Security Sensitive Information Redacted, Version

Transcription

1 Albany Spill Prevention Control and Countermeasure Plan Albany Spill Prevention Control and Countermeasure Plan Albany Spill Prevention Control and Countermeasure Plan

2 Buckeye Albany Terminal, LLC. Albany Spill Prevention Control and Countermeasure Plan 301 Normanskill Road, Port of Albany Albany, NY 12202

3 Albany SPCC - 1 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN Last revised: December 2014 Technical Response Planning Corporation Introduction Figure Professional Engineer Certification Figure Certification & Applicability of Substantial Harm Figure Management Approval and Review Figure SPCC Review Record Figure Addendum 2.1 Spill Prevention And Control Measures - Compliance With SPCC Regulations 40 CFR, (a) General Facility Requirements 40 CFR, (b) Prediction Of The Direction, Rate Of Flow, And Total Quantity Of Oil Which Could Be Discharged From The Facility As A Result Of Each Type Of Major Equipment Failure 40 CFR, (c) Provide appropriate Containment 40 CFR, (d) Identification Of Impractical Controls 40 CFR, (e) Inspections, Tests, And Records 40 CFR, (f) Personnel Training And Discharge Prevention Procedures 40 CFR, (g) Security 40 CFR, (h) Facility Tank Car And Tank Truck Loading/Unloading Rack 40 CFR, (i) Brittle Fracture Evaluation Requirements

4 Albany SPCC - 2 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN, CONTINUED - Compliance With SPCC Regulations, Continued 40 CFR, (j) State Discharge Prevention Requirements 40 CFR, (k) Qualified Oil-Filled Operational Equipment 40 CFR, (a) General Requirements 40 CFR, (b) Facility Drainage 40 CFR, (c) Bulk Storage Containers 40 CFR, (d) Facility Transfer Operations, Pumping, And Facility Processes Figure Potential Spill Sources/ Containers Of Oil Figure Facility Diagram Figure Survey Diagram Figure Piping Diagram Figure Permeability Study Figure Reportable Spill History 3.1 Countermeasures And Spill Response Practices Figure Response Actions 3.2 Source Control and Mitigation Figure Spill Mitigation Procedures 3.3 Spill Volume Estimating Figure Spill Estimation Factors 3.4 Notifications Figure Spill / Incident Telephonic Notice Figure Notifications and Telephone Numbers

5 Albany SPCC - 3 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN, CONTINUED 3.5 Incident Management Team Figure Incident Management Team Organization 3.6 Response Resources Figure Company and Contractor Response Resources 3.7 Command Post Figure Command Post Checklist 3.8 Communications Figure Communications Checklist 3.9 Waste Management Figure Waste Management Flow Chart Figure Temporary Storage Methods 4.1 Sample Logs Figure Discharge Prevention Meeting Log Figure Inspection Procedures Figure Annual Inspection Record Figure Secondary Containment Drainage Log 5.1 Cross-References Figure EPA / SPCC Cross-Reference Figure EPA / Contingency Plan Cross-Reference 6.1 Additional Information 7.1 Record of Changes Figure Record of Changes

6 Albany SPCC INTRODUCTION FIGURE PROFESSIONAL ENGINEER CERTIFICATION 40 CFR, Part 112.3(d) Professional Engineer Certification 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. This SPCC Plan has been prepared for the exclusive use of Buckeye Albany Terminal and should be used only for the purpose for which it was intended. Should the user of this report change, the certification is no longer valid and the new user must comply with requirements outlined under 40 CFR 112. If conditions at the facility have changed as they were on the date of the field visit, then this Plan may no longer be applicable and the certification may not be valid unless the plan is updated in accordance with the regulations and updated conditions at the site. The work was performed using the standard of care and level of skill ordinary exercised under similar circumstances. No warranty expressed or implied is made as to the conclusions and professional advice included in this report. The findings presented are relative to the dates of our site work and information provided by the facility and should not be relied on to represent conditions at substantially later dates or under different management or ownership. Other plans referred to in this SPCC Plan were provided by the facility. The references may no longer apply if changes are made to those plans after the date of this certification. The facility is not in compliance for the following areas: The North Tank Farm is has cracks that are being sealed. Once sealed, according to the Secondary Containment Assessment report dated July 2009 certified by EMS Environmental, once sealed, the containment is sufficiently impervious. Note: Certification is conditional pending satisfactory resolution of the required improvements listed in FIGURE Addendum. Printed Name of Registered Professional Engineer: Signature of Registered Professional Engineer: Date: Registration No.: Seal: Gianna Aiezza , New York

