Number range CHAPTER**[Disclaimer - Appendix D]{.smallcaps}**

The sample Spill Prevention, Control and Countermeasure (SPCC) Plan in
Appendix D is intended to provide examples and illustrations of how a
bulk storage facility could address a variety of scenarios in its SPCC
Plan. The "facility" is not an actual facility, nor does it represent
any actual facility or company. Rather, EPA is providing illustrative
examples of the type and amount of information that is appropriate SPCC
Plan language for these hypothetical situations.

Because the SPCC rule is designed to give each facility owner/operator
the flexibility to tailor the facility's SPCC Plan to the facility's
circumstances, this sample SPCC Plan is not a template to be adopted by
a facility; doing so does not mean that the facility will be in
compliance with the SPCC rule requirements. Nor is the sample plan a
template that must be followed in order for the facility to be
considered in compliance with the SPCC rule.

![](media/image1.wmf)

[Spill Prevention, Control, and Countermeasure Plan]{.smallcaps}

*Unified Oil Company*

123 A Street

Stonefield, Massachusetts 02000

May 12, 2003

Prepared by

Poppins & Associates, Inc.

Clearwater Falls, Massachusetts, 02210

**TABLE OF CONTENTS**

  ---------------------------------------------------------------- ------
                                                                   Page

  **Introduction**                                                 1

  **Part 1: Plan Administration**                                  

  1.1 Management Approval and Designated Person                    3

  1.2 Professional Engineer Certification                          3

  1.3 Location of SPCC Plan                                        4

  1.4 Plan Review                                                  4

  1.5 Facilities, Procedures, Methods, or Equipment Not Yet Fully  5
  Operational                                                      

  1.6 Cross-Reference with SPCC Provisions                         5

  **Part 2: General Facility Information**                         

  2.1 Facility Description                                         8

  2.2 Evaluation of Discharge Potential                            11

  **Part 3: Discharge Prevention -- General SPCC Provisions**      

  3.1 Compliance with Applicable Requirements                      12

  3.2 Facility Layout Diagram                                      12

  3.3 Spill Reporting                                              12

  3.4 Potential Discharge Volumes and Direction of Flow            13

  3.5 Containment and Diversionary Structures                      14

  3.6 Practicability of Secondary Containment                      16

  3.7 Inspections, Tests, and Records                              16

  3.8 Personnel, Training, and Discharge Prevention Procedures     18

  3.9 Security                                                     19

  3.10 Tank Truck Loading/Unloading Rack Requirements              19

  3.11 Brittle Fracture Evaluation                                 22

  3.12 Conformance with State and Local Applicable Requirements    22

  **Part 4: Discharge Prevention -- SPCC Provisions for Onshore    
  Facilities (Excluding Production Facilities)**                   

  4.1 Facility Drainage                                            23

  4.2 Bulk Storage Containers                                      23

  4.3 Transfer Operations, Pumping, and In-Plant Processes         29

  **Part 5: Discharge Response**                                   

  5.1 Response to a Minor Discharge                                30

  5.2 Response to a Major Discharge                                31

  5.3 Waste Disposal                                               32

  5.4 Discharge Notification                                       32

  5.5 Cleanup Contractors and Equipment Suppliers                  33

                                                                   

  **List of Tables**                                               

  Table 1-1: Plan Review Log                                       6

  Table 1-2: SPCC Cross-Reference                                  7

  Table 2-1: Oil Containers                                        9

  Table 2-2: Oil Discharge History                                 10

  Table 3-1: Potential Discharge Volume and Direction of Flow      13

  Table 3-2: Inspection and Testing Program                        16

  Table 3-3: Fuel Transfer Procedures                              21

  Table 4-1: List of Oil Containers                                24

  Table 4-2: Scope and Frequency of Bulk Storage Containers        27
  Inspections and Tests                                            

                                                                   

  **Appendices**                                                   

  A: Site Plan and Facility Diagram                                

  B: Substantial Harm Determination                                

  C: Facility Inspection Checklists                                

  D: Record of Containment Dike Drainage                           

  E: Record of Discharge Prevention Briefings and Training         

  F: Calculation of Secondary Containment Capacity                 

  G: Records of Tank Integrity and Pressure Tests                  

  H: Emergency Contacts                                            

  I: Discharge Notification Form                                   

  J: Discharge Response Equipment Inventory                        

  K: Agency Notification Standard Report                           
  ---------------------------------------------------------------- ------

**LIST OF ACRONYMS AND ABBREVIATIONS**

AST Aboveground Storage Tank

EPA U.S. Environmental Protection Agency

MADEP Massachusetts Department of Environmental Protection

NPDES National Pollutant Discharge Elimination System

PE Professional Engineer

POTW Publicly Owned Treatment Works

SPCC Spill Prevention, Control, and Countermeasure

STI Steel Tank Institute

UST Underground Storage Tank

**INTRODUCTION**

**Purpose**

The purpose of this Spill Prevention, Control, and Countermeasure (SPCC)
Plan is to describe measures implemented by Unified Oil to prevent oil
discharges from occurring, and to prepare Unified Oil to respond in a
safe, effective, and timely manner to mitigate the impacts of a
discharge.

This Plan has been prepared to meet the requirements of Title 40, *Code
of Federal Regulations,* Part 112 (40 CFR part 112), and supercedes the
earlier Plan developed to meet provisions in effect since 1974.

In addition to fulfilling requirements of 40 CFR part 112, this SPCC
Plan is used as a reference for oil storage information and testing
records, as a tool to communicate practices on preventing and responding
to discharges with employees, as a guide to facility inspections, and as
a resource during emergency response.

Unified Oil management has determined that this facility does not pose a
risk of substantial harm under 40 CFR part 112, as recorded in the
"Substantial Harm Determination" included in Appendix B of this Plan.

This Plan provides guidance on key actions that Unified Oil must perform
to comply with the SPCC rule:

-   Complete monthly and annual site inspections as outlined in the
    Inspection, Tests, and Records section of this Plan (Section 3.7)
    using the inspection checklists included in Appendix C.

-   Perform preventive maintenance of equipment, secondary containment
    systems, and discharge prevention systems described in this Plan as
    needed to keep them in proper operating conditions.

-   Conduct annual employee training as outlined in the Personnel,
    Training, and Spill Prevention Procedures section of this Plan
    (Section 3.8) and document them on the log included in Appendix E.

-   If either of the following occurs, submit the SPCC Plan to the EPA
    Region 1 Regional Administrator (RA) and the Massachusetts
    Department of Environmental Protection (MADEP), along with other
    information as detailed in Section 5.4 of this Plan:

-   The facility discharges more than 1,000 gallons of oil into or upon
    the navigable waters of the U.S. or adjoining shorelines in a single
    spill event; or

-   The facility discharges oil in quantity greater than 42 gallons in
    each of two spill events within any 12-month period.

-   Review the SPCC Plan at least once every five (5) years and amend it
    to include more effective prevention and control technology, if such
    technology will significantly reduce the likelihood of a spill event
    and has been proven effective in the field at the time of the
    review. Plan amendments, other than administrative changes discussed
    above, must be recertified by a Professional Engineer on the
    certification page in Section 1.2 of this Plan.

-   Amend the SPCC Plan within six (6) months whenever where is a change
    in facility design, construction, operation, or maintenance that
    materially affects the facility's spill potential. The revised Plan
    must be recertified by a Professional Engineer (PE).

-   Review the Plan on an annual basis. Update the Plan to reflect any
    "administrative changes" that are applicable, such as personnel
    changes or revisions to contact information, such as phone numbers.
    Administrative changes must be documented in the Plan review log of
    Section 1.4 of this Plan, but do not have to be certified by a PE.

    **Part 1: Plan Administration**

    **1.1 Management Approval and Designated Person (40 CFR 112.7)**

    Unified Oil Company ("Unified Oil') is committed to preventing
    discharges of oil to navigable waters and the environment, and to
    maintaining the highest standards for spill prevention control and
    countermeasures through the implementation and regular review and
    amendment to the Plan. This SPCC Plan has the full approval of
    Unified Oil management. Unified Oil has committed the necessary
    resources to implement the measures described in this Plan.

    The Facility Manager is the Designated Person Accountable for Oil
    Spill Prevention at the facility and has the authority to commit the
    necessary resources to implement this Plan.

    Authorized Facility Representative (facility response coordinator):
    Susan Blake

    Signature: Susan Blake

    Title: Facility Manager

    Date: May 12, 2003

    **1.2 Professional Engineer Certification (40 CFR 112.3(d))**

    The undersigned Registered Professional Engineer is familiar with
    the requirements of Part 112 of Title 40 of the *Code of Federal
    Regulations* (40 CFR part 112) and has visited and examined the
    facility, or has supervised examination of the facility by
    appropriately qualified personnel. The undersigned Registered
    Professional Engineer attests that this Spill Prevention, Control,
    and Countermeasure Plan has been prepared in accordance with good
    engineering practice, including consideration of applicable industry
    standards and the requirements of 40 CFR part 112; that procedures
    for required inspections and testing have been established; and that
    this Plan is adequate for the facility. \[40 CFR 112.3(d)\]

    This certification in no way relieves the owner or operator of the
    facility of his/her duty to prepare and fully implement this SPCC
    Plan in accordance with the requirements of 40 CFR part 112. This
    Plan is valid only to the extent that the facility owner or operator
    maintains, tests, and inspects equipment, containment, and other
    devices as prescribed in this Plan.

    Julie Andrews 90535055, Massachusetts

    Signature Professional Engineer Registration Number

    ![](media/image2.wmf){width="1.3604166666666666in"
    height="1.3604166666666666in"}

    *Julie Andrews Sr. Process Engineer*

    Name Title

    *Poppins and Associates May 12, 2003*

    Company Date

    **1.3 Location of SPCC Plan (40 CFR 112.3(e))**

    In accordance with 40 CFR 112.3(e), a complete copy of this SPCC
    Plan is maintained at the facility in the office building. The front
    office is attended whenever the facility is operating, i.e., 7:00 AM
    to 5:00 PM, 6 days per week (closed on Sundays).

