customer, local, state or federal agencies. 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 22 of 32 EMERGENCY RESPONSE FIRE (Source: Emergency Response Guidebook, Guide 128 “Flammable Liquids” page 204) CAUTION: All these products have a very low flash point: Use of water spray when fighting fire may be inefficient. CAUTION: For mixtures containing high percentage of an alcohol or polar solvent, alcohol-resistant foam may be more effective. Note: Material Safety Data Sheets (MSDS) binders are located at each active project location and active maintenance facility for reference. Small Fires • Dry chemical, CO2, water spray or regular foam. Large Fires • Carbon Dioxide, Dry Chemical, Water spray, fog or regular foam. • Use water spray or fog; do not use straight streams. • Move containers from fire area if you can do it without risk. Fire involving Tanks or Car/Trailer Loads • Fight fire from maximum distance or use unmanned hose holders or monitor nozzles. • Cool containers with flooding quantities of water until well after fire is out. • Withdraw immediately in case of rising sound from venting safety devices or discoloration of tank. • ALWAYS stay away from tanks engulfed in fire. • For massive fire, used unmanned hose holders or monitor nozzles; if this is impossible, withdraw from area and let fire burn. SPILL OR LEAK • ELIMINATE all ignition sources (no smoking, flares, sparks or flames in immediate area). • All equipment used when handling the product must be grounded. • Do not touch or walk through spilled material. • Stop leak if you can do it without risk. • Prevent entry into waterways, sewers, basements or confined areas. • A vapor suppressing foam may be used to reduce vapors. • Absorb or cover with dry earth, sand or other non-combustible material and transfer to containers. • Use clean non-sparking tools to collect absorbed material. Large Spills • Dike far ahead of liquid spill for later disposal. • Water spray may reduce vapor; but may not prevent ignition in closed spaces. FIRST AID • Move victim to fresh air. • Call 911 or emergency medical service. • Apply artificial respiration if victim is not breathing. • Administer oxygen if breathing is difficult. • Remove and isolate contaminated clothing and shoes. • In case of contact with substance, immediately flush skin or eyes with running water for at least 20 minutes. • Wash skin with soap and water. • Keep victim warm and quiet. • Ensure that medical personnel are aware of the material(s) involved, and take precautions to protect themselves. 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 23 of 32 POTENTIAL HAZARDS Ref: Emergency Response Guide Book: Guide # 128 “Flammable Liquid” Page 204. FIRE OR EXPLOSION • HIGHLY FLAMMABLE: Will be easily ignited by heat, sparks or flames. • Vapors may form explosive mixtures with air. • Vapors may travel to source of ignition and flash back. • Most vapors are heavier than air. They will spread along ground and collect in low or confined areas (sewers, basements, tanks). • Vapor explosion hazard indoors, outdoors or in sewers. • Those substances designated with a “P” may polymerize explosively when heated or involved in a fire. • Runoff to sewer may create fire or explosion hazard. • Containers may create fire or explosion hazard. • Containers may explode when heated. • Many liquids, for example, petroleum products are lighter than water. • Substance may be transported hot. HEALTH • Inhalation or contact with material may irritate or burn skin and eyes. • Fire may produce irritating, corrosive and/or toxic gases. • Vapors may cause dizziness or suffocation. • Runoff from fire control or dilution water may cause pollution. PUBLIC SAFETY • CALL Emergency Response Telephone Number on Shipping Paper first. If Shipping Paper not available or no answer, refer to appropriate telephone number listed on inside back cover. • Isolate spill or leak area immediately for at least 25 to 59 meters (80 to 160 feet) in all directions. • Keep unauthorized personnel away. • Stay upwind. • Keep out of low areas. • Ventilate closed spaces before entering. PROTECTIVE CLOTHING • Wear positive pressure self-contained breathing apparatus (SCBA). • Structural firefighters’ protective clothing will only provide limited protection. EVACUATION Large Spill • Consider initial downwind evacuation for at least 300 meters (1000 feet). Fire • If tank, rail car or tank truck is involved in a fire, ISOLATE for 800 meters (1/2 mile) in all directions; also, consider initial evacuation for 800 meters (1/2 mile) in all directions. 