7 Albany SPCC - 5 FIGURE CERTIFICATION & APPLICABILITY OF SUBSTANTIAL HARM Does the facility transfer oil over water to or from vessels and does the facility have a total oil storage capacity greater than or equal to 42,000 gallons? Yes Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and, within any storage area, does the facility lack secondary containment that is sufficiently large enough to contain the capacity of the largest above ground oil storage tank plus sufficient freeboard to allow for precipitation? No 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 Appendix C-III (59 FR 34105) or a comparable formula] such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments? Yes 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 Appendix C or a comparable formula) such that a discharge from the facility would shut down a public drinking water intake? No 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? No 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 information, I believe that the submitted information is true, accurate, and complete. Signature: Name: Title: James Allen Date: 11/14/2013 Lead Terminal Operator

8 Albany SPCC - 6 FIGURE MANAGEMENT APPROVAL AND REVIEW I hereby approve the contents of the Facility's Spill Prevention, Control, and Countermeasure Plan (SPCC Plan) and have the authority to commit the necessary resources to implement the SPCC Plan, as set forth in this document, in accordance with the federal requirements of 40 CFR Part 112. Name: Title: Signature: Date:

9 Albany SPCC - 7 FIGURE SPCC REVIEW RECORD RECORD OF REVIEWS Date of Review 1 Will Plan Need Amendment? 2 Reviewer's Signature 3 Reason for Amendment 4 Full Partial Yes / No Date of Amendment (or N/A) 1 A full review of the plan must be performed at least once every five years. 2 The SPCC plan must be amended when there is a change in the facility design, construction, operation, or maintenance that materially affects its potential for a discharge. Examples include, but are not limited to: commissioning or decommissioning containers; replacement, reconstruction, or movement of containers; reconstruction, replacement, or installation of piping systems; construction or demolition that might alter secondary containment structures; changes of product or service; or revision of standard operation or maintenance procedures. 3 Reviewer's signature indicates that he/she has completed review and evaluation of the SPCC plan for [Albany] on the date indicated and will or will not amend the plan as a result, as indicated. 4 Briefly describe reasons for plan amendment. These may include one or more of the reasons in footnote 2, above, administrative changes such as updates to names or phone numbers, regulatory changes, or changes in Company policies. A Professional Engineer must certify any technical amendments.

10 Albany SPCC - 8 FIGURE ADDENDUM Certification of this Spill Prevention Control and Countermeasure plan is contingent upon correction of all discrepancies listed in this Addendum. The discrepancies for this facility are: REGULATION 40 CFR (c) DISCREPANCY The North Tank Farm has cracks that are being sealed. Once sealed, according to the Secondary Containment Assessment report dated July 2009 certified by EMS Environmental, once sealed, the containment is sufficiently impervious. PLAN OF ACTION ESTIMATED TIME TO COMPLETE DATE COMPLETED

11 Albany SPCC SPILL PREVENTION AND CONTROL MEASURES FIGURE COMPLIANCE WITH SPCC REGULATIONS FACILITY INFORMATION Name of Facility: Albany Type of Facility: Onshore/Non Production Location of Facility: Latitude/ Longitude: General Facility Description: 301 Normanskill Road, Port of Albany Albany, NY ' 2.44 '' N ' '' W Name & Address of Owner or Operator: Designated Personnel Accountable for Oil Spill Prevention at the Facility: Buckeye Albany Terminals, LLC Port of Albany Albany, NY James Allen 40 CFR Oil means oil of any kind or in any form, including, but not limited to: fats, oils, or greases of animal, fish, or marine mammal origin; vegetable oils, including oils from seeds, nuts, fruits, or kernels; and, other oils and greases, including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with wastes other than dredged spoil.

