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HomeMy WebLinkAboutM_Hazardous_Materials_Management_Statement_091625_v1 1 SPILL PREVENTION CONTROL, COUNTERMEASURE AND SPILL CONTINGENCY PLAN (SPCC) Prepared For VALVOLINE INSTANT OIL CHANGE Market Service Center # 90192 4225 NE 4th St Renton WA 98059 Prepared by Valvoline Environmental Staff A copy of the SPCC Plan shall be available at the VIOC site electronically via the POS System (VPOINT Safety and Compliance\SuperPro Management\SPCC) i SPILL PREVENTION CONTROL & COUNTERMEASURE SPILL CONTINGENCY PLAN TABLE OF CONTENTS Spill Prevention Control and Countermeasure Plan Page Table of Contents i SPCC Cross Reference Table ii Purpose 1 Section 1 - General Facility Information 2 Plan Certification and Management Approval 3 Certificate of Applicability Substantial Harm Criteria 4 Amendments 5 Section 2 – Oil Storage and Handling 7 Bulk and Container Storage 7 Piping 7 Material Inventory 8 Potential Spills - Prediction and Control 9 Section 3 - Preventive Maintenance 12 Section 4 - Transfer Operations 14 Section 5 - Personnel Training 14 Emergency Response Procedures Action Procedures 15 Spill Response Table - Delegation of Duties 17 Spill Response 18 Alert Procedure 19 Valvoline Spill Reporting Information 20 Appendices 21 Site Drawings ii CROSS REFERENCE TABLE OF CONTENTS U.S. Environmental Protection Agency (U.S. EPA) Regulation, 40 CFR 112 SPCC SECTION SPCC DESCRIPTION PLAN REFERENCE General Facility Information Section 1. General Information General Operator and Owner Addresses/ phone numbers Section 1. General Information 112.1(b) General applicability Purpose 112.1.2 (ii) Applicability: storage capacity >1320 gal, container size 55 gal or larger. Purpose 112.3(d)(iv) Procedures for inspection and testing Section 3. Preventive Maintenance 112.4(a) Spill reporting to EPA Regional Admin. Alert Procedure \ Amendments 112.5(b) Plan review at least once every 5 years. Section 1. General Information 112.6 (a) Self-Certification 112.7 General Requirements – cross reference SPCC Cross reference \ Certification 112.7(a)1 Discussion of the facility’s conformance Management Approval \ Attachment Action Items 112.7(a)2 Comply with all applicable requirements Management Approval \ Attachment Action Items 112.7(a)3 Describe the physical layout and include a facility diagram Section 1. General Information / Attachment 112.7(a)3(i) Type of oil in each container and capacity. Potential Spill Prediction and Control 112.7(a)3(ii) Discharge prevention measures, including procedures for routine handling of products. Section 4. Transfer operations 112.7(a)3(iii) Discharge or drainage controls Section 4. Transfer operations 112.7(a)3(iv) Countermeasures for discharge discovery, response and cleanup. Action Procedures 112.7(a)3(v) Methods of disposal of recovered materials. Action Procedures 112.7(a)3(vi) Contact list and phone numbers. Alert Procedures 112.7(a)4 Information and procedures to report a discharge. Alert Procedures / Attachment Form 7032 112.7(a)5 Organize portions of the plan describing (spill) procedures so it is readily usable. See Action Plan and Delegation of Duties 112.7(b) Spill prediction Potential Spills Prediction and Control 112.7(c) Appropriate containment and/or diversionary structures to prevent a discharge. Potential Spills Prediction and Control 112.7(e) Inspections, test and records. Section 3 & Appendix 112.7(f) Personnel, training, and discharge prevention procedures. Section 5. Personnel Training 112.7(g)1 Security – fencing Section 3 Preventive Maintenance ( c) Security 112.7(g)2 Security – valves Section 3 Preventive Maintenance ( c) Security 112.7(g)3 Security – pump/motor starter controls Section 3 Preventive Maintenance ( c) Security 112.7(g)4 Security – cap or blank out of service piping. Section 3 Preventive Maintenance ( c) Security 112.7(g)5 Security – facility lighting Section 3 Preventive Maintenance ( c) Security 112.7(h)1 Tank car/truck loading/unloading – drainage & containment. Section 4 Transfer Operations 112.7(h)2 Tank car/truck loading/unloading – disconnect warning. Section 4 Transfer Operations 112.7(h)3 Tank car/truck loading/unloading – inspect all outlets before departure. Section 4 Transfer Operations 112.7(i.) Brittle Fracture evaluation of field erected ASTs after repair, alteration, etc. Not Applicable iii CROSS REFERENCE TABLE OF CONTENTS (Continued) SPCC SECTION SPCC DESCRIPTION PLAN REFERENCE 112.7(j) Discussion of conformance with any additional discharge prevention and containment procedures required by any State rules, regulations or guidelines. Special State requirements will be added to this plan as defined in the State Laws and Regulations. 112.8(a) Meet the general requirements for the Plan listed under Sec. 112.7 and the specific requirements in Sec. 112.8. Cross-reference. 112.8(b)1 Facility Drainage – Restrain drainage from diked storage areas by valves… Section 2. Bulk and Container Storage 112.8(b)2 Facility Drainage – Use valves of manual, open/close design. Section 2. Bulk and Container Storage 112.8(b)3 Facility Drainage – Design drainage from undiked areas with a potential for discharge… Section 2. Bulk and Container Storage 112.8(b)4 Facility Drainage – If not (b)3, then a diversion system that would retain oil at the facility. Section 2. Bulk and Container Storage 112.8(b)5 Facility Drainage – Redundant pumps if pump transfer is utilized. Not Applicable 112.8(c)1 Bulk Storage Containers – Compatible material. Section 2. Bulk and Container Storage 112.8(c)2 Bulk Storage Containers – Secondary containment. Section 2. Bulk and Container Storage 112.8(c)3 Bulk Storage Containers – Storm water drainage from secondary containment. Not Applicable secondary containment is under roof. 112.8(c)4 Bulk Storage Containers – Completely buried, protect from corrosion. Section 2. Bulk Container Storage 112.8(c)5 Bulk Storage Containers – Partially buried or completely buried, protect from corrosion. Section 2. Bulk Container Storage 112.8(c)6 Bulk Storage Containers – Integrity testing on a regular schedule and after material repairs. Section 3. Preventive Maintenance (b) Integrity Inspections. 