    **1.4 Plan Review (40 CFR 112.3 and 112.5)**

    **1.4.1 Changes in Facility Configuration**

    In accordance with 40 CFR 112.5(a), Unified Oil periodically reviews
    and evaluates this SPCC Plan for any change in the facility design,
    construction, operation, or maintenance that materially affects the
    facility's potential for an oil discharge, including, but not
    limited to:

```{=html}
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```
-   commissioning of containers;

-   reconstruction, replacement, or installation of piping systems;

-   construction or demolition that might alter secondary containment
    structures; or

-   changes of product or service, revisions to standard operation,
    modification of testing/inspection procedures, and use of new or
    modified industry standards or maintenance procedures.

    Amendments to the Plan made to address changes of this nature are
    referred to as technical amendments, and must be certified by a PE.
    Non-technical amendments can be done (and must be documented in this
    section) by the facility owner and/or operator. Non-technical
    amendments include the following:

-   change in the name or contact information (i.e., telephone numbers)
    of individuals responsible for the implementation of this Plan; or

-   change in the name or contact information of spill response or
    cleanup contractors.

    Unified Oil must make the needed revisions to the SPCC Plan as soon
    as possible, but no later than six months after the change occurs.
    The Plan must be implemented as soon as possible following any
    technical amendment, but *no later than six months* from the date of
    the amendment. The Facility Manager is responsible for initiating
    and coordinating revisions to the SPCC Plan.

    **1.4.2 Scheduled Plan Reviews**

    In accordance with 40 CFR 112.5(b), Unified Oil reviews this SPCC
    Plan at least once every five years (in the past, such reviews were
    required every three years). Revisions to the Plan, if needed, are
    made within six months of the five-year review. A registered
    Professional Engineer certifies any technical amendment to the Plan,
    as described above, in accordance with 40 CFR 112.3(d). The last
    SPCC review occurred on *May 13, 2001*. This Plan is dated *May 12,
    2003*. The next plan review is therefore scheduled to take place on
    or prior to *May 12, 2008*.

    **1.4.3 Record of Plan Reviews**

    Scheduled reviews and Plan amendments are recorded in the Plan
    Review Log (Table 1-1). This log must be completed even if no
    amendment is made to the Plan as a result of the review. Unless a
    technical or administrative change prompts an earlier review of the
    Plan, the next scheduled review of this Plan must occur by *May 12,
    2008.*

    **1.5 Facilities, Procedures, Methods, or Equipment Not Yet Fully
    Operational (40 CFR 112.7)**

    Bulk storage containers at this facility have never been tested for
    integrity since their installation in 1989. Section 4.2.6 of this
    Plan describes the inspection program to be implemented by the
    facility following a regular schedule, including the dates by which
    each of the bulk storage containers must be tested.

    **1.6 Cross-Reference with SPCC Provisions (40 CFR 112.7)**

    This SPCC Plan does not follow the exact order presented in 40 CFR
    part 112. Section headings identify, where appropriate, the relevant
    section(s) of the SPCC rule. Table 1-2 presents a cross-reference of
    Plan sections relative to applicable parts of 40 CFR part 112.

    **Table 1-1: Plan Review Log**

+----------+--------+-----------+----------+--------------------------+
| **By**   | **     | **A       | **PE     | **Comments**             |
|          | Date** | ctivity** | certi    |                          |
|          |        |           | fication |                          |
|          |        |           | req      |                          |
|          |        |           | uired?** |                          |
+----------+--------+-----------+----------+--------------------------+
| Mike     | 5/2    | Prepare   | Yes      | Initial SPCC Plan.       |
| Davies   | 0/1989 | Plan      |          |                          |
|          |        |           |          |                          |
|          |        | Start of  |          |                          |
|          |        | O         |          |                          |
|          |        | perations |          |                          |
+----------+--------+-----------+----------+--------------------------+
| Mike     | 5/1    | Scheduled | No       | No change.               |
| Davies   | 8/1992 | review    |          |                          |
+----------+--------+-----------+----------+--------------------------+
| Mike     | 2/1    | Plan      | Yes\*    | Changes to inspection    |
| Davies   | 8/1994 | amendment |          | procedures, addition of  |
|          |        |           |          | a new tank, full review  |
|          |        |           |          | not conducted.           |
+----------+--------+-----------+----------+--------------------------+
| Susan    | 5/1    | Scheduled | No       | Change in responsible    |
| Blake    | 5/1995 | review    |          | individual and contact   |
|          |        |           |          | information.             |
+----------+--------+-----------+----------+--------------------------+
| Susan    | 5/1    | Scheduled | No       | No change.               |
| Blake    | 5/1998 | review    |          |                          |
+----------+--------+-----------+----------+--------------------------+
| Susan    | 5/1    | Scheduled | No       | No change.               |
| Blake    | 3/2001 | review    |          |                          |
+----------+--------+-----------+----------+--------------------------+
| Susan    | 5/1    | Periodic  | Yes\*    | Installation of          |
| Blake    | 2/2003 | review    |          | oil/water separator      |
|          |        | due to    |          |                          |
|          |        | physical  |          |                          |
|          |        | change    |          |                          |
+----------+--------+-----------+----------+--------------------------+
|          |        |           |          |                          |
+----------+--------+-----------+----------+--------------------------+
|          |        |           |          |                          |
+----------+--------+-----------+----------+--------------------------+
|          |        |           |          |                          |
+----------+--------+-----------+----------+--------------------------+
|          |        |           |          |                          |
+----------+--------+-----------+----------+--------------------------+
|          |        |           |          |                          |
+----------+--------+-----------+----------+--------------------------+

\* Previous PE certifications of this Plan are summarized below.

  ----------- --------------------------- ---------------- -----------------
  **Date**    **Scope**                   **PE Name**      **Licensing State
                                                           and Registration
                                                           No.**

  2/18/1994   Addition of new tank and    Chris Ebert      MA, 90117823
              changes in inspection                        
              procedures.                                  

  5/12/2003   Installation of oil/water   Julie Andrews    MA, 905350055
              separator                                    
  ----------- --------------------------- ---------------- -----------------

# Table 1-2: SPCC Cross-Reference

+------------+---------------------------------------------+-----------+
| **P        | **Plan Section**                            | **Page**  |
| rovision** |                                             |           |
+============+=============================================+===========+
| 112.3(d)   | Professional Engineer Certification         | 3         |
+------------+---------------------------------------------+-----------+
| 112.3(e)   | Location of SPCC Plan                       | 4         |
+------------+---------------------------------------------+-----------+
| 112.5      | Plan Review                                 | 4         |
|            |                                             |           |
|            |                                             | Table 1-1 |
+------------+---------------------------------------------+-----------+
| 112.7      | Management Approval                         | 3         |
+------------+---------------------------------------------+-----------+
| 112.7      | Cross-Reference with SPCC Rule              | Table 1-2 |
+------------+---------------------------------------------+-----------+
| 1          | Part 2: General Facility Information        | 8         |
| 12.7(a)(3) |                                             |           |
|            | Appendix A: Site Plan and Facility Diagram  | Appendix  |
|            |                                             | A         |
+------------+---------------------------------------------+-----------+
| 1          | 5.4 Discharge Notification                  | 32        |
| 12.7(a)(4) |                                             |           |
|            |                                             | Appendix  |
|            |                                             | I         |
|            |                                             |           |
|            |                                             | Appendix  |
|            |                                             | K         |
+------------+---------------------------------------------+-----------+
| 1          | Part 5: Discharge Response                  | 32        |
| 12.7(a)(5) |                                             |           |
+------------+---------------------------------------------+-----------+
| 112.7(b)   | 3.4 Potential Discharge Volumes and         | 13        |
|            | Direction of Flow                           |           |
+------------+---------------------------------------------+-----------+
| 112.7(c)   | 3.5 Containment and Diversionary Structures | 14        |
+------------+---------------------------------------------+-----------+
| 112.7(d)   | 3.6 Practicability of Secondary Containment | 16        |
+------------+---------------------------------------------+-----------+
| 112.7(e)   | 3.7 Inspections, Tests, and Records         | 16        |
|            |                                             |           |
|            |                                             | Appendix  |
|            |                                             | B         |
+------------+---------------------------------------------+-----------+
| 112.7(f)   | 3.8 Personnel, Training and Discharge       | 18        |
|            | Prevention Procedures                       |           |
+------------+---------------------------------------------+-----------+
| 112.7(g)   | 3.9 Security                                | 19        |
+------------+---------------------------------------------+-----------+
| 112.7(h)   | 3.10 Tank Truck Loading/Unloading           | 19        |
+------------+---------------------------------------------+-----------+
| 112.7(i)   | 3.11 Brittle Fracture Evaluation            | 22        |
+------------+---------------------------------------------+-----------+
| 112.7(j)   | 3.12 Conformance with Applicable State and  | 22        |
|            | Local Requirements                          |           |
+------------+---------------------------------------------+-----------+
| 112.8(b)   | 4.1 Facility Drainage                       | 23        |
+------------+---------------------------------------------+-----------+
| 1          | 4.2.1 Construction                          | 23        |
| 12.8(c)(1) |                                             |           |
+------------+---------------------------------------------+-----------+
| 1          | 4.2.2 Secondary Containment                 | 25        |
| 12.8(c)(2) |                                             |           |
+------------+---------------------------------------------+-----------+
| 1          | 4.2.3 Drainage of Diked Areas               | 26        |
| 12.8(c)(3) |                                             |           |
|            |                                             | Appendix  |
|            |                                             | D         |
+------------+---------------------------------------------+-----------+
| 1          | 4.2.4 Corrosion Protection                  | 26        |
| 12.8(c)(4) |                                             |           |
+------------+---------------------------------------------+-----------+
| 1          | 4.2.5 Partially Buried and Bunkered Storage | 26        |
| 12.8(c)(5) | Tanks                                       |           |
+------------+---------------------------------------------+-----------+
| 1          | 4.2.6 Inspection                            | 26        |
| 12.8(c)(6) |                                             |           |
|            | Appendix B - Facility Inspection Checklists | Appendix  |
|            |                                             | C         |
+------------+---------------------------------------------+-----------+
| 1          | 4.2.7 Heating Coils                         | 27        |
| 12.8(c)(7) |                                             |           |
+------------+---------------------------------------------+-----------+
| 1          | 4.2.8 Overfill Prevention System            | 27        |
| 12.8(c)(8) |                                             |           |
+------------+---------------------------------------------+-----------+
| 1          | 4.2.9 Effluent Treatment Facilities         | 28        |
| 12.8(c)(9) |                                             |           |
+------------+---------------------------------------------+-----------+
| 11         | 4.2.10 Visible Discharges                   | 28        |
| 2.8(c)(10) |                                             |           |
+------------+---------------------------------------------+-----------+
| 11         | 4.2.11 Mobile and Portable Containers       | 28        |
| 2.8(c)(11) |                                             |           |
+------------+---------------------------------------------+-----------+
| 112.8(d)   | 4.3 Transfer Operations, Pumping and        | 29        |
|            | In-Plant Processes                          |           |
+------------+---------------------------------------------+-----------+
| 112.20(e)  | Certification of Substantial Harm           | Appendix  |
|            | Determination                               | B         |
+------------+---------------------------------------------+-----------+

\* Only selected excerpts of relevant rule text are provided. For a
complete list of SPCC requirements, refer to the full text of 40 CFR
part 112.

**Part 2: General Facility Information**

Name: Unified Oil Company

Address: 123 A Street

Stonefield, MA 02000

\(781\) 555-5556

Type: Bulk storage distribution facility

Date of Initial Operations: May 20, 1989

Owner/Operator: Blake and Daughters, Inc.

20 Fairview Road

Stonefield, MA 02000

Primary contact: Susan Blake, Facility Manager

Work: (781) 555-5550

Cell (24 hours): (781) 555-5559

**2.1 Facility Description (40 CFR 112.7(a)(3))**

**2.1.1 Location and Activities**

Unified Oil distributes a variety of petroleum products to primarily
commercial customers. The facility handles, stores, uses, and
distributes petroleum products in the form of gasoline, diesel, No. 2
fuel oil, No. 6 fuel oil, and motor oil. Unified Oil receives products
by common carrier via tanker truck. The products are stored in several
aboveground storage tanks (ASTs) and in one underground storage tank
(UST). They are delivered to customers by Unified Oil trucks or by
independent contractors. The facility refuels its own two delivery
trucks from an underground diesel tank connected to a fueling pump.

Hours of operation are between 7:00 AM and 5:00 PM, 6 days per week.
Personnel at the facility include a facility manager, a plant operator,
two truck drivers, an office administrator, and three operations and
maintenance personnel.

The Site Plan and Facility Diagram included in Appendix A of this Plan
show the location and layout of the facility. The Facility Diagram
(Figure A-2) shows the location of oil containers, buildings,
loading/unloading and transfer areas, and critical spill control
structures.

Unified Oil is located in a primarily commercial area at 123 A Street in
Stonefield, Massachusetts. The site is comprised of approximately 2
acres of land and is bordered to the east by A Street, to the west by
Silver Creek, and to the north by ABC Plating Co.

The site includes an office building, a maintenance shop, a tanker truck
loading rack and unloading area, and product storage and handling areas.
Petroleum products are stored within the main bulk storage area,
underground, and inside the maintenance building.

**2.1.2 Oil Storage**

Oil storage at the facility consists of seven tanks: four fixed ASTs,
one portable tank, and two metallic USTs. In addition, the facility
stores a varying stock of oil drums inside the maintenance building.

The capacities of oil containers present at the site are listed below
and are also indicated on the facility diagram in Figure A-2. All
containers with capacity of 55 gallons or more are included. The
capacity of the oil/water separator is not included in the total storage
capacity for the facility since it is used to treat storm water and as a
means of secondary containment for areas of the facility with potential
for an oil discharge outside dikes or berms.

Unified Oil owns two 2,000-gallon transport trucks that are used to
deliver product to customers. One of the two trucks is periodically
parked overnight while full; the capacity of this truck is therefore
counted in the total storage capacity for this facility.

**Table 2-1: Oil Containers**

  -------------- -------------- --------------------- -------------------------------
  **ID**         **Storage      **Content**           **Description**
                 capacity**                           

  **Fixed                                             
  Storage**                                           

  1              20,000 gallons Diesel                Aboveground vertical tank

  2              20,000 gallons Unleaded regular      Aboveground horizontal tank
                                gasoline              elevated on built-in saddles

  3              20,000 gallons Unleaded premium      Aboveground horizontal tank
                                gasoline              elevated on built-in saddles

  6              1,000 gallons  No. 2 fuel oil        Underground horizontal tank

  7              10,000 gallons No. 6 fuel oil        Field-constructed aboveground
                                                      vertical tank

                 1,100 gallons  Motor oil             55-gallon storage drums
                                                      (variable stock; up to 20 drums
                                                      on site at any time)