12 Albany SPCC - 10 FIGURE COMPLIANCE WITH SPCC REGULATIONS 40 CFR, (a) GENERAL REQUIREMENTS (1) Include a discussion of your facility's conformance with the requirements listed in this part This SPCC plan has been prepared in accordance with good engineering practices and the sequence specified in 40 CFR Part 112. The Plan has the full approval of management and the commitment to providing the necessary resources to fully implement the plan. In addition, the Terminal operates in compliance with the petroleum bulk storage requirements listed in 6 NYCRR 610 through 614. The specific requirements are detailed in bulleted responses below. (2) Comply with all applicable requirement listed in this part. Your Plan may deviate from some requirements if you provide additional protection or explanation Requirements are addressed below. Any deviations are described in the appropriate sections and include (1) the reason for nonconformance, (2) the alternative method or practice, (3) a description of how the alternative method or practice achieves equivalent environmental protection. (3) You must also address in your plan: The facility is an Onshore/Non-Production facility; refer to FIGURES 2.1-3, 2.1-4, and for the facility diagrams. Refer to Facility Information above for the general facility description. If a release is detected and judged by the Qualified Individual to warrant the use of contracted resources, the Company has established a contractual agreement with the OSROs listed in FIGURE Refer to FIGURE for response times. i.the type of oil in each container and its storage capacity Refer to FIGURE 2.1-2, Potential Spill Sources. The petroleum storage tanks at the Buckeye Albany Terminal are registered under the provisions of 6 NYCRR Part 610, "Certification of Onshore Major Oil Facilities" (MOSF). The closest water body to the Terminal is the Hudson River, located in the immediate vicinity to the Terminal. In the event of the most probable spill it is unlikely that the Hudson River will be adversely impacted, as spilled material would be contained by the tankfield, rail offloading and/or tank truck loading rack containment areas as described in 40 CFR 112.7(c). These tanks are operated under the provisions of 6 NYCRR Part 613, "Handling and Storage of Petroleum". The tanks are managed in accordance with the applicable requirements of 6 NYCRR 613 for overfill protection and secondary containment, monthly inspections of aboveground storage facilities and inspection reports. Tank closures and future installations will be conducted under the provisions of 6 NYCRR Part The facility maintains a current MOSF License Number for oil storage tanks as identified in FIGURE Any new or substantially modified tanks will be constructed, designed and installed pursuant to the provisions of 6 NYCRR Part 614, "Standards for New and Substantially Modified Petroleum Storage Facilities".