112.8(c)7 Bulk Storage Containers – monitor steam return lines on internal heating coils. Not Applicable 112.8(c)8 Bulk Storage Containers – High level alarm and/or automatic liquid level gauge and regular testing of same. Section 4. Transfer Operations 112.8(c)9 Bulk Storage Containers – Observe effluent treatment facilities frequently enough to detect a leak. Section 3. Preventive Maintenance (a) Visual Inspections, Oil Water Separator. 112.8(c)1 0 Bulk Storage Containers – Promptly correct visible discharges. Section 3. Preventive Maintenance 112.8(c)1 1 Bulk Storage Containers – Position or locate Mobile or Portable oil storage containers to prevent discharge, including providing a secondary means of containment. See Section 2. Bulk and Container Storage 112.8(d)1 Facility Transfer Operations – Buried piping Section 2 Piping 112.8(d)2 Facility Transfer Operations – Cap or blank flange piping that is not in service. Section 2 Piping 112.8(d)3 Facility Transfer Operations – Pipe supports Section 2 Piping 112.8(d)4 Facility Transfer Operations – Regularly inspect all aboveground valves, piping and appurtenances. Section 3 Preventive Maintenance (a) Visual Inspections 112.8(d)5 Facility Transfer Operations – Warn all vehicles entering the facility that could endanger aboveground piping or other oil transfer operations. Section 3 Preventive Maintenance (a) Visual Inspections 1 PURPOSE The following document is designed to help VIOC prevent the release of oil and to comply with regulations and guidance set forth in 40 CFR 112 and 40 CFR 109 and is to be followed by company personnel when dealing with oil spill emergencies. It is the intent of Valvoline Instant Oil Change to comply with all applicable regulations pertaining to Spill Prevention, Control and Countermeasure (SPCC) Plans and Spill Response Plans. Therefore, based on the size of a service center and the maximum volume of oil the service center contains at one time, the SPCC and Spill Contingency Plans were compiled to apply specifically to the oil change industry. SPCC rules apply to containers 55 gallons and greater. The prevention of oil spills is a primary objective of the company in all our operations, and this objective can best be accomplished through good housekeeping, adequate equipment, proper maintenance, and personnel adhering to proper operation procedures. If an accidental spill does occur, it will require the immediate coordination efforts of various company personnel and perhaps, the assistance of outside agencies. The purpose of this SPCC and Spill Contingency Plan is as follows: (1) To set forth procedures for preventive maintenance operations to be followed by company personnel; • Prevent spill or leak from occurring (2) To provide appropriate designation of authority for the assignment of jobs to prevent an oil spill; (3) To provide an indication of priority and importance to a list of jobs that must be done when oil is spilled; • Respond with quick and effective spill containment procedures; (4) To provide communication patterns to assure coordination of efforts; (5) To provide reference materials to those responsible for various duties arising as the result of a spill. It is our goal to, as practicable as possible, limit damage to property, wildlife, or the environment from such a spill or release. The plan will be modified, as there is a change in the facility design, construction, operation, or maintenance that materially affects its potential for a discharge. SPCC rules require that the plan be reviewed every five years. 2 1. GENERAL FACILITY INFORMATION 1. Name of facility: Valvoline Instant Oil Change 2. Type of facility/description: Vehicle oil change center Date of initial operation: 7/10/2026 3. Location of facility: 4225 NE 4th St Renton WA 98059 4. Name and address of owner or operator: Name: Valvoline Instant Oil Change Address: 100 Valvoline Way Lexington, Kentucky Phone: 833-VVV-Report (833-888-7376) 5. Designated person accountable for oil spill prevention at facility: Name and Title: Market Manager – Doug Norris dnorris@valvoline.com 6. Facility reportable oil spill history is maintained by Valvoline EH&S and is available upon request. 7. Fixed and general oil storage is presented in the “Potential Spills – Prediction and Control” section. 8. A facility diagram is presented in the Attachment. The diagram shows the location of all fixed tanks and direction of runoff. 3 Market «Region» Service Center «ID_» Valvoline Instant Oil Change SPCC Plan Management Certification: In accordance with 40 CFR 112.6 (a) I attest: 1. I am familiar with the requirements identified within this plan. Our SPCC Subject Matter Experts (SME) are familiar with our facility and identified within this plan the applicable regulations, procedures, and inspections. 2. I have visited and examined the facility. 3. The plan was prepared by our SME in accordance with accepted and sound industry practices and SPCC regulatory requirements. 4. The spill prevention, containment and countermeasure procedures, and inspections as described by this plan are implemented. 5. Less than 10,000 gallons of oil is stored on site. 6. The facility has not released 1,000 gallons of oil or had two 42 gallon releases within a 12 month period over the past 3 years. 7. Full containment is provided for oil containers 55 gallons or larger. 8. This plan and individual responsible for implementing the plan have full approval of Valvoline Instant Oil Change management to commit the necessary resources to fully implement the plan. Market Manager Signature: ____________________________________________ Name: _ Doug Norris __ Date: ____________________ Next Five* Year Plan Review Date: 8/5/2031 Note: An updated Engineering Review is required when the plan will be modified, as there is a change in the facility design, construction, operation, or maintenance that materially affects its potential for a discharge. * SPCC regulations require a five-year review. Revisions to the Plan, if any are needed, are made within six months of this five-year review. VIOC will implement any amendment as soon as possible, but not later than six months following preparation of any amendment. 