  **Portable                                          
  storage**                                           

  4              500 gallons    Gasoline              Double-walled aboveground
                                                      horizontal tank

  **Vehicles**                                        

                 2,000 gallons  Fuel oil              Delivery truck\*
  -------------- -------------- --------------------- -------------------------------

\* ***Note:** Unified Oil owns two delivery trucks. Both trucks are used
in transportation-related activities outside the confines of the
facility and generally return to the facility empty for parking
overnight. One of the two delivery trucks is periodically parked while
full. This truck is therefore counted in the storage capacity for this
facility. The other truck is dedicated to scheduled deliveries and
returns to the facility empty (except for minor residual). If the tanker
truck returns to the facility with more than residual product, this
product will be returned to inventory via the unloading station. If the
facility decides to use this tanker for overnight storage, then this
Plan must be modified to include the capacity of the truck and ensure
compliance with other rule requirements, including secondary
containment.*

**Total Oil Storage: 74,600 gallons**

Other containers: (1) 1,500-gallon oil/water separator

*Note: The oil/water separator is used treat facility drainage (i.e.,
wastewater) prior to discharge into Silver Creek under state and federal
wastewater discharge permits. Discharge from the facility includes storm
water collected from the paved areas outside the loading rack/unloading
area containment berm and bulk storage containment dike. No external oil
tanks are associated with the oil/water separator. This equipment is
used to meet certain secondary containment requirements under 40 CFR
part 112, as described later in this Plan. Thus, the capacity of the
oil/water separator is not counted towards the facility total storage
capacity.*

\(1\) 5,000-gallon underground horizontal tank (Diesel) -- Tank #5

*Note: This underground storage tank is subject to, and meets, all the
technical requirements of Massachusetts Underground Storage Tank Program
at 527 CMR 9, as approved under 40 CFR part 281, and is therefore not
counted in the storage capacity for this facility (exempted under 40 CFR
112.1(d)(4). Its location is indicated on the Facility Diagram in
Appendix A. Note that the other underground storage tank (Tank #6) which
contains No. 2 fuel oil for heating consumption on the premises of the
facility is not subject to certain technical requirements under 40 CFR
part 280 or a program approved under part 281, in particular corrosion
protection, and is therefore included in the storage capacity for this
facility (and is SPCC-regulated), as described above.*

**2.2 Evaluation of Discharge Potential**

**2.2.1 Distance to Navigable Waters and Adjoining Shorelines and Flow
Paths**

The facility is located on relatively level terrain. Drainage generally
flows in the direction of Silver Creek, which runs immediately along the
southwest side of the site. Silver Creek flows north to the Blackpool
River approximately 1.5 miles from the facility. Spill trajectories are
indicated on the facility diagram. Storm drains are located along A
Street at the northeast end of the site. They discharge to Silver Creek.

Approximately three-quarters of the facility's ground surface area is
paved with asphalt. The remainder consists of compacted gravel, grass,
and low-lying vegetation.

**2.2.2 Discharge History**

Table 2-1 summarizes the facility's discharge history.

**Table 2-2: Oil Discharge History**

  ----------------------- ----------------------- -----------------------
  **Description of        **Corrective Actions    **Plan for Preventing
  Discharge**             Taken**                 Recurrence**

  On 3/23/2003, a leaking A boom was placed into  An oil/water separator
  valve on a delivery     Silver Creek            was installed and the
  truck discharged 50     immediately upon        facility drainage was
  gallons of diesel oil   discovery.              designed to flow into
  onto the ground during  Approximately 35        the separator.
  a rain event, allowing  gallons of oil were     
  approximately 10        recovered from Silver   
  gallons to enter Silver creek and the facility  
  Creek.                  ground.                 
  ----------------------- ----------------------- -----------------------

**PART 3: Discharge Prevention - General SPCC Provisions**

The following measures are implemented to prevent oil discharges during
the handling, use, or transfer of oil products at the facility.
Oil-handling employees have received training in the proper
implementation of these measures.

**3.1 Compliance with Applicable Requirements (40 CFR 112.7(a)(2))**

This facility uses an oil/water separator as part of its drainage system
to contain oil discharged in certain areas of the facility (i.e.,
overfills, and the loading/unloading area associated with Tank #4).
Because Tank #4 does not meet the specifications provided in EPA's
memorandum concerning its policy on double-walled tanks, general
containment must be provided to address overfills. The separator
provides environmental protection equivalent to the requirements under
112.8(b)(3) to use ponds, lagoons, or catchment basins to retain oil at
the facility in the event of an uncontrolled discharge. As described in
Section 3.5 of this Plan, the operational and emergency oil storage
capacity of the oil/water separator is sufficient to handle the quantity
of oil expected to be discharged in undiked areas from tank overfills or
transfer operations.

Non-destructive integrity evaluation is not performed on Tank #4
(500-gallon portable storage tank) or the 55-gallon storage drums. Tank
#4 has a double-wall construction and is elevated off the ground. The
tank is inspected regularly and following a regular schedule in
accordance with the Steel Tank Institute (STI) SP-001 tank inspection
standard as described in this Plan. Any leakage from the primary
container would be detected through monitoring of the interstitial space
performed on a monthly basis. Any leakage from the secondary shell would
be detected visually during scheduled visual inspections by facility
personnel. Storage drums are elevated on spill pallets and have all
sides visible, and any leak would be readily detected by facility
personnel before they can cause a discharge to navigable waters or
adjoining shorelines. Corrosion poses minimal risk of failure since
drums are single-use and remain on site for a relatively short period of
time (less than one year). The drum storage area is inspected monthly.
This is in accordance with accepted industry practice for drum storage
and provides an effective means of verifying container integrity, as
noted by EPA in the preamble to the SPCC rule at 67 FR 47120.

**3.2 Facility Layout Diagram (40 CFR 112.7(a)(3))**

Figure A-1 in Appendix A shows the general location of the facility on a
U.S. Geological Survey topographic map. Figure A-2 in Appendix A
presents a layout of the facility and the location of storage tanks and
drums. The diagram also shows the location of storm water drain inlets
and the direction of surface water runoff. As required under 40 CFR
112.7(a)(3), the facility diagram indicates the location and content of
ASTs, USTs, and transfer stations and connecting piping.

**3.3 Spill Reporting (40 CFR 112.7(a)(4))**

The discharge notification form included in Appendix I will be completed
upon immediate detection of a discharge and prior to reporting a spill
to the proper notification contacts.

**3.4 Potential Discharge Volumes and Direction of Flow (40 CFR
112.7(b))**

Table 3-1 presents expected volume, discharge rate, general direction of
flow in the event of equipment failure, and means of secondary
containment for different parts of the facility where oil is stored,
used, or handled.

**Table 3-1: Potential Discharge Volumes and Direction of Flow**

  -----------------------------------------------------------------------------------
  **Potential Event**     **Maximum     **Maximum       **Direction   **Secondary
                          volume        discharge       of Flow**     Containment**
                          released      rate**                        
                          (gallons)**                                 
  ----------------------- ------------- --------------- ------------- ---------------
  **Bulk Storage Area**                                               
  (Aboveground Storage                                                
  Tanks #1, 2, 3, or 7)                                               

  Failure of aboveground  20,000        Gradual to      SW to Silver  Concrete dike
  tank (collapse or                     instantaneous   Creek         
  puncture below product                                              
  level)                                                              

  Tank overfill           1 to 120      60 gal/min      SW to Silver  Concrete dike
                                                        Creek         

  Pipe failure            20,000        240 gal/min     SW to Silver  Concrete dike
                                                        Creek         

  Leaking pipe or valve   600           1 gal/min       SW to Silver  Concrete dike
  packing                                               Creek         

  Leaking heating coil    10,000        1 gal/min       SW to Silver  Concrete dike
  (Tank #7)                                             Creek         

  **Loading                                                           
  Rack/Unloading Area**                                               

  Tank truck leak or      1 to 2,000    Gradual to      SW to Silver  Rollover berm,
  failure inside the                    instantaneous   Creek         on to oil/water
  rollover berm                                                       separator

  Tank truck leak or      1 to 2,000    Gradual to      SW to Silver  Rollover berm,
  failure outside the                   instantaneous   Creek         on to oil/water
  rollover berm                                                       separator

  Hose leak during truck  1 to 300      60 gal/min      SW to Silver  Rollover berm
  loading                                               Creek         

  **Fuel Dispensing                                                   
  Areas**                                                             

  Tank #4 and diesel      1 to 150      30 gal/minute   SW to Silver  Land-based
  dispenser hose/                                       Creek.        spill response
  connections leak                                                    capability
                                                                      (spill kit) and
                                                                      oil/water
                                                                      separator

  **Maintenance                                                       
  Building**                                                          

  Leak or failure of drum 1 to 55       Gradual to      SW to Silver  Spill pallets,
                                        instantaneous   Creek.        oil/water
                                                                      separator

  **Other Areas**                                                     

  Complete failure of     500           Gradual to      SW to Silver  Secondary
  portable tank (Tank #4)               instantaneous   Creek.        shell,
                                                                      oil/water
                                                                      separator

  Leaking portable tank   1 to 100      3 gal/min       SW to Silver  Secondary
  or overfills (Tank #4)                                Creek.        shell,
                                                                      oil/water
                                                                      separator

  Leak during transfer to 1 to 120      60 gal/min      SW to Silver  Oil/water
  heating fuel UST (Tank                                Creek.        separator
  \# 6)                                                               

  Oil/water separator     1 to 300      1 gal/min       SW to Silver  
  malfunction                                           Creek.        
  -----------------------------------------------------------------------------------

**3.5 Containment and Diversionary Structures (40 CFR 112.7(c))**

Methods of secondary containment at this facility include a combination
of structures (e.g., dike, berm, built-in secondary containment),
drainage systems (e.g., oil/water separator), and land-based spill
response (e.g., drain covers, sorbents) to prevent oil from reaching
navigable waters and adjoining shorelines:

-   For bulk storage containers (refer to Section 4.2.2 of this Plan):

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-   **Dike.** A concrete dike enclosure is provided around fixed
    aboveground storage tanks, as described in Section 4.2.2 of this
    Plan.

-   **Double-wall tank construction.** Tank #6 (UST), and the 500-gallon
    portable storage tank (Tank #4) both have double-wall design with a
    secondary shell designed to contain 110 percent of the inner shell
    capacity. The portable tank is generally located near the entrance
    to the maintenance building; however, it may be used elsewhere on
    site. It is used to refuel various small pieces of equipment (each
    less than 55-gallon capacity) such as trucks and compressors, that
    may be deployed at different areas on the site.

-   **Spill pallets.** Each spill pallet has a capacity of 75 gallons,
    which can effectively contain the volume of any single 55-gallon
    drum. Drums are also stored inside the maintenance building and are
    not exposed to precipitation. The floor of the maintenance building
    and lower 24 inches of the outside walls are constructed of poured
    concrete that would restrict the flow of oil outside the building.
    The floor has two floor drains; the drain closest to the drum
    storage area is located 18 feet away. Floor drains flow into the
    oil/water separator, which is capable of containing any oil
    discharged from a 55-gallon drum.

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-   At the loading rack and unloading area (refer to Section 3.10 of
    this Plan):

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-   **Rollover berm.** The loading rack/unloading area is surrounded by
    a 4-inch rollover berm that provides sufficient containment for the
    largest compartment of the tank truck loading or unloading at the
    facility (2,000 gallons), and an additional 4 inches of freeboard
    for precipitation.

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-   In transfer areas and other parts of the facility where a discharge
    could occur:

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-   **Drip pans.** Fill ports for all ASTs are equipped with drip pans
    to contain small leaks from the piping/hose connections.

-   **Sorbent material.** Spill cleanup kits that include absorbent
    material, booms, and other portable barriers are located inside the
    maintenance building near the drummed oil storage area and in an
    outside shed located near the loading rack/unloading area, as shown
    on the Facility Diagram in Appendix A. The spill kits are located
    within close proximity of the oil product storage and handling areas
    for rapid deployment should a spill occur. Sorbent material, booms,
    and other portable barriers are stored in the shed next to the
    loading rack/unloading area to allow for quick deployment in the
    event of a discharge during loading/unloading activities or any
    other accidental discharge outside the dike or loading
    rack/unloading area, such as from tank vehicles entering/leaving the
    facility or spills associated with the fuel dispenser. The response
    equipment inventory for the facility is listed in Appendix J of this
    Plan. The inventory is checked monthly to ensure that used material
    is replenished.

-   **Drainage system.** The facility surface drainage is engineered to
    direct oil that may be discharged outside of engineered containment
    structures such as dikes or berms into the oil/water separator.

-   **Oil/water separator.** The oil/water separator is designed to
    separate and retain oil at the facility. The oil/water separator has
    a total capacity for oil/water mixture of 1,500 gallons and a design
    flow rate of 150 gallons per minute. The separator outlet valve can
    be closed in the event of a large discharge (greater than 300
    gallons) to provide additional emergency containment of up to 1,200
    gallons. The maximum amount of oil potentially discharged outside
    the diked or bermed areas is estimated at roughly 2,000 gallons
    (from the complete failure of an on-site tanker truck). A spill of
    this volume outside the diked or bermed areas will be primarily
    contained by deploying sorbent material and other portable spill
    barriers upon discovery of the spill, and additional oil containment
    capacity will be provided by the oil/water separator. The operating
    oil storage capacity is 300 gallons. Best Management Practices are
    used to minimize the amount of solids and oil that flow into the
    oil/water separator. Facility personnel are instructed to avoid and
    address small spills using sorbents to minimize runoff of oil into
    the oil/water separator. The oil/water separator is inspected
    monthly as part of the scheduled inspection to check the level of
    water within the separator and measure the depth of bottom sludges
    and floating oils. Floating oil is removed by a licensed waste
    collector when it reaches a thickness of 2 inches.

    **3.6 Practicability of Secondary Containment (40 CFR 112.7(d))**

    Unified Oil management has determined that secondary containment is
    practicable at this facility.

    **3.7 Inspections, Tests, and Records (40 CFR 112.7(e))**

    As required by the SPCC rule, Unified Oil performs the inspections,
    tests, and evaluations listed in the following table. Table 3-2
    summarizes the various types of inspections and tests performed at
    the facility. The inspections and tests are described later in this
    section, and in the respective sections that describe different
    parts of the facility (e.g., Section 4.2.6 for bulk storage
    containers).

    **Table 3-2: Inspection and Testing Program**

+------------+---------------------------+----------------------------+
| **Facility | **Action**                | *                          |
| C          |                           | *Frequency/Circumstances** |
| omponent** |                           |                            |
+============+===========================+============================+
| A          | Test container integrity. | Following a regular        |
| boveground | Combine visual inspection | schedule (monthly, annual, |
| container  | with another testing      | and during scheduled       |
|            | technique                 | inspections) and whenever  |
|            | (non-destructive shell    | material repairs are made. |
|            | testing). Inspect outside |                            |