13 Albany SPCC - 11 FIGURE COMPLIANCE WITH SPCC REGULATIONS, CONTINUED 40 CFR, (a) GENERAL REQUIREMENTS i.the type of oil in each container and its storage capacity In the event of a release of oil outside of secondary containment, immediate action to contain the oil would be taken. The nearest water body is the Hudson River and the Terminal has an OSRO contract with an Emergency Spill contractor for immediate oil spill response. ii.discharge prevention measures Specific discharge prevention measures are listed in Sections 40 CFR 112.7(h), 112.8(d)(1) and 112.8(c)(8) of this Plan. As noted in section 112.7(a) (1) of this SPCC plan, the tanks are regulated under the provisions of 6 NYCRR Part 610 "Certification of Onshore Major Oil Facilities". iii.discharge or drainage controls such as secondary containment around containers and other structures, equipment, and procedures for the control of a discharge Refer to FIGURE CFR (b). The above ground oil storage tanks, rail offloading areas and truck loading/unloading rack operated at the Terminal have appropriate containment identified in 112.7(c) to prevent discharged oil from reaching navigable waters. Deviations from this requirement are listed in Figure Addendum. Fill port overflow protection is provided. Offloading procedures are in section 112.7(c) of this plan. iv.countermeasures for discharge discovery, response, and cleanup (both the facility's capability and those that might be required of a contractor) Refer to SECTION 3.1. A spill at these tanks could most likely occur during fill operations. These operations occur under constant personnel supervision; therefore spills would be detected promptly. Any minor spills that could occur would collect in secondary containment areas or fill port overfill protection and be immediately cleaned up. Any soils impacted by oil will be removed and disposed of in accordance with all Federal, State and local regulations. Any circumstance noted by Terminal personnel with the potential for oil discharge is addressed immediately. Site personnel will respond and assess the incident. Terminal personnel will provide response including controlling the spill, containing the spill and initiating clean up. An environmental remediation contractor will be called for any spills that cannot be handled by Terminal personnel. The cleanup responsibility for Terminal personnel will be limited to small spills that are contained on land within the facility. The cleanup procedure will consist of placing either absorbents (e.g. Speedi-dri, absorbent socks and/or pads) or soil material on the spilled product to contain and absorb it. The absorbent material will then be collected, properly classified and disposed of in accordance with all local, State and Federal laws. Large spills and/or those that may enter the Hudson River, will be immediately reported to the Qualified Individual and the Emergency Spill Contractors will be notified to commence with the emergency cleanup in accordance with the OSRO contract and the Terminal Facility Response Plan. v.methods of disposal of recovered materials Refer to SECTION 3.9 Waste Management.

14 Albany SPCC - 12 FIGURE COMPLIANCE WITH SPCC REGULATIONS, CONTINUED 40 CFR, (a) GENERAL REQUIREMENTS v.methods of disposal of recovered materials Absorbent material is located in the storage building at the Terminal. The primary objective is to recover any spilled oil for reuse where feasible. Any oil or contaminated oily materials unable to be recycled or reused will be disposed of in accordance with all Federal, State and local requirements. vi.contact list and phone numbers for responding to a spill or emergency Refer to FIGURE (4) Unless you have submitted a response plan, provide information and procedures to report a discharge A Facility Response Plan (FRP) has been submitted to the regional administrator. The Terminal maintains a Facility Response Plan in accordance with the regulations, 40 CFR and As required under this section, the following information is provided and must be collected in the event of a spill: Exact location of facility, Phone Number of Facility (Caller must give their specific telephone number), Date of Discharge, Time of Discharge, Type of Material Discharged, Estimate of Total Quantity, Source of Discharge, Affected Media, Cause of Discharge, Damages or Injuries, Actions to Stop, Remove and Mitigate Discharge, Necessity for Evacuation, Organizations Contacted. (5) Unless you have submitted a response plan, describe procedures you will use when a discharge occurs A Facility Response Plan (FRP) has been submitted to the regional administrator. The person responsible for oil spill prevention and containment is the Terminal Supervisor FSO/Qualified Individual. He is accountable for implementing the procedures described in the facility's "Spill Prevention Control and Countermeasure Plan". The Facility Response Plan (FRP) for the Terminal provides complete oil spill contingency plans. Additional information in the FRP includes copies of the emergency spill response contracts, Qualified Individual certification and exercise logs. The Terminal personnel will respond to an oil spill at the facility. If additional assistance is required, an emergency response contractor will be called for cleanup services. Crude oil and ethanol products are delivered by railroad. Asphalt products are delivered by rail and marine vessels (on the Hudson River). Ethanol and asphalt products are offloaded at the tank truck unloading areas and at the marine transfer station along the shoreline of this terminal. Crude oil is loaded at the marine transfer station. The transfers are always made when Terminal personnel are on site. A spill at these locations is most likely to occur during the offloading/filling operations. Strict procedures are in place in the Facility Response Plan to ensure immediate discovery and response to a spill. Emergency spill response equipment is located at the storage building at the terminal and additional emergency spill response contracts are in place with a contractor able to provide the level of assistance required to respond to a worst case discharge at the Terminal. (b) PREDICTION OF THE DIRECTION, RATE OF FLOW, AND TOTAL QUANTITY OF OIL WHICH COULD BE DISCHARGED FROM THE FACILITY AS A RESULT OF EACH TYPE OF MAJOR EQUIPMENT FAILURE The potential spill sources at the facility are summarized in FIGURE Following is an analysis of the probability of a spill occurring at the Terminal. This analysis is quantitative, and addresses such factors as tank age, spill history, horizontal range of a potential spill, and vulnerability to natural disaster.