4 CERTIFICATION OF APPLICABILITY OF SUBSTANTIAL HARM CRITERIA In compliance with 40 CFR 112.20 (e), Valvoline has evaluated the applicability of the substantial harm criteria listed below and has completed the required certification. (40 CFR 112, Appendix C, Attachment C II) Facility Name: Valvoline Instant Oil Change Facility Address: 4225 NE 4th St Renton WA 98059 1. Does the facility transfer oil over water to or from vessels and does the facility have a total oil storage capacity greater than or equal to 42,000 gallons? Yes___ No X 2. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and does the facility lack secondary containment that is sufficiently large to contain the capacity of the largest aboveground oil storage tank plus sufficient freeboard to allow for precipitation within any aboveground oil storage tank area? Yes ___ No X 3. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance (as calculated using the appropriate formula in Attachment C- III to this appendix or a comparable formula {1}) such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments? For further description of fish and wildlife and sensitive environments, see Appendices I, II, and III to DOC/NOAA's "Guidance for Facility and Vessel Response Plans: Fish and Wildlife and Sensitive Environments" (see Appendix E to this part, section 10, for availability) and the applicable Area Contingency Plan. Yes___No X 4. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance (as calculated using the appropriate formula in Attachment C- III to this appendix or a comparable formula{1}) such that a discharge from the facility would shut down a public drinking water intake{2}? Yes___ No X 5. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and has the facility experienced a reportable oil spill in an amount greater than or equal to 10,000 gallons within the last 5 years? Yes ___ No X CERTIFICATION I certify under penalty of law that I have personally examined and am familiar with the information submitted in this document, and that based on my inquiry of those individuals responsible for obtaining this information, I believe that the submitted information is true, accurate, and complete. Signature ___________________________ Name (please type or print) Doug Norris Title __Market Manager__________________________ 5 Amendments A log of plan amendments is provided in the attachment. An SPCC Plan is not required to be filed with the US EPA, but a copy must be available for on- site review by the Regional Administrator (RA) during normal working hours. The SPCC Plan must be submitted to the US EPA Region and the state agency along with the other information specified in Section 112.4 (a) if either of the following occurs: 1. The facility discharges more than 1,000 gallons of oil into or upon the navigable waters of the United States or adjoining shorelines in a single spill event; or 2. The facility discharges oil in quantities greater than 42 gallons in each of two spill events within any twelve-month period. The following spill information must be submitted to the RA within 60 days if either of the above thresholds is reached. This report is to contain the following information (112.4 (a)): 1. Name of the facility. 2. Name of the individual submitting the information. 3. Location of the facility. 4. Maximum storage or handling capacity of the facility and normal daily throughput. 5. The corrective actions and/or countermeasures taken, including adequate description of equipment repairs and/or replacements. 6. Description of the facility including maps, flow diagrams, and topographical map.. 7. The cause(s) of such spill(s), including a failure analysis of system or subsystem in which failure occurred. 8. Additional preventive measures taken or contemplated to minimize the possibility of recurrence. 9. Such other information as the Regional Administrator may reasonably require that is pertinent to the plan or spill event(s). 6 SPCC regulations require a five-year review. Revisions to the Plan, if any are needed, are made within six months of this five-year review. VIOC will implement any amendment as soon as possible, but not later than six months following preparation of any amendment. 112.3(d). SPCC regulations require a (5) five-year review. Next Five-Year Plan Review Date: 8/5/2029 Amendment or Review Date Personnel, Physical, or Operational Change Amendment Location in SPCC Contingency Plan 9/5/2025 New Plan Corrective Action Items 1. None Facility Description This VIOC facility performs automotive oil changing services (filter and fluid) and other automotive services such as the sale and installation batteries, and headlights. The site stores greater than 1,320 gallons of oil in containers 55 gallons or larger including tanks listed the following tables. The facility is equipped with an oil-water separator to treat storm water, snow melt from cars and wastewater generated from cleaning activities. The pit in the service is also designed to provide secondary containment for the oil products stored on site. A summary of the secondary containment is provided on the following tables. The oil changing operation occurs in a service bay. The vehicle is driven and positioned where the VIOC employees perform oil changes. Movable drain trays are placed directly under the drain plug of the vehicle being serviced. The used oil is drained into the tray and is gravity drained to the used oil AST located in secondary containment. After draining the oil, the drain plug is installed, and the oil filter replaced. The new oil ASTs are equipped with pneumatic pumps and are piped to dispenser reels on the ground-level where the new oil is dispensed into the vehicle. 