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 24 of 32 FUELING OPERATIONS Smoking is prohibited during the refueling of any equipment. Clean the fuel cap area before opening. This will prevent dirt or moisture from entering your fuel system. After you remove the fuel cap, place it on the fuel trailer or the meter box to prevent losing the cap. (After fueling is completed replace the cap back on the equipment’s fuel receptacle.) Never put a rag, paper towels or any other material in the fuel receptacle in place of a missing fuel cap. If dirt, rags other materials enter the fuel system it will cause major problems. The only way to clean the system is to drain the tank and remove it and steam clean the tank. Next remove the fuel nozzle from the fuel tank hanger. Wipe the nozzle to ensure no dirt gets into your truck fuel tank. Then place the nozzle into the equipment’s fuel receptacle. Remain with the nozzle to prevent any fuel spillage. If you do spill fuel, dam the area immediately to prevent run off. Report the spill to your supervisor immediately. Fuel Spill will be cleaned up immediately and all contaminated soil will be removed and disposed of properly. A Safety Tip: Ensure that the fuel nozzle remains grounded to the equipment fuel receptacle to prevent any static sparks from occurring while fueling. If a fire occurs leave the nozzle in the tank. Removing the nozzle will spread the fire. A fire extinguisher should be accessible during all fueling operations in case of an emergency. 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 25 of 32 IT IS YOUR RIGHT TO KNOW ABOUT HAZARDOUS AND TOXIC SUBSTANCES WHERE YOU WORK FOR YOUR SAFETY CONTACT: Project Manager or Division Safety Manager (See Phone Listing) Transystems Service Center 800-548-9864 FOR FURTHER INFORMATION ON THE HAZARD COMMUNICATION PROGRAM 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 26 of 32 TRANSYSTEMS WRITTEN HAZARD COMMUNICATION PROGRAM AS REQUIRED BY OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION To all employees: All employers, including this company, must provide information to their employees about potential hazards of chemicals which they may be exposed to on the job. In our company there are some employees who are covered by this requirement because their work involves exposure to hazardous chemicals, and others who are not covered because their work does not involve such exposure. The Occupational Safety and Health Administration (OSHA) defines a covered employee as any worker who is exposed to hazardous chemicals under normal operating conditions or in foreseeable emergencies. OSHA explains that workers such as office workers or bank tellers who encounter hazardous chemicals only in non-routine, isolated instances are not covered. OSHA required that employers establish a written hazard communication program at each facility so that employees can access information about hazardous chemicals in the workplace as needed. We have surveyed work sites in this company to determine which work processes use hazardous chemicals. The names of these chemicals are the same as names shown on material safety data sheets for each chemical and on labels on containers of each chemical. The following is a listing of such chemicals. Parts Cleaning Solvent Acetylene Gasoline (leaded and unleaded) Oxygen Methyl Alcohol 25% Carbon Dioxide/75% Argon Anti-Freeze Sulfuric Acid Motor Oil. Used Windshield Washer Solvent Motor Oil SAE 50 Steel coated Paint Motor Oil SAE 15W-90 Steel coated Solvent Diesel Fuel Penetrating Oil Gear Lubricant SAE 80W-90 RTX Silicone Gasket Maker Polyuria EP Grease Anti-seize Lubricant Thread Cutting Oil Welding Gases Argon Hydraulic Oil Diesel Fuel Additive Automatic Transmission Fluid Automatic Transmission Fluid ARCAIR Air Carbon Electrodes 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 27 of 32 Labels are placed on containers by manufacturers and distributors to serve as an immediate visual warning of the chemical hazards in the workplace. It is not the responsibility of our company to label containers but periodically company managers will inspect containers to assure that labels are intact and legible. Our company will also assure that there are material safety data sheets available to employees at the workplace for each hazardous chemical used. The material safety data sheets are provided to us by manufacturers and distributors of chemicals when we purchase them. These safety data sheets will be maintained in the workplace and readily accessible to any employee by asking the immediate manager. The material safety data sheet contains the following information: • • • • Identity of the material; Physical and chemical characteristics; Physical hazards including potential for fire, explosion and reactivity; Health hazards including signs and symptoms of exposure, and any medical conditions which are generally recognized as being aggravated by exposure to the chemical; • Primary routes of entry into the body; skin absorption, smell, etc. • Exposure limits; • Whether the chemical is listed in the National Toxicology Program Annual Report on Carcinogens or has been found to be a potential carcinogen in the International Agency for Research on Cancer Monographs, or by OSHA; • Any generally applicable precautions for safe handling and use including appropriate hygienic practices, protective measures during repair and maintenance of contaminated equipment, and procedures for cleaning up spills and leaks; • Any generally applicable control measures such as engineering controls, work practices, or personal protective equipment; • Emergency and first aid procedures; • Date of preparation of the material safety data sheet or the last change to it; • Name, address and telephone number of the party preparing or distributing the • MSDS who can provide additional information on the hazardous chemical and appropriate emergency procedures, if necessary. If no relevant information is