Annual Briefing:Spill Prevention Control and

Countermeasure Plan (SPCC)

Managed Services AdministrationFreeport, Texas____________________

281458_365

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

Desired Outcome – Understanding and knowledge of:

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

months)– Facility’s SPCC Plan Changes

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

Overview

SPCC Introduction– Spill Prevention Control and

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

– SPCC regulates the storage of Oil*

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

*Oil as defined by 40 CFR Part 112

Overview

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

– Potential for oil to get to the water

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

• Any container whose capacity is less than 55 gallons

• Permanently closed containers

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

MSA Applicability

Dow has a Work Process to determine SPCC Oils.

 

    

Our Facility’s SPCC Oils

SPCC Bulk Oil Containers

Location Total Oil Quantity (Gal.)

Mobile Gasoline Tank A-715 Scaffold Yard 500 gal tank

Mobile Gasoline Tank B-5401 Scaffold Yard 500 gal tank

Mobile Gasoline Tank OC-905 500 gal tank

Bulk Storage (In Service)

Our Plant’s SPCC Oils

Electrical Equipment (In Service)

Electrical Equipment

Location Total Oil Quantity (Gal.)

T-3605 Transformer B-3605 618 gal

T-2414 Transformer B-2404 180 gal

T-5008 Transformer B-5008 250 gal

T-5401 Transformer B-5401 Scaffold Yard 117 gal

A-915 Transformer A-915 166 gal

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

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

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

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

Lesson Summary

Inspection Requirements:– Inspection for oil sheen or other

contamination before draining the diked area is required.

– Use Rain Water Discharge Checklist

– Assign appropriate WPN as needed

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

SPCC Plan Requirements

Inspection Requirements: – Oil storage vessels (including

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

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

– Routine GMISS inspections as applicable

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

SPCC Plan Requirements

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

 

    

Review of SPCC Oil LOPC’s

SPCC Oil LOPC

LOPC Quantity

(Gal)

Location Primary Cause

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

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

 

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

 

Facility’s SPCC Oil Management Learnings

• Developed NEW SPCC Plan including:

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

Key Learning Points –

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

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

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

Lesson Summary

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

 

    

Review of SPCC Oil Plan Changes

SPCC Oil Event

Primary Contact

Location Follow-Up Actions

Developed and

implemented new SPCC

plan

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

Certified by PE, and implemented through

MOC

Our Facility’s SPCC Plan Changes

Key Learning Points –

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

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

Lesson Summary

Revision History

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

  Date Revised By Changes

 

6/11/2011 N. Wisby Created training

 

8/15/2011 Karin Slough Made ready for MyLearning

10/27/2014 Jennifer Hill Revised due to SPCC update