7 SECTION 2 - OIL STORAGE AND HANDLING BULK AND CONTAINER STORAGE All bulk tanks and containers are stored in a manner to prevent the release of oil to the environment. VIOC lubricant oils are non-corrosive and are stored in containers made of compatible materials. All tanks are shop built and located inside the service centers under roof to minimize corrosion. VIOC provides containment with sealed concrete lower level built with an impermeable barrier. The Service Center’s site-specific containment is described in the tank and container Potential Spills Prediction and Control Table located below: • Aboveground tanks are located as designated in the Potential Spills Prediction and Control Table. The lower level of the service center has a sealed concrete floor with impermeable barrier installed under the floor and outside walls. The lower level has no floor drains and lift pumps are located above floor level to provide secondary containment for the facility. • 55-gallon containers are pumped to bulk tanks, or 55-gallon containers located in the lower of the service center to contain potential spills. PIPING • All piping is aboveground and indoor. The piping is installed in oil gun islands and extends through the pit to minimize the potential for a vehicle to damage the piping or service equipment. The piping is inspected in accordance with the preventive maintenance procedure in Section 3. All piping is installed to minimize the potential for a release. • The site has no buried piping. • All piping fill ports, or open pipe ends are flanged or capped when not in use. 8 Material Inventory Chemical Name Product Name CAS Number Oil \ Aliphatic Hydrocarbons Motor Oil & Lubricants Various Types None Oil \ Aliphatic Hydrocarbons Used Oil None Methanol \ Water Window Wash Solutions 67-56-1 Ethylene Glycol Anti Freeze \ Spent Anti- Freeze 107-21-1 Safety Data Sheets (SDS) for all inventoried products stored at this facility are on file at this location or on the POS system. SDS sheets for non-inventoried materials are maintained electronically in the POS in VPOINT. 9 2. POTENTIAL SPILLS – PREDICTION AND CONTROL (TANKS AND BULK TRANSFER) Please Note: The number and type of containers, content, volume, and locations of each stored material will vary according to customer demand. Contents A Volume (gallons) Location Secondary Containment Direction of Flow & First Response Location B Motor Oil Delivery/ Used Oily Transfer C 3,000 Drive Paved Area \ Spill Kits Release will follow general site drainage Window Wash Solution 105 Bottom Side Contained pit / basement, manual discharge after inspection for release Flow contained Inside Basement (See Drawing) Window Wash Solution 105 Bottom Side Contained pit / basement, manual discharge after inspection for release Flow contained Inside Basement (See Drawing) Antifreeze 105 Bottom Side Contained pit / basement, manual discharge after inspection for release Flow contained Inside Basement (See Drawing) Antifreeze 105 Bottom Side Contained pit / basement, manual discharge after inspection for release Flow contained Inside Basement (See Drawing) Spent Antifreeze 200 Bottom Side Contained pit / basement, manual discharge after inspection for release Flow contained Inside Basement (See Drawing) Lubricating Oil 200 Bottom Side Contained pit / basement, manual discharge after inspection for release Flow contained Inside Basement (See Drawing) Lubricating Oil 200 Bottom Side Contained pit / basement, manual discharge after inspection for release Flow contained Inside Basement (See Drawing) Contents A – TF = Transmission fluid (any type), UAF – Used Anti-freeze all types, WW – Window wash solution (Methanol and water) Direction of Flow and First Response Location B - please note response plan and drawing in Appendix. Bulk Transfer Areas C – physical secondary containment in not required for bulk truck loading and unloading areas that do not have a loading rack. VIOC provides spill kits and trains personnel to block off storm drains and drainage to contain and prevent oil from entering storm water system or leaving the site. 10 2. POTENTIAL SPILLS – PREDICTION AND CONTROL (TANKS Continued) Please Note: The number and type of containers, content, volume, and locations of each stored material will vary according to customer demand. Contents A Volume (gallons) Location Secondary Containment Direction of Flow & First Response Location B Lubricating Oil 200 Bottom Side Contained pit / basement, manual discharge after inspection for release Flow contained Inside Basement (See Drawing) Lubricating Oil 200 Bottom Side Contained pit / basement, manual discharge after inspection for release Flow contained Inside Basement (See Drawing) Lubricating Oil 200 Bottom Side Contained pit / basement, manual discharge after inspection for release Flow contained Inside Basement (See Drawing) Lubricating Oil 200 Bottom Side Contained pit / basement, manual discharge after inspection for release Flow contained Inside Basement (See Drawing) Lubricating Oil 200 Bottom Side Contained pit / basement, manual discharge after inspection for release Flow contained Inside Basement (See Drawing) Lubricating Oil 200 Bottom Side Contained pit / basement, manual discharge after inspection for release Flow contained Inside Basement (See Drawing) Lubricating Oil 200 Bottom Side Contained pit / basement, manual discharge after inspection for release Flow contained Inside Basement (See Drawing) Lubricating Oil 250 Bottom Side Contained pit / basement, manual discharge after inspection for release Flow contained Inside Basement (See Drawing) Lubricating Oil 250 Bottom Side Contained pit / basement, manual discharge after inspection for release Flow contained Inside Basement (See Drawing) Lubricating Oil 250 Bottom Side Contained pit / basement, manual discharge after inspection for release Flow contained Inside Basement (See Drawing) Lubricating Oil 250 Bottom Side Contained pit / basement, manual discharge after inspection for release Flow contained Inside Basement (See Drawing) Used Oil 500 Bottom Side Contained pit / basement, manual discharge after inspection for release Flow contained Inside Basement (See Drawing) Used Oil 500 Bottom Side Contained pit / basement, manual discharge after inspection for release Flow contained Inside Basement (See Drawing) Contents A – TF = Transmission fluid (any type), UAF – Used Anti-freeze all types, WW – Window wash solution (Methanol and water) Direction of Flow and First Response Location B - please note response plan and drawing in Appendix 11 2. POTENTIAL SPILLS – PREDICTION AND CONTROL (DRUMS & PORTABLE CONTAINERS Continued) Please Note: The number and type of drums and portable containers, content, volume, and locations of each stored material will vary according to customer demand. Number of Container by Type \ Location A Contents B Volume (gallons) Location Secondary Containment Direction of Flow & First Response Location C * All oil drums 55 gallons or greater will be located within contained areas. Container A - Possible complete or partial failure of these containers provides the potential for a release Contents B – TF = Transmission fluid (any type), AF – Anti-freeze all types, WW – Window wash solution (Methanol and water) Direction of Flow and First Response Location C - please note response plan and drawing in Appendix. 