Annual review of plan with oil handling employees. A person who reports to facility management is designated and accountable for discharge prevention. [§112.7(f)] Name/Title: Bobby Taylor, Maintenance Manager Discharge prevention briefings are conducted for oil-handling personnel annually to assure adequate understanding of the SPCC Plan for that facility. Such briefings highlight and describe past reportable discharges or failures, malfunctioning components, and any recently developed precautionary measures. [§112.7(f)] ABC has defined oil-handling personnel to include Production Supervisors and Maintenance Employees. These employees will review the SPCC plan and Spill Work Instruction annual and records shall be maintained. All employees are trained at the time of hire on how to respond to oil leaks and spills. Employees can respond to leaks and spills <5 gallons. Spills >5 gallons employees are required to notify the Production Supervisor or Maintenance personnel. Security (excluding oil production facilities) (§112.7(g)): G-6 Implementation and Description of Security Measures Security measures are implemented at this facility to prevent unauthorized access to oil handling, processing, and storage area. The following is a description of how you secure and control access to the oil handling, processing and storage area; secure master flow and drain valves; prevent unauthorized access to starter controls on oil pumps; secure out-of-service and loading/unloading connections of oil pipelines; address the appropriateness of security lighting to both prevent acts of vandalism and assist in the discover of oil discharges: The facility is currently in operation on 3 shifts and typically 5 days per week. All Oil storage containers are within the building. Access to the facility is controlled and only authorized employees are permitted access. When the facility is not operating it is completely secured and has an alarm system. Emergency Procedures and Notifications (§112.7(a)(3)(iv) and 112.7(a)(5)): Table G-7 Description of Emergency Procedures and Notifications The following is a description of the immediate actions to be taken by facility personnel in the event of a discharge to navigable waters or adjoining shorelines [§112.7(a)(3)(iv) and 112.7(a)(5)]: Work Instruction WI 44444 defines the spill response process. This includes the following actions by the Shift Supervisor on-site: spill socks around area to contain oil
required per industry inspection standards 10Examples of leak detection include, but are not limited to, double-walled tanks and elevated containers where leaks can be visually identified. Attachment 3.3 – Dike Drainage Log – NOT APPLICABLE TO THIS FACILITY Table G-18 Dike Drainage Log Date Bypass valve sealed closed Rainwater inspected to be sure no oil (or sheen) is visible Open bypass valve and reseal it following drainage Drainage activity supervised Observations Signature of inspector Not Required Attachment 3.4 – Oil-handling Personnel Training and Briefing Log Table G-19 Oil-handling Personnel Training and Briefing Log Date Attendees Initial SPCC training, SPCC requirements, maintenance of SPCC Plan xxxxxx – Materials Manager/EMS Rep xxxxxxx – Quality Manager xxxxxxx - Maintenance Manager, EMS Coordinator ATTACHMENT 4 – Discharge Notification Form