|            | of container for signs of |                            |
|            | deterioration and         |                            |
|            | discharges.               |                            |
+------------+---------------------------+----------------------------+
| Container  | Inspect container's       | Following a regular        |
| supports   | supports and foundations. | schedule (monthly, annual, |
| and        |                           | and during scheduled       |
| foundation |                           | inspections) and whenever  |
|            |                           | material repairs are made. |
+------------+---------------------------+----------------------------+
| Liquid     | Test for proper           | Monthly                    |
| level      | operation.                |                            |
| sensing    |                           |                            |
| devices    |                           |                            |
| (overfill) |                           |                            |
+------------+---------------------------+----------------------------+
| Diked area | Inspect for signs of      | Monthly                    |
|            | deterioration,            |                            |
|            | discharges, or            | Prior to draining          |
|            | accumulation of oil       |                            |
|            | inside diked areas.       |                            |
|            |                           |                            |
|            | Visually inspect content  |                            |
|            | for presence of oil.      |                            |
+------------+---------------------------+----------------------------+
| Lowermost  | Visually inspect.         | Prior to filling and       |
| drain and  |                           | departure                  |
| all        |                           |                            |
| outlets of |                           |                            |
| tank truck |                           |                            |
+------------+---------------------------+----------------------------+
| Effluent   | Detect possible system    | Daily, monthly             |
| treatment  | upsets that could cause a |                            |
| facilities | discharge.                |                            |
+------------+---------------------------+----------------------------+
| All        | Assess general condition  | Monthly                    |
| a          | of items, such as flange  |                            |
| boveground | joints, expansion joints, |                            |
| valves,    | valve glands and bodies,  |                            |
| piping,    | catch pans, pipeline      |                            |
| and        | supports, locking of      |                            |
| app        | valves, and metal         |                            |
| urtenances | surfaces.                 |                            |
+------------+---------------------------+----------------------------+
| Buried     | Leak test.                | Annually                   |
| metallic   |                           |                            |
| storage    |                           |                            |
| tank       |                           |                            |
+------------+---------------------------+----------------------------+
| Buried     | Inspect for               | Whenever a section of      |
| piping     | deterioration.            | buried line is exposed for |
|            |                           | any reason.                |
|            | Integrity and leak        |                            |
|            | testing.                  | At the time of             |
|            |                           | installation,              |
|            |                           | modification,              |
|            |                           | construction, relocation,  |
|            |                           | or replacement.            |
+------------+---------------------------+----------------------------+

**3.7.1 Daily Inspection**

A Unified Oil employee performs a complete walk-through of the facility
each day. This daily visual inspection involves: (1) looking for
tank/piping damage or leakage, stained or discolored soils, or excessive
accumulation of water in diked and bermed areas; (2) observing the
effluent from the oil/water separator; and (3) verifying that the dike
drain valve is securely closed.

**3.7.2 Monthly Inspection**

The checklist provided in Appendix C is used for monthly inspections by
Unified Oil personnel. The monthly inspections cover the following key
elements:

-   Observing the exterior of aboveground storage tanks, pipes, and
    other equipment for signs of deterioration, leaks, corrosion, and
    thinning.

-   Observing the exterior of portable containers for signs of
    deterioration or leaks.

-   Observing tank foundations and supports for signs of instability or
    excessive settlement.

-   Observing the tank fill and discharge pipes for signs of poor
    connection that could cause a discharge, and tank vent for
    obstructions and proper operation.

-   Verifying the proper functioning of overfill prevention systems.

-   Checking the inventory of discharge response equipment and
    restocking as needed.

-   Observing the effluent and measuring the quantity of accumulated oil
    within the oil/water separator.

    All problems regarding tanks, piping, containment, or response
    equipment must immediately be reported to the Facility Manager.
    Visible oil leaks from tank walls, piping, or other components must
    be repaired as soon as possible to prevent a larger spill or a
    discharge to navigable waters or adjoining shorelines. Pooled oil is
    removed immediately upon discovery.

    Written monthly inspection records are signed by the Facility
    Manager and maintained with this SPCC Plan for a period of three
    years.

    3.  **Annual Inspection**

Facility personnel perform a more thorough inspection of facility
equipment on an annual basis. This annual inspection complements the
monthly inspection described above and is performed in June of each year
using the checklist provided in Appendix C of this Plan.

The annual inspection is preferably performed after a large storm event
in order to verify the imperviousness and/or proper functioning of
drainage control systems such as the dike, rollover berm, control
valves, and the oil/water separator.

Written annual inspection records are signed by the Facility Manager and
maintained with this SPCC Plan for a period of three years.

**3.7.4 Periodic Integrity Testing**

In addition to the above monthly and annual inspections by facility
personnel, Tanks #1, 2, 3, 4, and 7 are periodically evaluated by an
outside certified tank inspector following the Steel Tank Institute
(STI) *Standard for the Inspection of Aboveground Storage Tanks*,
SP-001, 2005 version, as described in Section 4.2.6 of this Plan.

**3.8 Personnel, Training, and Discharge Prevention Procedures
(40 CFR 112.7(f))**

The Facility Manager is the facility designee and is responsible for oil
discharge prevention, control, and response preparedness activities at
this facility.

Unified Oil management has instructed oil-handling facility personnel in
the operation and maintenance of oil pollution prevention equipment,
discharge procedure protocols, applicable pollution control laws, rules
and regulations, general facility operations, and the content of this
SPCC Plan. Any new facility personnel with oil-handling responsibilities
are provided with this same training prior to being involved in any oil
operation.

Annual discharge prevention briefings are held by the Facility Manager
for all facility personnel involved in oil operations. The briefings are
aimed at ensuring continued understanding and adherence to the discharge
prevention procedures presented in the SPCC Plan. The briefings also
highlight and describe known discharge events or failures,
malfunctioning components, and recently implemented precautionary
measures and best practices. Facility operators and other personnel will
have the opportunity during the briefings to share recommendations
concerning health, safety, and environmental issues encountered during
facility operations.

A simulation of an on-site vehicular discharge has been conducted, and
future training exercises will be periodically held to prepare for
possible discharge responses.

Records of the briefings and discharge prevention training are kept on
the form shown in Appendix E and maintained with this SPCC Plan for a
period of three years.

**3.9 Security (40 CFR 112.7(g))**

The facility is surrounded by 8-ft tall steel security fencing. The
fence encircles the entire footprint of the facility. The single
entrance gate is locked when the facility is unattended.

All drain valves for containment areas are locked in the closed position
to prevent unauthorized opening. Water draw valves on the 20,000-gallon
storage tanks are maintained in the closed position to prevent
unauthorized opening via locks. Keys for all locked valves are kept in
the front office.

Two area lights illuminate the loading/unloading and storage areas.
Additional motion-activated lights are placed in other areas of the
facility. The lights are placed to allow for the discovery of discharges
and to deter acts of vandalism.

The electrical starter controls for the oil pumps, including the fuel
dispenser, are located in a closet inside the maintenance shop. The
closet is locked when the pumps are not in use. The maintenance shop is
locked when the facility is unattended.

The facility securely caps or blank-flanges the loading/unloading
connections of facility piping when not in service or when in standby
service for an extended period of time, or when piping is emptied of
liquid content either by draining or by inert gas pressure.

**3.10 Tank Truck Loading/Unloading Rack Requirements (40 CFR
112.7(h))**

The potential for discharges during tank truck loading and unloading
operations is of particular concern at this facility. Unified Oil
management is committed to ensuring the safe transfer of material to and
from storage tanks. The following measures are implemented to prevent
oil discharges during tank truck loading and unloading operations.

**3.10.1 Secondary Containment (40 CFR 112.7(h)(1))**

The facility has both a loading rack (for loading moderate capacity oil
delivery tanker trucks) and an unloading area (where product is unloaded
from large capacity tanker truck to the facility bulk storage tanks).

The loading rack and unloading area are co-located and are used by
outside suppliers making deliveries to the facility and to load Unified
Oil delivery trucks.

The tank truck loading rack/unloading area is surrounded with a 4-inch
rollover asphalt berm that provides secondary containment in the event
of a discharge during transfer operations. The secondary containment
berm is designed to address the more stringent rack containment
requirements of 40 CFR 112.7(h), which requires that the berm be
sufficient to contain the capacity of the largest compartment, plus
freeboard for precipitation. The curbed area provides a catchment
capacity of 2,500 gallons, which is capable of containing the largest
compartment of the petroleum suppliers truck making deliveries at this
facility (maximum 2,000 gallons), and is also capable of containing the
capacity of Unified Oil's delivery trucks, which each have a total
capacity of 2,000 gallons.

To minimize direct exposure to rain, and facilitate the cleanup of small
spills that may occur during loading/unloading operations, the area is
partially covered by a roof.

The area is graded to direct the flow of oil or water away from the
vehicle, and the low point of the curbed area is fitted with a gate
valve that is normally kept closed and locked. The key for that lock is
kept in the main office. The berm is drained by Unified personnel after
verifying that the retained water is free of oil. The accumulated water
is released to the oil/water separator. The drain valve is closed and
locked following drainage.

Although delivery trucks are usually empty while at the site for
extended periods of time, Unified Oil periodically parks one of its two
delivery trucks while full overnight. If a delivery truck is parked
overnight or for an extended period of time while it still contains
fuel, it is parked inside the loading rack/unloading area containment
berm. As discussed above, the berm provides sufficient containment
capacity for the truck volume, plus sufficient freeboard for 4 inches of
precipitation.

**3.10.2 Loading/Unloading Procedures (40 CFR 112.7(h)(2) and (3))**

All suppliers must meet the minimum requirements and regulations for
tank truck loading/unloading established by the U.S. Department of
Transportation. Unified Oil ensures that the vendor understands the site
layout, knows the protocol for entering the facility and unloading
product, and has the necessary equipment to respond to a discharge from
the vehicle or fuel delivery hose.

The Facility Manager or his/her designee supervises oil deliveries for
all new suppliers, and periodically observes deliveries for existing,
approved suppliers.

All loading and unloading of tank vehicles takes place only in the
designated loading rack/unloading area.

Vehicle filling operations are performed by facility personnel trained
in proper discharge prevention procedures. The truck driver or facility
personnel remain with the vehicle at all times while fuel is being
transferred. Transfer operations are performed according to the minimum
procedures outlined in Table 3-3. This table is also posted next to the
loading/unloading point.

**Table 3-3: Fuel Transfer Procedures**

  -----------------------------------------------------------------------
  **Stage**   **Tasks**
  ----------- -----------------------------------------------------------

  -----------------------------------------------------------------------

+----------+-----------------------------------------------------------+
| Prior to | -   Visually check all hoses for leaks and wet spots.     |
| loading/ |                                                           |
| u        | -   Verify that sufficient volume (ullage) is available   |
| nloading |     in the storage tank or truck.                         |
|          |                                                           |
|          | -   Lock in the closed position all drainage valves of    |
|          |     the secondary containment structure.                  |
|          |                                                           |
|          | -   Secure the tank vehicle with wheel chocks and         |
|          |     interlocks.                                           |
|          |                                                           |
|          | -   Ensure that the vehicle's parking brakes are set.     |
|          |                                                           |
|          | -   Verify proper alignment of valves and proper          |
|          |     functioning of the pumping system.                    |
|          |                                                           |
|          | -   If filling a tank truck, inspect the lowermost drain  |
|          |     and all outlets.                                      |
|          |                                                           |
|          | -   Establish adequate bonding/grounding prior to         |
|          |     connecting to the fuel transfer point.                |
|          |                                                           |
|          | -   Turn off cell phone.                                  |
+----------+-----------------------------------------------------------+
| During   | 1.  Number range CHAPTERDriver must stay with the vehicle |
| loading/ |     at all times during loading/unloading activities.     |
| u        |                                                           |
| nloading | 2.  Periodically inspect all systems, hoses and           |
|          |     connections.                                          |
|          |                                                           |
|          | 3.  When loading, keep internal and external valves on    |
|          |     the receiving tank open along with the pressure       |
|          |     relief valves.                                        |
|          |                                                           |
|          | 4.  When making a connection, shut off the vehicle        |
|          |     engine. When transferring Class 3 materials, shut off |
|          |     the vehicle engine unless it is used to operate a     |
|          |     pump.                                                 |
|          |                                                           |
|          | 5.  Maintain communication with the pumping and receiving |
|          |     stations.                                             |
|          |                                                           |
|          | 6.  Monitor the liquid level in the receiving tank to     |
|          |     prevent overflow.                                     |
|          |                                                           |
|          | 7.  Monitor flow meters to determine rate of flow.        |
|          |                                                           |
|          | 8.  When topping off the tank, reduce flow rate to        |
|          |     prevent overflow.                                     |
+----------+-----------------------------------------------------------+
| After    | -   Make sure the transfer operation is completed.        |
| loading/ |                                                           |
| u        | -   Close all tank and loading valves before              |
| nloading |     disconnecting.                                        |
|          |                                                           |
|          | -   Securely close all vehicle internal, external, and    |
|          |     dome cover valves before disconnecting.               |
|          |                                                           |
|          | -   Secure all hatches.                                   |
|          |                                                           |
|          | -   Disconnect grounding/bonding wires.                   |
|          |                                                           |
|          | -   Make sure the hoses are drained to remove the         |
|          |     remaining oil before moving them away from the        |
|          |     connection. Use a drip pan.                           |
|          |                                                           |
|          | -   Cap the end of the hose and other connecting devices  |
|          |     before moving them to prevent uncontrolled leakage.   |
|          |                                                           |
|          | -   Remove wheel chocks and interlocks.                   |
|          |                                                           |
|          | 9.  Inspect the lowermost drain and all outlets on tank   |
|          |     truck prior to departure. If necessary, tighten,      |
|          |     adjust, or replace caps, valves, or other equipment   |