12 3. PREVENTIVE MAINTENANCE The following procedures have been established as a preventive maintenance and pollution prevention tool. The purpose is to maintain equipment in an optimal working condition and prevent potential risk of a release into the environment. When a problem is detected it is to be immediately corrected by repairing or taking the tank out of service and removing any accumulation of oil. The corrective actions shall be communicated as warranted by the nature of the corrective actions. 1) Visual Inspections: The Service Center Manager (SCM) or his designee is responsible for ensuring that bulk storage tanks, portable storage containers and secondary containment located at the service center are always in good condition. In accordance with 40 CFR 112.8(c)(10) all leaks and drips are corrected through appropriate equipment maintenance. Documented weekly visual inspections are conducted to assure all leaks and drips are identified and corrected. Service Center personnel will visually inspect each tank (active and inactive) and containers 55 gallons or larger located at the facility using the checklist in the Appendix of this plan. Completed inspection forms are maintained for three years in accordance with 40 CFR 112.7(e) in the Service Center EH&S files. Tank and Containment System (Located Annual Compliance Manual, Monthly Tabs) (Monthly Inspection) i) All sides of aboveground storage tanks (ASTs) will be checked: • for corrosion, pitting, valve leaks, seam leaks and weakness; • floor and foundation for sign of deterioration of support structure ii) The associated pipes will be thoroughly checked: • for dry-rotting, cracking, and loose connections; iii) The containment wall, if applicable, will be checked: • for loose bricks, cracks, holes in the wall, seam cracks, and seams between floor and wall; iv) The containment area or tank locations will be checked for: • water or product in the area, find source and stop leak; Used Oil Tank Level and Oil/Water Separator Inspection: (Located Annual Compliance Manual, Monthly Tabs) To prevent costly and dangerous overfill problems with the used oil tank, a checklist has been established for daily used oil tank gauging. Each day the used oil tank will be gauged and recorded electronically. The electronic records are available from VIOC operations upon request and will be maintained for 3 years. Oil/Water Separator is checked weekly and skimmed free of oil as required. The date of skimming, volume skimmed, and person responsible is recorded each week. 13 Spill Containment Kit: (Quarterly Inspection – The checklist is located in the January, April, July & October Monthly Tabs of the Compliance Manual) To verify that this Service Center has the appropriate spill containment equipment, the spill kit will be checked quarterly using the checklist located in the Compliance Manual. 2) Integrity testing: As required by 40 CFR 112.8(c)(6), integrity testing must take into account container size, configuration, and design. The Steel Tank Institute Standard SP001 recommends that steel ASTs storing flammable and combustible liquids be inspected at periodic intervals, depending upon their Category. Per the SP001 standard, ASTs less than five thousand gallons in volume that are considered “Category 1” tanks (integral secondary containment or outer containment tanks) do not require internal integrity tests or external integrity tests that need to be conducted by a certified AST inspector. Rather, Category 1 ASTs require periodic AST inspection by a person designated by the owner who is knowledgeable of the storage system. Periodic AST inspections do not require internal access to the ASTs nor any quantitative testing methods; the inspection is a thorough external visual inspection of the storage tank system and its supports and foundation. VIOC technicians are familiar with the storage systems and perform this periodic inspection as part of the weekly SPCC visual inspection. If the AST inspection reveals an issue (e.g. deformity, damage, significant corrosion) that may require inspection by a certified AST inspector or pressure testing, the service center employees will contact 833-VVV-Report (833-888-7376) and Area Manager to determine if the AST should remain in-service pending the inspection or replacement. AST integrity testing records will be maintained for a minimum of 3 years as a means for comparison, but it is recommended that they be maintained for the life of the tank. 3) Security: Each facility is equipped with an emergency communication system and remains locked during closed hours. Surveillance cameras are also used at the facility 24 hrs a day to deter theft or damage to the property. Drums and tanks are located inside the building within containment. 4) Spill History - 40 CFR 112.7 (a): Copies of significant spill reports and recent spill prevention evaluations are available from the EH&S department. 14 4. TRANSFER OPERATIONS During all transfer operations of bulk and used oil, the following operations are to be used by all VIOC personnel and the bulk oil contractors. The supplier utilizes a tanker truck for these deliveries and pickups. A “quick drainage system” is not required in the loading and unloading areas of the VIOC Center. VIOC and the oil delivery/pickup supplier provide prevention and control measures per 40 CFR 112.7(c) in these loading: • Verify that the tank or collection truck has the capacity to hold the volume of oil being transferred. • During the transfer no one will be allowed in the vehicle and the brakes must be set. • Make the correct connections at all valve locking terminals; • In accordance with 112.8 (iv) a person must observe the direct vision gauge or the level in the tank when product transfer is made. • When using a hose reel and nozzle dispenser the SCM will ensure that the product is dispensed to the correct tank and that all transfers are conducted in paved areas. • Used oil collection drivers shall locate their vehicle as close as possible to the service bays to minimize hose sections located outside the contained area. Used oil transfers shall be conducted with a suction pump to minimize a release of product in the hose which will be contained on the pavement or in the building. • Ensure there are no line, terminal or valve leaks; • The drivers conducting the transfers shall assure all lines are disconnected and any drips are cleaned up prior to departing. In the event of a bulk oil overflow or valve/line leak the SCM must ensure that the driver corrects the problem, contains the spilled material, and contacts the appropriate management personnel. Furthermore, the driver is responsible for cleanup costs and procedures. All transfers shall be conducted over paved areas. 