found for any given category on a material safety data sheet, the MSDS will be marked to indicate that no applicable information was found. In addition, where complex mixtures have similar hazards and contents, one material safety data sheet may apply to all of these similar mixtures. Employees will receive information and training about hazardous materials exposure at the time of an employee’s initial work assignment in an area where hazardous chemicals are used and whenever a new hazard is introduced into their work area. Managers will show and explain labels, material safety data sheets, and other hazard warnings. Managers will also explain the nature of hazardous chemicals in specific workplaces and the written hazard communication program. Training will include instruction to employees on methods and observations to detect the presence or release of a hazardous chemical (such as monitoring by the company, visual 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 28 of 32 appearance, or odors). Training will also include instruction to employees on physical and health hazards, protective measures, and details of the hazard communication program. Employees will be instructed on how to obtain and use hazard information. For employees who handle sealed containers of chemicals and do not open the containers under normal conditions, our company will: • • • • Maintain and provide access to material safety data sheets that are received for hazardous chemicals while the chemicals are in the workplace; Obtain material safety data sheets when they are not received but an employee requests one; Insure that labels on incoming containers of hazardous materials are not removed or defaced; Provide information and training to the extent needed to protect those employees in the event of a spill or a leak. Employees who have questions about this program or who are seeking additional information should request this information through their manager. 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 29 of 32 Transystems Hazardous Materials Inventory NFPA Classifications Chemical List (MSDS) Cleaning Solvents Gasoline (leaded & unleaded) Methyl Alcohol Anti-Freeze Motor Oil (Used) Motor Oil SAE 50 Motor Oil SAL 15-40 W #2 Diesel Fuel Gear Lubricant SAE 80-90 W Polyuria E.P. Grease Thread Cutting Oil Argon Acetylene Oxygen 25% Carbon Dioxide/ 75% Argon Sulphuric Acid Windshield Washer Solvent Steel coated paint Steel coated Solvent Penetrating Oil RTX Silicone Gasket Maker Anti-Seize Lubricant Welding Gases Hydraulic Oil Diesel Fuel Additive Automatic Transmission Fluid ARCAIR Air Carbon Electrodes Fire Reactivity Specific Health 2 0 * 1 4 0 * 2 4 2 * 2 1 2 * 1 1 0 * 1 1 0 * 1 1 0 * 1 2 0 * 1 1 0 * 0 1 0 * 0 1 0 * 0 0 0 * 1 4 3 * 1 0 0 OXY 3 0 0 0 1 0 3 Acid 3 4 2 * 1 3 0 * 1 3 0 * 1 2 0 * 1 1 0 * 1 4 0 * 1 See MSDS for Information 1 0 * 1 3 0 * 1 1 0 * 1 0 0 * 1 Note: The numbering system above is to be used as a guide when applying the hazard degree to the warning decals. A lettering device or ink should be used that will not wash off. 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 30 of 32 RECORD OF DIKE DRAINAGE Instructions: Project Manager will complete this form when rainwater from dike area is released into a storm drain or into an open water course, lake, or pond, and bypasses the in-plant treatment. This form will also be used to record removal of rainwater from containments and its disposal. Maintain record with the SPCC Plan at the project. Facility Name: ____________________________________________________________ Dike Area Date Presence of Oil Time Started Time Finished Printable Form - Maintain record with the SPCC Plan at the project. 900-O-P2-8-12 Signature SIDNEY MT SPCC PLAN - VERSION 1 - Page 31 of 32 SIDNEY MT CONTAINMENT CALCULATIONS AND DIMENSIONS Aboveground Storage Tank 900-O-P2-8-12 SIDNEY MT SPCC PLAN - VERSION 1 - Page 32 of 32 FACILITY INSPECTION CHECKLIST Instructions: This inspection record will be completed every month. Place an X in the appropriate box for each item. If any response requires elaboration, do so in the descriptions and comments space provided. Further descriptions or comments should be attached on a separate sheet of paper if necessary. Transystems Yes No Descriptions, Date and Comments Facility Inspection Checklist Tank surfaces show signs of leakage Tanks are damaged, rusted, or deteriorated Bolts, rivets, or seams are damaged Tank supports are deteriorated or bulked Tank foundations have eroded or settled Level gauges or alarms are inoperative Vents are obstructed Valve seals or gaskets are leaking Pipelines or supports are damaged or deteriorated Loading/unloading area is damaged or deteriorated Connections are not capped or blank-flanged Secondary containment is damaged or stained Has the containment been repaired within the past 30 days : Cracks or other damage Dike drainage valves are open Fencing, gates, or lighting is non-functional Has any minor spills or releases occurred within the past 30 days Inspectors Name: Date of Inspection: Date corrective actions completed: Signature: Verified by Inspector: Printable Form: File completed document with SPCC Plan at the project office. 900-O-P2-8-12
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