|          |     to prevent oil leaking while in transit.              |
+----------+-----------------------------------------------------------+

**3.11 Brittle Fracture Evaluation (40 CFR 112.7(i))**

The only field-constructed tank at the facility is Tank #7. All other
tanks were shop-built.

The shell thickness of Tank #7 is less than one-half inch. As discussed
in the American Petroleum Institute (API) Standard 653 *Tank Inspection,
Repair, Alteration, and Reconstruction* (API-653), brittle fracture is
not a concern for tanks that have a shell thickness of less than
one-half inch. This is the extent of the brittle fracture evaluation for
this tank.

Nonetheless, in the event that Tank #7 undergoes a repair, alteration,
reconstruction, or change in service that might affect the risk of a
discharge or failure, the container will be evaluated for risk of
discharge or failure, following API-653 or an equivalent approach, and
corrective action will be taken as necessary.

**3.12 Conformance with State and Local Applicable Requirements (40 CFR
112.7(j))**

All bulk storage tanks at this facility are registered with the state
and local authorities (Stonefield Fire Department) and have current
certificates of registration and special use permits required by the
local fire code.

Both USTs at the facility (Tanks #5 and 6) meet all requirements of
Massachusetts UST regulation, including cathodic protection, double-wall
construction, and monitoring systems, although Tank #6 is not subject to
these requirements.

Treated storm water runoff is discharged to Silver Creek as permitted
under NPDES permit #MA0001990. The maximum allowable daily oil/grease
concentration is 15 mg/L. Grab samples are taken each quarter, following
the monitoring requirements specified in the NPDES permit.

**PART 4: Discharge Prevention -- SPCC Provisions for Onshore Facilities
(Excluding Production Facilities)**

**4.1 Facility Drainage (40 CFR 112.8(b))**

Drainage from the concrete dike surrounding tanks 1, 2, and 3 is
restrained by a manually-operated gate valve to prevent a discharge from
entering the facility drainage system. The gate valve is normally sealed
closed, except when draining the secondary containment structure. The
content of the secondary containment dike is inspected by facility
personnel prior to draining to ensure that only oil-free water is
allowed to enter the facility storm water drainage system. The bypass
valve is opened and resealed under direct personnel supervision.
Drainage events are recorded in the log included in Appendix D to this
SPCC Plan.

Any potential discharge from ASTs will be restrained by secondary
containment structures. Discharges occurring during loading/unloading
operations will be restrained by the rollover berm. The facility
includes a drainage system and an oil/water separator, which are used to
as containment for spill sources outside the main berm areas (fuel
dispensing, overfills of 500-gallon AST (Tank#4), and transfers
associated with the heating oil tank). The facility is equipped with an
oil/water separator engineered to retain oil at the facility. This
separator provides environmental protection equivalent to ponds,
lagoons, or catchments basins required under 40 CFR 112.8(b)(3) and (4),
as allowed in 40 CFR 112.7(a)(2). Discharges outside the containment
areas, such as those occurring in the fuel dispensing area or while
unloading heating oil, will flow by gravity into the drainage collection
area and into the oil/water separator where oil will be retained until
it can be pumped out.

**4.2 Bulk Storage Containers (40 CFR 112.8(c))**

Table 4-1 summarizes the construction, volume, and content of bulk
storage containers at Unified Oil facility.

**Table 4-1: List of Oil Containers**

+----+----------+-----------------+-------+------------+-------------+
| ** | **Lo     | **Type          | **Cap | *          | **Discharge |
| Ta | cation** | (Construction   | acity | *Content** | Prevention  |
| nk |          | Standard)**     | (     |            | &           |
| ** |          |                 | gallo |            | Co          |
|    |          |                 | ns)** |            | ntainment** |
+----+----------+-----------------+-------+------------+-------------+
| #1 | Bulk     | AST vertical    | 2     | Diesel     | Concrete    |
|    | Storage  | (UL142)         | 0,000 |            | dike.       |
|    | Area     |                 |       |            |             |
|    |          |                 |       |            | Liquid      |
|    |          |                 |       |            | level       |
|    |          |                 |       |            | gauge.      |
+----+----------+-----------------+-------+------------+-------------+
| #2 | Bulk     | AST horizontal  | 2     | Premium    | Concrete    |
|    | Storage  | (UL142)         | 0,000 | unleaded   | dike.       |
|    | Area     |                 |       | gasoline   |             |
|    |          |                 |       |            | Liquid      |
|    |          |                 |       |            | level       |
|    |          |                 |       |            | gauge.      |
+----+----------+-----------------+-------+------------+-------------+
| #3 | Bulk     | AST horizontal  | 2     | Regular    | Concrete    |
|    | Storage  | (UL142)         | 0,000 | unleaded   | dike.       |
|    | Area     |                 |       | gasoline   |             |
|    |          |                 |       |            | Liquid      |
|    |          |                 |       |            | level       |
|    |          |                 |       |            | gauge.      |
+----+----------+-----------------+-------+------------+-------------+
| #4 | Varies   | AST dual wall,  | 500   | Regular    | D           |
|    |          | portable tank   |       | unleaded   | ouble-wall. |
|    |          | (UL142)         |       | gasoline   |             |
|    |          |                 |       |            | Liquid      |
|    |          |                 |       |            | level gauge |
|    |          |                 |       |            | and         |
|    |          |                 |       |            | i           |
|    |          |                 |       |            | nterstitial |
|    |          |                 |       |            | monitoring  |
|    |          |                 |       |            | system.     |
+----+----------+-----------------+-------+------------+-------------+
| #5 | Fuel     | UST dual wall   | 5,000 | Diesel     | D           |
|    | Di       | (STI P3)        |       |            | ouble-wall. |
|    | spensing |                 |       |            |             |
|    | Area     |                 |       |            | Liquid      |
|    |          |                 |       |            | level       |
|    |          |                 |       |            | gauge,      |
|    |          |                 |       |            | overfill    |
|    |          |                 |       |            | protection  |
|    |          |                 |       |            | system, and |
|    |          |                 |       |            | i           |
|    |          |                 |       |            | nterstitial |
|    |          |                 |       |            | monitoring. |
+----+----------+-----------------+-------+------------+-------------+
| #6 | Outside  | UST dual wall   | 1,000 | No. 2 Fuel | D           |
|    | Office   | (STI P3)        |       | Oil        | ouble-wall. |
|    | Building |                 |       |            |             |
|    |          |                 |       |            | Liquid      |
|    |          |                 |       |            | level       |
|    |          |                 |       |            | gauge,      |
|    |          |                 |       |            | overfill    |
|    |          |                 |       |            | protection  |
|    |          |                 |       |            | system, and |
|    |          |                 |       |            | i           |
|    |          |                 |       |            | nterstitial |
|    |          |                 |       |            | monitoring. |
+----+----------+-----------------+-------+------------+-------------+
| #7 | Bulk     | AST vertical    | 1     | No. 6 Fuel | Concrete    |
|    | Storage  | (               | 0,000 | Oil        | dike.       |
|    | Area     | field-erected). |       |            |             |
|    |          | Heated during   |       |            | Liquid      |
|    |          | winter months   |       |            | level       |
|    |          | (internal       |       |            | gauge.      |
|    |          | coils)          |       |            |             |
+----+----------+-----------------+-------+------------+-------------+
|    | Inside   | Steel drums     | 55    | Motor oil  | Spill       |
|    | Mai      |                 |       | and used   | pallets     |
|    | ntenance |                 |       | oil        | with        |
|    | Building |                 |       |            | built-in    |
|    |          |                 |       |            | containment |
|    |          |                 |       |            | capacity.   |
|    |          |                 |       |            | Building    |
|    |          |                 |       |            | also serves |
|    |          |                 |       |            | as          |
|    |          |                 |       |            | containment |
|    |          |                 |       |            | since floor |
|    |          |                 |       |            | drains flow |
|    |          |                 |       |            | into        |
|    |          |                 |       |            | oil/water   |
|    |          |                 |       |            | separator   |
+----+----------+-----------------+-------+------------+-------------+

1.  **Construction (40 CFR 112.8 (c)(1))**

All oil tanks used at this facility are constructed of steel, in
accordance with industry specifications as described above. The design
and construction of all bulk storage containers are compatible with the
characteristics of the oil product they contain, and with temperature
and pressure conditions.

Piping between fixed aboveground bulk storage tanks is made of steel and
placed aboveground on appropriate supports designed to minimize erosion
and stress.

**4.2.2 Secondary Containment (40 CFR 112.8(c)(2))**

A dike is provided around Tanks #1, 2, 3, and 7. Tanks #1, 2, and 3 each
have a 20,000-gallon capacity. Tank #7 has a 10,000-gallon capacity. The
dike has a total containment capacity of 27,316 gallons to allow
sufficient volume for the largest tank and freeboard for precipitation.
The freeboard is sufficient to contain a 4-inch rainfall corresponding
to a 25-year, 24-hour storm event for this region of Massachusetts, as
documented in Appendix F of this Plan. The floor and walls of the
containment dike are constructed of poured concrete reinforced with
steel. The concrete dike was built under the supervision of a structural
engineer and in conformance with his specifications to be impervious to
oil for a period of 72 hours. The facility is unattended for a maximum
of 40 hours (Saturday evening through Monday morning) and therefore any
spill into the diked area would be detected before it could escape the
diked area. The surface of the concrete floor, the inside and outside of
the walls, and the interface of the floor and walls, are visually
inspected during the monthly facility inspection to detect any crack,
signs of heaving or settlement, or other structural damage that could
affect the ability of the dike to contain oil. Any damage is promptly
corrected to prevent migration of oil into the ground, or out of the
dike.

The 500-gallon portable AST tank is of double-wall construction and
provides intrinsic secondary containment for 110 percent of the tank
capacity. Since the secondary containment is not open to precipitation,
this volume is sufficient to fully contain the product in the event of a
leak from the primary container. The interstitial space between the
primary and secondary containers is inspected on a monthly basis to
detect any leak of product from the primary container. The container,
however, is not equipped to prevent overfills as required by EPA policy
in its memorandum on double-walled tanks. Therefore, general containment
is required for potential tank overfills. This containment is
accomplished through the facility drainage system and the oil/water
separator, which provide environmentally equivalent protection as
described in Section 3.1 of this Plan.

Both USTs are of double-wall construction and provide intrinsic
secondary containment for 110 percent of the tank capacity. The
interstitial space between the primary and secondary containers is
inspected on a monthly basis to detect any leak of product from the
primary container.

The 55-gallon drums are placed on spill pallets inside the maintenance
shop. Each spill pallet provides 75 gallons of containment capacity,
which is more than the required 55 gallons for any single drum since the
drums are not exposed to precipitation. The floor of the maintenance
shop is impervious and sloped to direct any discharge occurring in the
building away from doorways and towards the drainage system that leads
to the facility oil/water separator.

**4.2.3 Drainage of Diked Areas (40 CFR 112.8(c)(3))**

The concrete dikes are drained under direct supervision of facility
personnel. The accumulated water is observed for signs of oil prior to
draining. The gate valves are normally kept in a closed position and
locked except when draining the dike. Dike drainage events are recorded
on the form included in Appendix D of this Plan; records are maintained
at the facility for at least three years.

**4.2.4 Corrosion Protection (40 CFR 112.8(c)(4))**

Both metallic underground storage tanks, including Tank #6, which is
subject to the requirements of 40 CFR part 112, are coated and
cathodically protected to prevent corrosion and leakage into the ground.
Pressure testing is performed on both buried storage tanks every two
years following the requirements of 40 CFR part 280. The cathodic
protection system is tested annually to verify its efficacy.

Cathodic protection is provided for both tanks in accordance with 40 CFR
part 280 and meets the requirements of 40 CFR part 112.

Records of pressure tests are kept for at least three years.

**4.2.5 Partially Buried and Bunkered Storage Tanks (40 CFR
112.8(c)(5))**

This section is not applicable since there are no partially buried or
bunkered storage tanks at this facility.

**4.2.6 Inspections and Tests (40 CFR 112.8(c)(6))**

Visual inspections of ASTs by facility personnel are performed according
to the procedure described in this SPCC Plan. Leaks from tank seams,
gaskets, rivets, and bolts are promptly corrected. Records of
inspections and tests are signed by the inspector and kept at the
facility for at least three years.

The scope and schedule of certified inspections and tests performed on
the facility's ASTs are specified in STI Standard SP-001. The external
inspection includes ultrasonic testing of the shell, as specified in the
standard, or if recommended by the certified tank inspector to assess
the integrity of the tank for continued oil storage.

Records of certified tank inspections are kept at the facility for at
least three years. Shell test comparison records are retained for the
life of the tanks.

Table 4-2 summarizes inspections and tests performed on bulk storage
containers ("EE" indicates that an environmentally equivalent measure is
implemented in place of the inspection/test, as discussed in Section 3.1
of this Plan).

**Table 4-2: Scope and Frequency of Bulk Storage Containers Inspections
and Tests**

+----------------------+----+----+----+----+----+----+----+-----+
|                      | ** |    |    |    |    |    |    |     |
|                      | Ta |    |    |    |    |    |    |     |
|                      | nk |    |    |    |    |    |    |     |
|                      | ID |    |    |    |    |    |    |     |
|                      | ** |    |    |    |    |    |    |     |
+----------------------+----+----+----+----+----+----+----+-----+
| **Inspection/Test**  | ** | ** | ** | ** | ** | ** | ** | **D |
|                      | #1 | #2 | #3 | #4 | #5 | #6 | #7 | rum |
|                      | ** | ** | ** | ** | ** | ** | ** | s** |
+----------------------+----+----+----+----+----+----+----+-----+
| Visual inspection by | M  | M  | M  | M  |    |    | M  | M   |
| facility personnel   |    |    |    |    |    |    |    |     |
| (as per checklist of | A  | A  | A  | A  |    |    | A  | A   |
| Appendix C)          |    |    |    |    |    |    |    |     |
+----------------------+----+----+----+----+----+----+----+-----+
| External inspection  | 20 | 20 | 10 | EE |    |    | 10 | EE  |
| by certified         | yr | yr | yr |    |    |    | yr |     |
| inspector (as per    |    |    |    |    |    |    |    |     |
| STI Standard SP-001) |    |    |    |    |    |    |    |     |
+----------------------+----+----+----+----+----+----+----+-----+
| Internal inspection  | †  | †  | 20 | EE |    |    | 20 | EE  |
| by certified         |    |    | yr |    |    |    | yr |     |
| inspector (as per    |    |    | \* |    |    |    | \* |     |
| STI Standard SP-001) |    |    |    |    |    |    |    |     |
+----------------------+----+----+----+----+----+----+----+-----+
| Tank tightness test  |    |    |    |    | 2  | 2  |    |     |
| meeting requirements |    |    |    |    | yr | yr |    |     |
| of 40 CFR 280        |    |    |    |    |    |    |    |     |
+----------------------+----+----+----+----+----+----+----+-----+

Legend: M: Monthly

A: Annual

EE: Inspection not required given use of environmentally equivalent
measure (refer to Section 3.1 of this Plan).

\* Or earlier, as recommended by the certified inspector based on
findings from an external inspection.

† Internal inspection may be recommended by the certified inspector
based on findings from the external inspection.

The frequency above is based on implementation of a scheduled
inspection/testing program. To initiate the program, ASTs will be
inspected by the following dates:

-   Tank #1: external inspection to be performed by December 31, 2009

-   Tank #2: external inspection to be performed by December 31, 2009

-   Tank #3: external inspection to be performed by December 31, 2006

-   Tank #7: external Inspection to be performed by December 31, 2006

    **4.2.7 Heating Coils (40 CFR 112.8(c)(7))**

    Exhaust lines from internal heating coils for Tank #7 drain to the
    oil/water separator. The exhaust lines are monitored for signs of
    leakage as part of the monthly inspection of the facility.

    **4.2.8 Overfill Prevention Systems (40 CFR 112.8(c)(8))**

    All tanks are equipped with a direct-reading level gauge.
    Additionally, all four fixed ASTs (Tanks #1, 2, 3, and 7) are
    equipped with high level alarms set at 90 percent of the rated
    capacity. Tank #4 does not have an overfill prevention system.
    General secondary containment is provided in the event of overfills,
    as described in this Plan.

    Storage drums are not refilled, and therefore overfill prevention
    systems do not apply.

    Tanks #5 and 6 are equipped with liquid level gauges and overfill
    protection systems. Liquid level sensing devices are tested on a