5. PERSONNEL TRAINING New VIOC employees receive general operations training, interactive on-line spill response training, and “on-the-job” training on handling oil as required by 40 CFR 112.7(f). Training also covers accidental releases, spill kit, emergency response numbers, high-level alarms, groundwater management, oil water separator inspections, and housekeeping. Every manager will review the SPCC Plan on an annual basis, and train the VIOC center employees on spill prevention, proper spill notification and cleanup procedures through the VIOC Buzz Session format. 15 6. ACTION PROCEDURE Appropriate actions (to control, contain, notify, remove, clean-up and properly dispose of spills) are to begin immediately whenever a spill is reported by an employee. The immediate responsibility for these actions rests with the ranking company employee on the scene. If the spill presents a fire or safety hazard the Service Center employees will verbally notify all employees to evacuate the facility before proceeding with the following actions. Responsibility will move to higher levels of management depending upon the size of the spill, the ability of local units to control it and the potential for damage. If a spill occurs during the loading or unloading operations by a supplier, the supplier will implement their emergency spill response, cleanup, and reporting procedures. The supplier is required to carry in their truck a copy of their emergency spill response, cleanup, and reporting procedures, and appropriate spill response equipment (i.e., spill kit). Additional spill response supplies, and support may be by the Service Center but the Service Center is responsible for notifying the supplier for replacement. 1. Find source of spill and stop the release 2. Contain spill within building or on Site (Use Spill Kit for larger spills) 3. Contact 833-VVV-Report (833-888-7376) and Area Manager (Valvoline EH&S will Initiate Agency Notifications) 4. Valvoline will provide spill cleanup contractor if necessary 5. Find outfall of storm sewer to assure oil was not released off-site. 6. Check and skim oil water separator. 7. Arrange security of site and drive if oil has potential to exit lot. 8. Work with Valvoline EH&S on proper waste disposal 9. Complete Spill Prevention and Analysis Summary and submit to VIOC Regional Office Manager When a spill meets the following criteria, the Valvoline Emergency Number (833-888-7376) must be called within the first fifteen (15) minutes of detection. • All spills, any volume, which occurs outside the building or exits the building and enters the environment must be reported immediately. • All spills which occur within the service center and are greater than 5-gallons must be reported to 833-VVV-Report (833-888-7376) immediately. 16 Records It is important to keep a written record of all clean-up operations and decisions. These will be needed if the service center is found responsible for the spill and/or damages caused by the spill. The cost for clean-up of a spill can be extremely high. Every action taken and every piece of material, machinery or personnel used must be recorded to assure proper cost documentation. On major spills, a risk management file should be utilized to perform this function. 17 SPILL RESPONSE DELEGATION OF DUTIES TABLE 1 Responsibility Size of Spill Minor 25 gals or less Medium - Large 25 or greater 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Find source of spill and stop. Contain spill within building.* Find and cover outfall of storm sewer Contact EH&S personnel. Alert management of situation. Notify Appropriate Fed, State and Local agencies. Contact spill cleanup contractor Notify Law Department Notify Media Department Notify Sewer Dep. Water users Setup command post Arrange security of site. Contact Risk Management Services. Arrange for local lab service Waste Disposal SCM** SCM** SCM SCM** SCM** EH&S EH&S EH&S N/A N/A NA N/A N/A EH&S EH&S EH&S SCM** SCM** SCM & AM SCM** SCM** EH&S EH& EH&S EH&S EH&S AM & EH&S SCM & AM AM EH&S EH&S EH&S * When a spill exits the building, or a spill has occurred outside the building, you must immediately notify Valvoline EH&S personnel through the Emergency Command Center. SCM** - The job duties are not entirely the responsibility of the service center manager (SCM). The service center manager will delegate the responsibility to the other VIOC employees as necessary. There will always be a minimum of two people at a service center. Additionally, each VIOC service center has been equipped with a spill containment kit, applicable to the service center layout. 18 8 SPILL RESPONSE The vast majority of potential spills will be contained within the service center by use of secondary containment and spill containment equipment readily available to all personnel. In the event that a spill extends beyond the interior of the service center building, or the spill occurs outside the building, the service center manager shall follow the protocol established in Table 1 Initial surveys have indicated that the following areas would be key set-up locations to contain the spill: 1) If a tank/drum/container releases a regulated substance, the initial objective would be to contain the substance within the building by utilizing absorbent socks to contain material at bay doors. 2) If material does exit the building or the spill occurs outside the building, any storm sewers, storm drains, creeks, or streams should be protected with the use of a readily available spill kit. 3) Bulk oil transfer locations are important containment areas. A spill kit should be readily available for these areas. 