15 Albany SPCC - 13 FIGURE COMPLIANCE WITH SPCC REGULATIONS, CONTINUED 40 CFR, (b) PREDICTION OF THE DIRECTION, RATE OF FLOW, AND TOTAL QUANTITY OF OIL WHICH COULD BE DISCHARGED FROM THE FACILITY AS A RESULT OF EACH TYPE OF MAJOR EQUIPMENT FAILURE Source: Storage Tanks No. 6 Fuel Oil. Major Type Of Failure: Rupture. Total Quantity (Gallons): 201,600 9,897,804. Rate (Gallons Per Hour): Variable. Direction Of Flow: Onto Ground. Secondary Containment: Tank farm containment area. Source: Storage Tanks Asphalt. Major Type Of Failure: Rupture. Total Quantity (Gallons): 196,392-3,289,873. Rate (Gallons Per Hour): Variable. Direction Of Flow: Onto Ground. Secondary Containment: Tank farm containment area. Source: Storage Tanks Gasoline/Ethanol or Gasoline. Major Type Of Failure: Rupture. Total Quantity (Gallons): 2,462,376 7,114,338. Rate (Gallons Per Hour): Variable. Direction Of Flow: Onto Ground. Secondary Containment: Tank farm containment area. Source: Storage Tanks. Major Type Of Failure: Bottom Leakage. Total Quantity (Gallons): 196,392-9,897,804. Rate (Gallons Per Hour): Variable. Direction Of Flow: Into Ground. Secondary Containment: -. Source: Storage Tanks. Major Type Of Failure: Water draw off valve. Total Quantity (Gallons): 9,897,804. Rate (Gallons Per Hour): 840,000. Direction Of Flow: Onto ground and into sump system. Secondary Containment: Tank farm containment area & oily water treatment system. Source: Storage Tanks. Major Type Of Failure: Overfill. Total Quantity (Gallons): 196,392. Rate (Gallons Per Hour): 504,000. Direction Of Flow: Onto ground. Secondary Containment: Tank farm containment area. Source: Pipeline System (In dike area). Major Type Of Failure: Leak or rupture of line. Total Quantity (Gallons): 12,600-50,400. Rate (Gallons Per Hour): 126, ,000. Direction Of Flow: Onto ground. Secondary Containment: Containment area. Source: Pipeline System (Outside dike area). Major Type Of Failure: Leak or rupture of line. Total Quantity (Gallons): 12,600-50,400. Rate (Gallons Per Hour): 126, ,000. Direction Of Flow: Onto ground. Secondary Containment: Catch basin system for drainage. Source: Tank Farm Pumps. Major Type Of Failure: Leak at seal. Total Quantity (Gallons): -. Rate (Gallons Per Hour): Direction Of Flow: Onto ground & water collection sump. Secondary Containment: Containment area. Source: Tank Truck. Major Type Of Failure: Equipment failure (normal drippage to tank rupture). Total Quantity (Gallons): 42-7,980. Rate (Gallons Per Hour): 21,000-29,400. Direction Of Flow: To drainage collection structure. Secondary Containment: Drainage collection system/oil water treatment system. Source: Tank Truck. Major Type Of Failure: Overfill. Total Quantity (Gallons): 210. Rate (Gallons Per Hour): 21,000-29,400. Direction Of Flow: To drainage collection structure. Secondary Containment: Loading rack containment. Source: Tank Car at the North rail spur. Major Type Of Failure: Equipment failure (normal drippage to tank rupture). Total Quantity (Gallons): Variable. Rate (Gallons Per Hour): -. Direction Of Flow: Onto ground. Secondary Containment: Site containment.