    monthly basis during the monthly inspection of the facility,
    following manufacturer recommendations. Venting capacity is suitable
    for the fill and withdrawal rates.

    Facility personnel are present throughout the filling operations to
    monitor the product level in the tanks.

    **4.2.9 Effluent Treatment Facilities (40 CFR 112.8(c)(9))**

    The facility's storm water effluent discharged into Silver Creek is
    observed and records maintained according to the frequency required
    by NPDES permit MA0000157 (at least once per month) to detect
    possible upsets in the oil/water separator that could lead to a
    discharge.

    **4.2.10 Visible Discharges (40 CFR 112.8(c)(10))**

    Visible discharges from any container or appurtenance -- including
    seams, gaskets, piping, pumps, valves, rivets, and bolts -- are
    quickly corrected upon discovery.

    Oil is promptly removed from the diked area and disposed of
    according to the waste disposal method described in Part 5 of this
    Plan.

    **4.2.11 Mobile and Portable Containers (40 CFR 112.8(c)(11))**

    Tank #4 is of double-wall design, which provides for adequate
    secondary containment in the event of leaks in the primary container
    shell. The interstitial space is monitored monthly for signs of
    leakage.

    Small portable oil storage containers, such as 55-gallon drums, are
    stored inside the maintenance shop where secondary containment is
    provided by spill pallets and the floor is sloped to drain away from
    the floor drains and door. Any discharged material is quickly
    contained and cleaned up using sorbent pads and appropriate cleaning
    products.

    Unified Oil delivery trucks generally return to the facility empty
    or product is returned to inventory. Whenever they remain at the
    facility while full for an extended period of time (such as when
    parking overnight with an emergency load of product), they are
    positioned in the loading rack/unloading area, which provides 2,500
    gallons of secondary containment capacity (i.e., sufficient for the
    capacity of the delivery truck (2,000 gallons) and additional
    freeboard for 4 inches of precipitation).

    **4.3 Transfer Operations, Pumping, and In-Plant Processes
    (40 CFR 112.8(d))**

    Transfer operations at this facility include:

-   The transfer of oil from the underground fuel oil storage tank to
    the furnace located in the basement of the office building. The oil
    is pumped from the oil storage tank by means of buried steel fuel
    lines and a suction pump system.

-   The filling of facility delivery trucks using the gasoline
    dispenser.

-   The transfer of oil into or from tanker trucks at the loading
    rack/unloading area.

    All buried piping at this facility is cathodically protected against
    corrosion and is provided with a protective wrapping and coating.
    When a section of buried line is exposed, it is carefully examined
    for deterioration. If corrosion damage is found, additional
    examination and corrective action must be taken as deemed
    appropriate considering the magnitude of the damage. Additionally,
    Unified Oil conducts integrity and leak testing of buried piping at
    the time of installation, modification, construction, relocation, or
    replacement. Records of all tests are kept at the facility for at
    least three years.

    Lines that are not in service or are on standby for an extended
    period of time are capped or blank-flanged and marked as to their
    origin.

    All pipe supports are designed to minimize abrasion and corrosion
    and to allow for expansion and contraction. Pipe supports are
    visually inspected during the monthly inspection of the facility.

    All aboveground piping and valves are examined monthly to assess
    their condition. Inspection includes aboveground valves, piping,
    appurtenances, expansion joints, valve glands and bodies, catch
    pans, pipeline supports, locking of valves, and metal surfaces.
    Observations are noted on the monthly inspection checklist provided
    in this Plan.

    Warning signs are posted at appropriate locations throughout the
    facility to prevent vehicles from damaging aboveground piping and
    appurtenances. Most of the aboveground piping is located within
    areas that are not accessible to vehicular traffic (e.g., inside
    diked area). Brightly painted bollards are placed where needed to
    prevent vehicular collisions with equipment.

    **Part 5: Discharge Response**

    This section describes the response and cleanup procedures in the
    event of an oil discharge. The uncontrolled discharge of oil to
    groundwater, surface water, or soil is prohibited by state and
    possibly federal laws. Immediate action must be taken to control,
    contain, and recover discharged product.

    In general, the following steps are taken:

-   Eliminate potential spark sources;

-   If possible and safe to do so, identify and shut down source of the
    discharge to stop the flow;

-   Contain the discharge with sorbents, berms, fences, trenches,
    sandbags, or other material;

-   Contact the Facility Manager or his/her alternate;

-   Contact regulatory authorities and the response organization; and

-   Collect and dispose of recovered products according to regulation.

    For the purpose of establishing appropriate response procedures,
    this SPCC Plan classifies discharges as either "minor" or "major,"
    depending on the volume and characteristics of the material
    released.

    A list of Emergency Contacts is provided in Appendix H. The list is
    also posted at prominent locations throughout the facility. A list
    of discharge response material kept at the facility is included in
    Appendix J.

    **5.1 Response to a Minor Discharge**

    A "minor" discharge is defined as one that poses no significant harm
    (or threat) to human health and safety or to the environment. Minor
    discharges are generally those where:

-   The quantity of product discharged is small (e.g., may involve less
    than 10 gallons of oil);

-   Discharged material is easily stopped and controlled at the time of
    the discharge;

-   Discharge is localized near the source;

-   Discharged material is not likely to reach water;

-   There is little risk to human health or safety; and

-   There is little risk of fire or explosion.

    Minor discharges can usually be cleaned up by Unified Oil personnel.
    The following guidelines apply:

-   Immediately notify the Facility Manager.

-   Under the direction of the Facility Manager, contain the discharge
    with discharge response materials and equipment. Place discharge
    debris in properly labeled waste containers.

-   The Facility Manager will complete the discharge notification form
    (Appendix I) and attach a copy to this SPCC Plan.

-   If the discharge involves more than 10 gallons of oil, the Facility
    Manager will call the Massachusetts Department of Environmental
    Protection Incident Response Division (617-556-1133).

    **5.2 Response to a Major Discharge**

    A "major" discharge is defined as one that cannot be safely
    controlled or cleaned up by facility personnel, such as when:

-   The discharge is large enough to spread beyond the immediate
    discharge area;

-   The discharged material enters water;

-   The discharge requires special equipment or training to clean up;

-   The discharged material poses a hazard to human health or safety; or

-   There is a danger of fire or explosion.

    In the event of a major discharge, the following guidelines apply:

-   All workers must immediately evacuate the discharge site via the
    designated exit routes and move to the designated staging areas at a
    safe distance from the discharge. Exit routes are included on the
    facility diagram and posted in the maintenance building, in the
    office building, and on the outside wall of the outside shed that
    contains the spill response equipment.

-   If the Facility Manager is not present at the facility, the senior
    on-site person notifies the Facility Manager of the discharge and
    has authority to initiate notification and response. Certain
    notifications are dependent on the circumstances and type of
    discharge. For example, if oil reaches a sanitary sewer, the
    publicly owned treatment works (POTW) should be notified
    immediately. A discharge that threatens Silver Creek may require
    immediate notification to downstream users such as the town drinking
    water plant, which has an intake located on Silver Creek.

-   The Facility Manager (or senior on-site person) must call for
    medical assistance if workers are injured.

-   The Facility Manager (or senior on-site person) must notify the Fire
    Department or Police Department.

-   The Facility Manager (or senior on-site person) must call the spill
    response and cleanup contractors listed in the Emergency Contacts
    list in Appendix H.

-   The Facility Manager (or senior on-site person) must immediately
    contact the Massachusetts Department of Environmental Protection
    Incident Response Division (617-556-1133) and the National Response
    Center (888-424-8802).

-   The Facility Manager (or senior on-site person) must record the call
    on the Discharge Notification form in Appendix I and attach a copy
    to this SPCC Plan.

-   The Facility Manager (or senior on-site person) coordinates cleanup
    and obtains assistance from a cleanup contractor or other response
    organization as necessary.

    If the Facility Manager is not available at the time of the
    discharge, then the next highest person in seniority assumes
    responsibility for coordinating response activities.

    **5.3 Waste Disposal**

    Wastes resulting from a minor discharge response will be
    containerized in impervious bags, drums, or buckets. The facility
    manager will characterize the waste for proper disposal and ensure
    that it is removed from the facility by a licensed waste hauler
    within two weeks.

    Wastes resulting from a major discharge response will be removed and
    disposed of by a cleanup contractor.

    **5.4 Discharge Notification**

    Any size discharge (i.e., one that creates a sheen, emulsion, or
    sludge) that affects or threatens to affect navigable waters or
    adjoining shorelines must be reported immediately to the National
    Response Center (1-800-424-8802). The Center is staffed 24 hours a
    day.

    A summary sheet is included in Appendix I to facilitate reporting.
    The person reporting the discharge must provide the following
    information:

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-   Name, location, organization, and telephone number

-   Name and address of the party responsible for the incident

-   Date and time of the incident

-   Location of the incident

-   Source and cause of the release or discharge

-   Types of material(s) released or discharged

-   Quantity of materials released or discharged

-   Danger or threat posed by the release or discharge

-   Number and types of injuries (if any)

-   Media affected or threatened by the discharge (i.e., water, land,
    air)

-   Weather conditions at the incident location

-   Any other information that may help emergency personnel respond to
    the incident

    Contact information for reporting a discharge to the appropriate
    authorities is listed in Appendix H and is also posted in prominent
    locations throughout the facility (e.g., in the office building, in
    the maintenance building, and at the loading rack/unloading area).

    In addition to the above reporting, 40 CFR 112.4 requires that
    information be submitted to the United States Environmental
    Protection Agency (EPA) Regional Administrator and the appropriate
    state agency in charge of oil pollution control activities (see
    contact information in Appendix H) whenever the facility discharges
    (as defined in 40 CFR 112.1(b)) *more than 1,000 gallons of oil in a
    single event,* or discharges (as defined in 40 CFR 112.1(b)) *more
    than 42 gallons of oil in each of two discharge incidents within a
    12-month period.* The following information must be submitted to the
    EPA Regional Administrator and to MADEP within 60 days:

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-   Name of the facility;

-   Name of the owner/operator;

-   Location of the facility;

-   Maximum storage or handling capacity and normal daily throughput;

-   Corrective action and countermeasures taken, including a description
    of equipment repairs and replacements;

-   Description of facility, including maps, flow diagrams, and
    topographical maps;

-   Cause of the discharge(s) to navigable waters and adjoining
    shorelines, including a failure analysis of the system and subsystem
    in which the failure occurred;

-   Additional preventive measures taken or contemplated to minimize
    possibility of recurrence; and

-   Other pertinent information requested by the Regional Administrator.

    A standard report for submitting the information to the EPA Regional
    Administrator and to MADEP is included in Appendix K of this Plan.

    **5.5 Cleanup Contractors and Equipment Suppliers**

    Contact information for specialized spill response and cleanup
    contractors are provided in Appendix H. These contractors have the
    necessary equipment to respond to a discharge of oil that affects
    Silver Creek or adjoining shorelines, including floating booms and
    oil skimmers.

    Spill kits are located at the loading rack/unloading area and inside
    the maintenance building. The inventory of response supplies and
    equipment is provided in Appendix J of this Plan. The inventory is
    verified on a monthly basis. Additional supplies and equipment may
    be ordered from the following sources:

    AA Equipment Co. (800) 555-5556

    Eastern Sorbent (800) 555-5557

    **Appendix A**

    ![](media/image3.wmf)

    ![](media/image4.wmf): Facility Diagram.

    **Appendix B**

    **Substantial Harm Determination**

    Facility Name: Unified Oil Company

    Facility Address: 123 A Street

    Stonefield, MA 02000

    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?

    Number range CHAPTERYes G No O

    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 storage tank area?

    Yes G No O

    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 40 CFR part
    112 Appendix C, Attachment C-III or a comparable formula) such that
    a discharge from the facility could cause injury to fish and
    wildlife and sensitive environments?

    Yes G No O

    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 40 CFR part
    112 Appendix C, Attachment C-III or a comparable formula) such that
    a discharge from the facility would shut down a public drinking
    water intake?

    Yes G No O

    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 G No O

    **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.

    Susan Blake *Facility Manager*

    Signature Title

    *Susan Blake* *May 12, 2003*

    Name (type or print) Date

    **APPENDIX C**

    **Facility Inspection Checklists**

    The following checklists are to be used for monthly and annual
    facility-conducted inspections. Completed checklists must be signed
    by the inspector and maintained at the facility, with this SPCC
    Plan, for at least three years.

    **Monthly Inspection Checklist**

    This inspection record must be completed *each month* except the
    month in which an annual inspection is performed. Provide further
    description and comments, if necessary, on a separate sheet of paper
    and attach to this sheet. \*Any item that receives "yes" as an
    answer must be described and addressed immediately.

  -------------------------------------- --------- --- -------------------------
                                         **Y**\*   N   Description & Comments

  **Storage tanks**                                    

  *Tank surfaces show signs of leakage*                

  *Tanks are damaged, rusted or                        
  deteriorated*                                        

  *Bolts, rivets, or seams are damaged*                

  *Tank supports are deteriorated or                   
  buckled*                                             

  *Tank foundations have eroded or                     
  settled*                                             

  *Level gauges or alarms are                          
  inoperative*                                         

  *Vents are obstructed*                               

  *Secondary containment is damaged or                 
  stained*                                             

  *Water/product in interstice of                      
  double-walled tank*                                  

  *Dike drainage valve is open or is not               
  locked*                                              

  **Piping**                                           

  *Valve seals, gaskets, or other                      
  appurtenances are leaking*                           

  *Pipelines or supports are damaged or                
  deteriorated*                                        

  *Joints, valves and other                            
  appurtenances are leaking*                           

  *Buried piping is exposed*                           

  **Loading/unloading and transfer                     
  equipment**                                          

  *Loading/unloading rack is damaged or                
  deteriorated*                                        

  *Connections are not capped or                       
  blank-flanged*                                       

  *Secondary containment is damaged or                 
  stained*                                             

  *Berm drainage valve is open or is not               
  locked*                                              

  **Oil/water separator**                              

  *Oil/water separator \> 2 inches of                  
  accumulated oil*                                     

  *Oil/water separator effluent has a                  
  sheen*                                               

  **Security**                                         

  *Fencing, gates, or lighting is                      
  non-functional*                                      

  *Pumps and valves are locked if not in               
  use*                                                 

  **Response Equipment**                               

  *Response equipment inventory is                     
  complete*                                            
  -------------------------------------- --------- --- -------------------------

#### Date: \_\_\_\_\_\_\_\_\_\_\_\_ Signature: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ 

**Annual Facility Inspection Checklist**

This inspection record must be completed *each year.* If any response
requires further elaboration, provide comments in Description & Comments
space provided. Further description and comments, if necessary, must be
provided on a separate sheet of paper and attached to this sheet. \*Any
item that receives "yes" as an answer must be described and addressed
immediately.

+-------------------------------------+---+---+------------------------+
|                                     | * | N | Description & Comments |
|                                     | * |   |                        |