4) While working to contain the spill employee should deploy wet and dry vacuum, squeegees, dust pans and absorbent to clean up the release. 5) Oil collected from a spill shall be placed in the used oil tank, absorbents and other spill cleanup materials are to be collected in plastic bags and in the used oil filter bin for fuel recovery. Debris from larger spills will be managed by EHS and the spill contractors. Special/Safety Procedures The safety of Valvoline Instant Oil Change employees and other personnel and the safety of individuals who arrive later on the scene of an oil spill must be considered before any action is taken. Safety should always receive first billing before any decision-making process is undertaken. Personnel responding to a spill should not risk personal injury under any circumstances. Valvoline Instant Oil Change’s Person In Charge must assess the situation and coordinate activities accordingly. Safety Data Sheets for all products are stored at this facility are on file at this location or on the POS system. SDS for non-inventory items are electronically available on the POS system, VPOINT Safety Compliance / General Resources / SDS, or on file at the site. 19 9.0 ALERT PROCEDURE This alert procedure will become effective immediately upon the observance of an oil spill from a company installation of any kind which could possibly pollute a river, the river banks or which could damage fowl or endanger any property or wildlife. I. MANDATORY NOTIFICATION NUMBERS: (1) In the event of an oil spill, the on-scene coordinator in charge of all spills at the facility, after taking steps to stop the source of the spill, must call or delegate someone to immediately call the Valvoline 24 Hour Emergency Command Center: 833-VVV-Report (833-888-7376) The Valvoline Operator will request the information listed on page 18 and then notify the appropriate company personnel. * Emergency Response Coordinators will provide assistance in contacting the following agencies, contractors, and personnel. (2) Valvoline EH&S will notify the National Response Center: National Response Center: 1-800/424-8802 Provide similar information to the operator as required in (1). (3) ENVIRONMENTAL AGENCIES: EPA Regional Office: Region 10 – 206-553-1200 (4) LOCAL EMERGENCY NUMBERS: Fire/Police/Ambulance – 911 II. OTHER EMERGENCY PHONE NUMBERS: (1) Local Spill Control Contractor: Available through 833-VVV-Report (2) Market Manager: Steve Filler sfiller@valvoline.com (3) Area Manager: Austen Holcomb aholcomb@valvoline.com (4) Valvoline EH&S: Jordan Williamson (606) 813-2180 (5) Local Emergency Planning Commission: TBD (6) Municipal Wastewater Treatment Plant TBD 20 10. Valvoline Emergency Operator Spill Information Request INITIAL INFORMATION: - Date - Time reported - Time occurred - Individual reporting - Location and address of spill - Phone - Severity of spill - Employee injuries - Source of incident - Cause of incident - Volume of release - Drains, waterways or soil impacted - Person spill was reported to - Weather conditions 21 Appendix A New Oil Transfer Procedures 22 NEW OIL PRODUCT DELIVERY (UNLOADING) PROCEDURE The procedure below will be followed to prevent an oil spill or discharge during the delivery and unloading of new oil bulk products from a supplier tanker truck to the new oil aboveground storage tanks (ASTs) at VIOC Service Centers: 1) The supplier delivering the new oil products will park the tanker truck in the designated unloading area. During the transfer no one will be allowed in the vehicle, brakes must be set and wheels chocked. 2) The supplier will check in with a VIOC employee to access the oil storage tanks. 3) The supplier will implement their emergency spill response, cleanup, and reporting procedures to control any minor spill that may occur. The VIOC representative will use the spill response equipment (i.e., spill kit; as backup to control any minor spills that may occur during the unloading process). 4) The supplier will check the available capacity in each new oil product AST to determine the approximate volume for filling the ASTs. Where practicable, the supplier will also temporarily cover the floor drains and outside catch basins which could reasonably receive oil in the event of an oil spill during unloading (recognizing absorbent materials are also available if needed). The temporary cover shall consist of a rubber mat or like product that will preclude oil entry into the drains. 5) The VIOC representative will unlock (if necessary) the fill ports on the new oil products ASTs. 6) The supplier will securely attach the hose to the new oil product AST to begin the unloading process. 7) During the unloading process, the supplier and VIOC representative will visually monitor (or use a high liquid level indicator if equipped) the liquid level in the AST and the supplier will shut off flow when the AST is properly filled. 8) After the new oil product unloading process is completed, the supplier will drain the hose into the AST (or if necessary, into a portable container), and remove the temporary drain covers. 9) The fill ports on the new oil product ASTs will be closed and locked (if equipped). 10) The supplier will prepare the tanker truck for departure. The supplier will check for any oil drips or leaks from under the tanker truck. If any oil drips or leaks are observed, the supplier will take corrective actions to stop the drips or leaks. Prior to signing the supplier manifest and allowing the supplier to leave the site, the VIOC representative will inspect the unloading area for any oil drips or spills that occurred during the unloading process. If any drips or spills occurred, the supplier or VIOC representative will clean up the spill and properly dispose of the residue. The supplier will then remove the wheel chocks and leave the facility. 11) The VIOC representative will restock/order any materials used from the spill response equipment (i.e., spill kit). 