|                                     | Y |   |                        |
|                                     | \ |   |                        |
|                                     | * |   |                        |
|                                     | * |   |                        |
|                                     | * |   |                        |
+=====================================+===+===+========================+
| **Storage tanks**                   |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Tank #1*                           |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Tank surfaces show signs of        |   |   |                        |
| leakage*                            |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Tank is damaged, rusted or         |   |   |                        |
| deteriorated*                       |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Bolts, rivets or seams are         |   |   |                        |
| damaged*                            |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Tank supports are deteriorated or  |   |   |                        |
| buckled*                            |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Tank foundations have eroded or    |   |   |                        |
| settled*                            |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Level gauges or alarms are         |   |   |                        |
| inoperative*                        |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Vents are obstructed*              |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Tank #2*                           |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Tank surfaces show signs of        |   |   |                        |
| leakage*                            |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Tank is damaged, rusted, or        |   |   |                        |
| deteriorated*                       |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Bolts, rivets, or seams are        |   |   |                        |
| damaged*                            |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Tank supports are deteriorated or  |   |   |                        |
| buckled*                            |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Tank foundations have eroded or    |   |   |                        |
| settled*                            |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Level gauges or alarms are         |   |   |                        |
| inoperative*                        |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Vents are obstructed*              |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Tank #3*                           |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Tank surfaces show signs of        |   |   |                        |
| leakage*                            |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Tank is damaged, rusted, or        |   |   |                        |
| deteriorated*                       |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Bolts, rivets, or seams are        |   |   |                        |
| damaged*                            |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Tank supports are deteriorated or  |   |   |                        |
| buckled*                            |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Tank foundations have eroded or    |   |   |                        |
| settled*                            |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Level gauges or alarms are         |   |   |                        |
| inoperative*                        |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Vents are obstructed*              |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Tank #4*                           |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Tank surfaces show signs of        |   |   |                        |
| leakage*                            |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Tank is damaged, rusted or         |   |   |                        |
| deteriorated*                       |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Bolts, rivets or seams are         |   |   |                        |
| damaged*                            |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Tank supports are deteriorated or  |   |   |                        |
| buckled*                            |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Tank foundations have eroded or    |   |   |                        |
| settled*                            |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Level gauges or alarms are         |   |   |                        |
| inoperative*                        |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Vents are obstructed*              |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Oil is present in the interstice*  |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Tank #7*                           |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Tank surfaces show signs of        |   |   |                        |
| leakage*                            |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Tank is damaged, rusted, or        |   |   |                        |
| deteriorated*                       |   |   |                        |
+-------------------------------------+---+---+------------------------+
| ###                                 |   |   |                        |
| Bolts, rivets, or seams are damaged |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Tank supports are deteriorated or  |   |   |                        |
| buckled*                            |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Tank foundations have eroded or    |   |   |                        |
| settled*                            |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Level gauges or alarms are         |   |   |                        |
| inoperative*                        |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Leakage in exhaust from heating    |   |   |                        |
| coils*                              |   |   |                        |
+-------------------------------------+---+---+------------------------+
| **Concrete dike**                   |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Secondary containment is stained*  |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Dike drainage valve is open or is  |   |   |                        |
| not locked*                         |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Dike walls or floors are cracked   |   |   |                        |
| or are separating*                  |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Dike is not retaining water        |   |   |                        |
| (following large rainfall)*         |   |   |                        |
+-------------------------------------+---+---+------------------------+
| **Piping**                          |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Valve seals or gaskets are         |   |   |                        |
| leaking*                            |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Pipelines or supports are damaged  |   |   |                        |
| or deteriorated*                    |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Joints, valves and other           |   |   |                        |
| appurtenances are leaking*          |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Buried piping is exposed*          |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Out-of-service pipes are not       |   |   |                        |
| capped*                             |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Warning signs are missing or       |   |   |                        |
| damaged*                            |   |   |                        |
+-------------------------------------+---+---+------------------------+
| **Loading/unloading and transfer    |   |   |                        |
| equipment**                         |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Loading/unloading rack is damaged  |   |   |                        |
| or deteriorated*                    |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Connections are not capped or      |   |   |                        |
| blank-flanged*                      |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Rollover berm is damaged or        |   |   |                        |
| stained*                            |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Berm drainage valve is open or is  |   |   |                        |
| not locked*                         |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Drip pans have accumulated oil or  |   |   |                        |
| are leaking*                        |   |   |                        |
+-------------------------------------+---+---+------------------------+
| **Oil/water separator**             |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Oil/water separator \> 2 inches of |   |   |                        |
| accumulated oil*                    |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Oil/water separator effluent has a |   |   |                        |
| sheen*                              |   |   |                        |
+-------------------------------------+---+---+------------------------+
| **Security**                        |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Fencing, gates, or lighting is     |   |   |                        |
| non-functional*                     |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Pumps and valves are not locked    |   |   |                        |
| (and not in use)*                   |   |   |                        |
+-------------------------------------+---+---+------------------------+
| **Response equipment**              |   |   |                        |
+-------------------------------------+---+---+------------------------+
| *Response equipment inventory is    |   |   |                        |
| incomplete*                         |   |   |                        |
+-------------------------------------+---+---+------------------------+

**Annual reminders:**

-   Hold SPCC Briefing for all oil-handling personnel (and update
    briefing log in the Plan);

-   Check contact information for key employees and response/cleanup
    contractors and update them in the Plan as needed;

    **Additional Remarks:**

    Date: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ Signature:
    \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

    **APPENDIX D**

    **Record of Containment Dike Drainage**

    This record must be completed when rainwater from diked areas is
    drained into a storm drain or into an open watercourse, lake, or
    pond, and bypasses the water treatment system. The bypass valve must
    normally be sealed in closed position. It must be opened and
    resealed following drainage under responsible supervision.

  ------------ ----------- ------------ ----------- ------------ --------------------
  **Date**     **Diked     **Presence   **Time      **Time       **Signature**
               Area**      of Oil**     Started**   Finished**   

  06/05/2003   Area 1      No oil       08:00       10:00        Susan Blake

  07/15/2003   Area 1      No oil       08:20       10:30        Susan Blake

                                                                 

                                                                 

                                                                 

                                                                 

                                                                 

                                                                 
  ------------ ----------- ------------ ----------- ------------ --------------------

**APPENDIX E**

**Record of Annual Discharge Prevention**

**Briefings and Training**

Briefings will be scheduled and conducted by the facility owner or
operator for operating personnel at regular intervals to ensure adequate
understanding of this SPCC Plan. The briefings will also highlight and
describe known discharge events or failures, malfunctioning components,
and recently implemented precautionary measures and best practices.
Personnel will also be instructed in operation and maintenance of
equipment to prevent the discharge of oil, and in applicable pollution
laws, rules, and regulations. Facility operators and other personnel
will have an opportunity during the briefings to share recommendations
concerning health, safety, and environmental issues encountered during
facility operations.

  ---------- ------------------- ------------------------------ -------------------
  **Date**   **Subjects          **Employees in Attendance**    **Instructor(s)**
             Covered**                                          

                                                                

                                                                

                                                                

                                                                

                                                                

                                                                

                                                                

                                                                

                                                                

                                                                

                                                                

                                                                
  ---------- ------------------- ------------------------------ -------------------

**APPENDIX F**

**Calculation of Secondary Containment Capacity**

The maximum 24-hour rainfall recorded in the last 25 years at this
location is **3.75 inches**.

**Bulk Storage Dike**

*Capacity of Tanks within the Diked Area:*

Tank 1 = 20,000 gallons (saddle-mounted tank, no significant
displacement)

Tank 2 = 20,000 gallons (saddle-mounted tank, no significant
displacement)

Tank 3 = 20,000 gallons (need to account for tank displacement)

Tank 7 = 10,000 gallons (on legs, no significant displacement)

*Dike Dimensions:*

Dike footprint = 50 feet x 60 feet

Dike height = 15 inches = 1.25 feet

Dike volume = 50\' x 60\' x 1.25\' = 3750 ft^3^ x 7.48 gal/ft^3^ =
28,050 gallons

*Displacement Volume of Tank 3:*

Tank diameter = 10 feet

3.1415 \* (10 ft)^2^ / 4 \* 1.25\' = 98 ft^3^ x 7.48 gal/ft^3^ = 734
gallons

*Available Freeboard* *for Precipitation*:

28,050 gallons - (20,000 gallons + 734 gallons) = 7,316 gallons

7,316 gallons / 7.48 gallons/ft^3^ / (50 ft x 60 ft) = 0.33 ft = **4
inches**

The dike therefore **provides sufficient storage capacity for the
largest bulk storage container within the diked area, tank displacement,
and precipitation**. The containment capacity is equivalent to 137% of
the capacity of the largest container ((28,050 gallons - 734
gallons)/20,000 gallons).

**Loading Rack/Unloading Area Rollover Berm**

*Capacity of Largest Tank Truck Compartment:*

2,000 gallons

*Berm Dimensions*:

Berm footprint = 28 feet x 45 feet (50% of the berm surface area is
covered by the roof)

Berm height = 4.5 inches = 0.375 feet

Berm volume = 28 ft x 45 ft x 0.375 ft = 473 ft^3^ x 7.48 gal/ft^3^ =
3,534 gallons

*Available Freeboard for Precipitation*:

Since 50% of the surface area of the berm is covered by a roof, the
volume of precipitation that enters the berm is reduced.

Minimum freeboard required = 28 ft x 45 ft x 0.5 x 3.75/12 = 197 ft^3^ =
1,472 gallons

Actual freeboard = 3,534 gallons - 2,000 gallons = 1,534 gallons

The berm therefore **provides sufficient storage capacity to contain
both the largest compartment of tank trucks loading/unloading at the
facility, and the volume of precipitation that enters the berm**.

**APPENDIX G**

**Records of Tank Integrity and Pressure Tests**

Attach copies of official records of tank integrity and pressure tests.

**APPENDIX H**

**Emergency Contacts**

***Designated person responsible for spill prevention: Susan Blake,
Facility Manager***

***781-555-5550***

**EMERGENCY TELEPHONE NUMBERS:**

+-------------------------------------------------------+--------------+
| **Facility**                                          |              |
+-------------------------------------------------------+--------------+
| Susan Blake, Facility Manager                         | 781-555-5550 |
+-------------------------------------------------------+--------------+
| **Local Emergency Response**                          |              |
+-------------------------------------------------------+--------------+
| Stonefield Fire Department                            | 911 or       |
|                                                       |              |
|                                                       | 781-555-5551 |
+-------------------------------------------------------+--------------+
| St. Mary's Hospital                                   | 781-555-5552 |
+-------------------------------------------------------+--------------+
| **Response/Cleanup Contractors**                      |              |
+-------------------------------------------------------+--------------+
| EZ Clean                                              | 617-555-5554 |
+-------------------------------------------------------+--------------+
| Stonefield Oil Removal                                | 781-555-5555 |
+-------------------------------------------------------+--------------+
| **Notification**                                      |              |
+-------------------------------------------------------+--------------+
| Massachusetts Department of Environmental Protection, | 617-556-1133 |
| Incident Response Division                            |              |
+-------------------------------------------------------+--------------+
| National Response Center                              | 800-424-8802 |
+-------------------------------------------------------+--------------+
| United States Environmental Protection Agency, Region | 888-372-7341 |
| 1                                                     |              |
+-------------------------------------------------------+--------------+

**APPENDIX I**

**Discharge Notification Form**

+--------------------------------+---+---------+------------------------+
| #####                          |   |         |                        |
|  Part A: Discharge Information |   |         |                        |
+--------------------------------+---+---------+------------------------+
| General information when       |   |         |                        |
| reporting a spill to outside   |   |         |                        |
| authorities:                   |   |         |                        |
|                                |   |         |                        |
| Name: Unified Oil Company      |   |         |                        |
|                                |   |         |                        |
| Address: 123 A Street          |   |         |                        |
|                                |   |         |                        |