23 Appendix B Used Oil Transfer Procedures 24 USED OIL PRODUCT PICKUP (LOADING) PROCEDURE – VIOC CENTERS The procedure below will be followed to prevent an oil spill or discharge during the transferring and loading of used oil from the used oil aboveground storage tanks (ASTs) to a collector tanker truck at the VIOC Center: 1) The VIOC representative will transfer the used oil into the used oil AST(s) by pneumatic/electric pumps, gravity flow and/or pouring. The VIOC representative must be careful not to overfill the tank using direct visual gauges or high liquid level alarms (if equipped). The Used Oil Collector will pick up oil on a standard frequency; if the tank exceeds 80% volume the SCM shall contact the collector to arrange a pickup of used oil 2) The collector will park the tanker truck at the designated loading area. During the transfer no one will be allowed in the vehicle, brakes must be set and wheels chocked. 3) The collector will check in with a VIOC representative to gain access to the used oil AST(s). 4) The collector will implement their emergency spill response, cleanup, and reporting procedures to control any minor spill that may occur. The VIOC representative will use the spill response equipment (i.e., spill kit) as backup to control any minor spills that may occur during the loading process. 5) Where practicable, the collector will temporarily cover the floor drains and outside catch basins which could reasonably receive oil in the event of an oil spill during loading (recognizing absorbent materials are also available if needed). The temporary cover shall consist of a rubber mat or like product that will preclude oil entry into the drains. The collector then will securely attach the hose to the used oil AST to begin the loading (vacuum pumping) process. 6) During the loading process, the collector will visually monitor the liquid level in the tanker truck and shut off the flow when the AST is emptied. 7) After the used oil loading process is completed, the collector will drain the hose into the tanker truck (or if necessary, into a portable container). 8) The drain/removal port on the used oil ASTs will be closed. 9) The collector will prepare the tanker truck for departure. The collector will check for any oil drips or leaks from under the tanker truck. If any oil drips or leaks are observed, the collector will take corrective actions to stop the drips or leaks. Prior to signing the collector manifest and allowing the collector to leave the site, A VIOC representative will also inspect the loading area for any oil drips or spills that occurred during the loading process. If any drips or spills occurred, the collector or VIOC representative will clean up the spill and properly dispose of the residue. The collector will then remove the wheel chocks, and leave the facility. 10) A VIOC representative will restock/order any materials used from the spill response equipment (i.e., spill kit). 25 Appendix C “Tank Overflow Prevention Procedures” 26 Tank Overflow Prevention • Be Proactive! • Contact Used Oil Collector If Tank Volume Exceed 80% (MAKE TWO CONTACTS) • Local Driver • Used Oil Collectors Contractor Emergency Response After Hours Number Safety Kleen 800-545-3520 Universal Environmental Services (UES) 800-988-7977 Vertex (Hartland) 800-889-7831 EcoLube 833-326-5823 World Oil Env. Services 800-974-4495 • Utilize Empty Drums to prevent overflows • Record level in used oil tanks daily (Log) • Assign responsibility for checking tanks • Post sign on used oil tank o Level at which to call Used Oil Collector (80% Tank Volume) o Used Oil Collector Phone Numbers o Maximum volume (95% Full) o Notify Area Manger (Log) For This Tank, 80% Full =____________ 27 Appendix D “Spill Kit” • 40 foot of Absorbent Socks • 10 Absorbent Pads • 25-pound bag of Absorbent (Organic) may be replaced with the approved dry floor cleaner if necessary • 3 Disposable bags Note: Bulk Used Oil collection vehicles are equipped with storm drain blocker mats. 28 Appendix E Tank Inspection Check List 29 Weekly SPCC Tank \ Drum Inspection Service Center: Month/Year: Week One (Monday) Good NG Tank No. Corrective Action Pipe or Tank Leaks(1)(2) Containment Area - No Standing Oil? Containment Structure (3)? Gauges \ High Level Alarms Work? Drums/Transformers free of leaks? Comments Corrective Actions: Week Two (Monday) Good NG Tank No. Corrective Action Pipe or Tank Leaks(1)(2) Containment Area - No Standing Oil? Containment Structure (3)? Gauges \ High Level Alarms Work? Drums/Transformers free of leaks? Comments Corrective Actions: Week Three (Monday) Good NG Tank No. Corrective Action Pipe or Tank Leaks(1)(2) Containment Area - No Standing Oil? Containment Structure (3)? Gauges \ High Level Alarms Work? Drums/Transformers free of leaks? Comments Corrective Actions: Week Four (Monday) Good NG Tank No. Corrective Action Pipe or Tank Leaks(1)(2) Containment Area - No Standing Oil? Containment Structure (3)? Gauges \ High Level Alarms Work? Drums/Transformers free of leaks? Comments Corrective Actions: Week Five (Monday) Yes No Tank No. Corrective Action Pipe or Tank Leaks(1)(2) Containment Area - No Standing Oil? Containment Structure (3)? Gauges \ High Level Alarms Work? Drums/Transformers free of leaks? Comments Corrective Actions: (1) Double wall tank remove the cap on the secondary containment (outer shell) and drop a pole with a paper towel wrapped around the end into the secondary containment until it hits the bottom and then retrieve. Does the paper towel indicate that the secondary containment is free of oil and water? (2) Are all Aboveground Storage Tank (ASTs) systems (tank shell, valves, or piping (including fill and drain pipe, and overhead piping)) free of leaks, corrosion, pitting, cracks, dry rot, spills and/or signs of deterioration? (3) Are containment wall and floors free of loose bricks or blocks, cracks, holes in the wall, seam cracks, and seams between floor and wall? 30 Appendix F “Abandoned Waste Procedures” DO NOT ADD ABANDONED WASTE TO USED OIL TANK • Visually inspect abandoned waste • Observe container type and labels • Layering (multiple products) • Color (Type of container, waste paint, solvents, acids, caustic) \ • Thickness (Don’t place solids in the used oil tank) • Odor Observation; • Indirectly observe odor at arm’s length only when emptying container • Pungent, burning, or unusual odor - seal the container and contact Emergency Command Center and Area Manager. • Call 833-VVV-Report to log all abandoned waste • If not used oil request EHS Support • If abandoned waste appears to be oil pour into abandoned waste oil keg.