| Stonefield, MA 02000           |   |         |                        |
|                                |   |         |                        |
| Telephone: (781) 555-5556      |   |         |                        |
|                                |   |         |                        |
| Owner/Operator: Blake and      |   |         |                        |
| Daughters, Inc.                |   |         |                        |
|                                |   |         |                        |
| 20 Fairview Road               |   |         |                        |
|                                |   |         |                        |
| Stonefield, MA 02000           |   |         |                        |
|                                |   |         |                        |
| Primary Contact: Susan Blake,  |   |         |                        |
| Facility Manager               |   |         |                        |
|                                |   |         |                        |
| Work: (781)555-5550            |   |         |                        |
|                                |   |         |                        |
| Cell (24 hrs): (781)555-5559   |   |         |                        |
+--------------------------------+---+---------+------------------------+
| Type of oil:                   |   | Di      |                        |
|                                |   | scharge |                        |
|                                |   | Date    |                        |
|                                |   | and     |                        |
|                                |   | Time:   |                        |
+--------------------------------+---+---------+------------------------+
| Quantity released:             |   | Di      |                        |
|                                |   | scovery |                        |
|                                |   | Date    |                        |
|                                |   | and     |                        |
|                                |   | Time:   |                        |
+--------------------------------+---+---------+------------------------+
| Quantity released to a         |   | Di      |                        |
| waterbody:                     |   | scharge |                        |
|                                |   | Du      |                        |
|                                |   | ration: |                        |
+--------------------------------+---+---------+------------------------+
| Location/Source:               |   |         |                        |
+--------------------------------+---+---------+------------------------+
| Actions taken to stop, remove, |   |         |                        |
| and mitigate impacts of the    |   |         |                        |
| discharge:                     |   |         |                        |
+--------------------------------+---+---------+------------------------+
| Affected media:                |   | G storm |                        |
|                                |   | water   |                        |
| G air                          |   | sew     |                        |
|                                |   | er/POTW |                        |
| G water                        |   |         |                        |
|                                |   | G       |                        |
| G soil                         |   | dike/   |                        |
|                                |   | berm/oi |                        |
|                                |   | l-water |                        |
|                                |   | se      |                        |
|                                |   | parator |                        |
|                                |   |         |                        |
|                                |   | G       |                        |
|                                |   | other:  |                        |
|                                |   | \       |                        |
|                                |   | _\_\_\_ |                        |
|                                |   | \_\_\_\ |                        |
|                                |   | _\_\_\_ |                        |
|                                |   | \_\_\_\ |                        |
|                                |   | _\_\_\_ |                        |
|                                |   | \_\_\_\ |                        |
|                                |   | _\_\_\_ |                        |
+--------------------------------+---+---------+------------------------+
| Notification person:           |   | Te      |                        |
|                                |   | lephone |                        |
|                                |   | c       |                        |
|                                |   | ontact: |                        |
|                                |   |         |                        |
|                                |   | Bu      |                        |
|                                |   | siness: |                        |
|                                |   |         |                        |
|                                |   | 24-hr:  |                        |
+--------------------------------+---+---------+------------------------+
| Nature of discharges,          |   |         |                        |
| environmental/health effects,  |   |         |                        |
| and damages:                   |   |         |                        |
|                                |   |         |                        |
| Injuries, fatalities or        |   |         |                        |
| evacuation required?           |   |         |                        |
+--------------------------------+---+---------+------------------------+
| **Part B: Notification         |   |         |                        |
| Checklist**                    |   |         |                        |
+--------------------------------+---+---------+------------------------+
|                                | D |         | Name of person         |
|                                | a |         | receiving call         |
|                                | t |         |                        |
|                                | e |         |                        |
|                                | a |         |                        |
|                                | n |         |                        |
|                                | d |         |                        |
|                                | t |         |                        |
|                                | i |         |                        |
|                                | m |         |                        |
|                                | e |         |                        |
+--------------------------------+---+---------+------------------------+
| **Discharge in any amount**    |   |         |                        |
+--------------------------------+---+---------+------------------------+
| Susan Blake, Facility Manager  |   |         |                        |
| and Response Coordinator       |   |         |                        |
|                                |   |         |                        |
| \(781\) 555-5550 / (781)       |   |         |                        |
| 555-5559                       |   |         |                        |
+--------------------------------+---+---------+------------------------+
| **Discharge in amount          |   |         |                        |
| exceeding 10 gallons and *not  |   |         |                        |
| affecting a waterbody or       |   |         |                        |
| groundwater***                 |   |         |                        |
+--------------------------------+---+---------+------------------------+
| Local Fire Department          |   |         |                        |
|                                |   |         |                        |
| Fire Chief: D. Evans           |   |         |                        |
|                                |   |         |                        |
| \(781\) 555-1258 or 911        |   |         |                        |
+--------------------------------+---+---------+------------------------+
| Massachusetts Department of    |   |         |                        |
| Environmental Protection       |   |         |                        |
|                                |   |         |                        |
| \(888\) 304-1133 or (617)      |   |         |                        |
| 553-1133                       |   |         |                        |
+--------------------------------+---+---------+------------------------+
| ##### Discharge in any         |   |         |                        |
|  amount and affecting (or thre |   |         |                        |
| atening to affect) a waterbody |   |         |                        |
+--------------------------------+---+---------+------------------------+
| Local Fire Department          |   |         |                        |
|                                |   |         |                        |
| Fire Chief: D. Evans           |   |         |                        |
|                                |   |         |                        |
| \(781\) 555-1258 or 911        |   |         |                        |
+--------------------------------+---+---------+------------------------+
| Massachusetts Department of    |   |         |                        |
| Environmental Protection       |   |         |                        |
|                                |   |         |                        |
| \(888\) 304-1133 or (617)      |   |         |                        |
| 553-1133                       |   |         |                        |
+--------------------------------+---+---------+------------------------+
| National Response Center       |   |         |                        |
|                                |   |         |                        |
| \(800\) 424-8802               |   |         |                        |
+--------------------------------+---+---------+------------------------+
| \*Town of Stonefield POTW      |   |         |                        |
|                                |   |         |                        |
| Plant Operator: K. Bromberg    |   |         |                        |
|                                |   |         |                        |
| \(781\) 555-5453               |   |         |                        |
+--------------------------------+---+---------+------------------------+
| Town of Stonefield Drinking    |   |         |                        |
| Water Plant                    |   |         |                        |
|                                |   |         |                        |
| Plant Operator: D. Lopez       |   |         |                        |
|                                |   |         |                        |
| \(781\) 555-5450               |   |         |                        |
+--------------------------------+---+---------+------------------------+
| EZ Clean                       |   |         |                        |
|                                |   |         |                        |
| \(617\) 555-5554               |   |         |                        |
+--------------------------------+---+---------+------------------------+

\* The POTW should be notified of a discharge only if oil has reached or
threatens sewer drains that connect to the POTW collection system.

**APPENDIX J**

**Discharge Response Equipment Inventory**

The discharge response equipment inventory is verified during the
monthly inspection and must be replenished as needed.

**Tank Truck Loading/Unloading Area**

Number range CHAPTERG Empty 55-gallons drums to hold contaminated
material 4

Number range CHAPTERG Loose absorbent material 200 pounds

Number range CHAPTERG Absorbent pads 3 boxes

Number range CHAPTERG Nitrile gloves 6 pairs

Number range CHAPTERG Neoprene gloves 6 pairs

Number range CHAPTERG Vinyl/PVC pull-on overboots 6 pairs

Number range CHAPTERG Non-sparking shovels 3

Number range CHAPTERG Brooms 3

Number range CHAPTERG Drain seals or mats 2

Number range CHAPTERG Sand bags 12

**Maintenance Building**

Number range CHAPTERG Empty 55-gallons drums to hold contaminated
material 1

Number range CHAPTERG Loose absorbent material 50 pounds

Number range CHAPTERG Absorbent pads 1 box

Number range CHAPTERG Nitrile gloves 2 pairs

Number range CHAPTERG Neoprene gloves 2 pairs

Number range CHAPTERG Vinyl/PVC pull-on overboots 2 pairs

Number range CHAPTERG Non-sparking shovels 1

Number range CHAPTERG Brooms 1

Number range CHAPTERG Drain seals or mats 1

**APPENDIX K**

**Agency Notification Standard Report**

Information contained in this report, and any supporting documentation,
must be submitted to the EPA Region 1 Regional Administrator, and to
MADEP, within 60 days of the qualifying discharge incident.

+--------------------------------+-------------------------------------+
| **Facility:**                  | *Unified Oil Company*               |
+--------------------------------+-------------------------------------+
| **Owner/operator:**            | *Blake and Daughters*               |
|                                |                                     |
|                                | *20 Fairview Road*                  |
|                                |                                     |
|                                | *Stonefield, MA 02000*              |
+--------------------------------+-------------------------------------+
| **Name of person filing        |                                     |
| report:**                      |                                     |
+--------------------------------+-------------------------------------+
| **Location:**                  | *123 A Street*                      |
|                                |                                     |
|                                | *Stonefield, MA 02000*              |
+--------------------------------+-------------------------------------+
| **Maximum storage capacity:**  | *74,600 gallons*                    |
+--------------------------------+-------------------------------------+
| **Daily throughput:**          | *8,000 gallons*                     |
+--------------------------------+-------------------------------------+
| **Nature of qualifying         |                                     |
| incident(s):**                 |                                     |
|                                |                                     |
| G Discharge to navigable       |                                     |
| waters or adjoining shorelines |                                     |
| exceeding 1,000 gallons        |                                     |
|                                |                                     |
| G Second discharge exceeding   |                                     |
| 42 gallons within a 12-month   |                                     |
| period.                        |                                     |
+--------------------------------+-------------------------------------+
| **Description of facility      |                                     |
| (attach maps, flow diagrams,   |                                     |
| and topographical maps):**     |                                     |
|                                |                                     |
| *Unified Oil distributes a     |                                     |
| variety of petroleum products  |                                     |
| to primarily commercial        |                                     |
| customers. The facility        |                                     |
| handles, stores, uses, and     |                                     |
| distributes petroleum products |                                     |
| in the form of gasoline,       |                                     |
| diesel, No. 2 fuel oil, No. 6  |                                     |
| fuel oil, and motor oil.       |                                     |
| Unified Oil receives products  |                                     |
| by common carrier via tanker   |                                     |
| truck. The products are stored |                                     |
| in five aboveground storage    |                                     |
| tanks (ASTs) and in one        |                                     |
| underground storage tank       |                                     |
| (UST). They are delivered to   |                                     |
| customers by Unified Oil       |                                     |
| trucks or by independent       |                                     |
| contractors. The facility      |                                     |
| refuels its own two delivery   |                                     |
| trucks from an underground     |                                     |
| diesel tank connected to a     |                                     |
| fueling pump.*                 |                                     |
|                                |                                     |
| *Unified Oil is located in a   |                                     |
| primarily commercial area at   |                                     |
| 123 A Street in Stonefield,    |                                     |
| Massachusetts. The site is     |                                     |
| comprised of approximately 2   |                                     |
| acres of land and is bordered  |                                     |
| to the East by A Street, to    |                                     |
| the West by Silver Creek, and  |                                     |
| to the North by ABC Plating    |                                     |
| Co.*                           |                                     |
|                                |                                     |
| *Site improvements include an  |                                     |
| office building, a maintenance |                                     |
| shop, a tanker truck loading   |                                     |
| rack and unloading area, and   |                                     |
| product storage and handling   |                                     |
| areas. Petroleum products are  |                                     |
| stored in the bulk storage     |                                     |
| area, the maintenance          |                                     |
| building, and the office       |                                     |
| building.*                     |                                     |
+--------------------------------+-------------------------------------+

  -----------------------------------------------------------------------
  **Agency Notification Standard Report (cont'd)**

  **Cause of the discharge(s), including a failure analysis of the system
  and subsystems in which the failure occurred**:

  **Corrective actions and countermeasures taken, including a description
  of equipment repairs and replacements:**

  **Additional preventive measures taken or contemplated to minimize
  possibility of recurrence:**

  **Other pertinent information:**
  -----------------------------------------------------------------------