16 Albany SPCC - 14 FIGURE COMPLIANCE WITH SPCC REGULATIONS, CONTINUED 40 CFR, (b) PREDICTION OF THE DIRECTION, RATE OF FLOW, AND TOTAL QUANTITY OF OIL WHICH COULD BE DISCHARGED FROM THE FACILITY AS A RESULT OF EACH TYPE OF MAJOR EQUIPMENT FAILURE Source: Tank Car Unit Train. Major Type Of Failure: Equipment failure (leak to rupture). Total Quantity (Gallons): Variable. Rate (Gallons Per Hour): 58,800. Direction Of Flow: Onto ground. Secondary Containment: Spill pan containment system and holding tanks Tank 17 and 18. The following assumptions were made in calculation of the total quantity spilled. Barrels are equivalent to 42 gallons. Storage Tanks (Rupture) Amount varies. Quantities listed reflect minimum and maximum tank volumes at the facility. Storage Tanks (Bottom Leakage) 4676 to 253,780 barrels (or 196,392-10,658,760 gallons). Amount of Spill ranges from smallest tank volume (Tanks 5, 6 and 7) to largest tank volume (Tank 25). Storage Tanks (Water Draw off Valve) 253,780 barrels (or 10,658,760 gallons). Amount of spill is predicted from a valve failure of the largest tank (Tank 25). Storage Tanks (Overfill) 6,000 barrels (or 252,000 gallons). The overfill period was predicted to occur over a 30 minute duration at a rate of 12,000 barrels per hour. With level detection devices at the facility, the response time will be much less than this time. The 30 minute duration indicates the failure response time and the communication and reaction times to correct the problem. Pipeline System (Leak or Rupture of Line) In dike area and outside dike area 300 to 1,200 barrels (or 12,600 50,400 gallons). The leak or rupture period was predicted to occur over a one-tenth of an hour period. Small leaks would not be detected as quickly as a rupture during transfer. With the means of closing a valve, a pipeline rupture problem would be isolated very quickly. Tank Farm Pumps (Leak at Seal). Rate of spill for seal leak is estimated to be 1 to 2 gallons per minute or 1.5 to 3 barrels (or gallons) per hour. Tank Truck (Equipment Failure) 1 to 190 barrels ( gallons). Rate of spill is 500 to 700 barrels (or 21,000 29,400 gallons) per hour. Total quantity spilled ranges from a very small amount to the total contents of the tank truck 190 barrels (or 8,000 gallons). Tank Truck (Overfill) 5 barrels (or 210 gallons). Assuming that an overfill occurs, the truck driver estimated response time - within 30 seconds. At a rate of 500 barrels per hour times one-half minute, the total spilled amount would equal 5 barrels (or 210 gallons). The following discussion is for each source of spill in order to detail existing conditions and equipment, proposed improvements, problems that may develop and methods and means of containment and control. Storage Tanks (Rupture) The storage tanks are monitored by the tank monitoring system 24 hours per day for any irregularities or accidental discharge caused by material failures. During working hours operating personnel make regular rounds to the tanks, not only to maintain security but at the same time immediately contact the shift supervisor of any spills or discharges.

17 Albany SPCC - 15 FIGURE COMPLIANCE WITH SPCC REGULATIONS, CONTINUED 40 CFR, (b) PREDICTION OF THE DIRECTION, RATE OF FLOW, AND TOTAL QUANTITY OF OIL WHICH COULD BE DISCHARGED FROM THE FACILITY AS A RESULT OF EACH TYPE OF MAJOR EQUIPMENT FAILURE Storage Tanks (Rupture) - There are three tank farms at the Terminal: South Tank Farm, Central Tank Farm and North Tank Farm. The South Tank Farm contains Tanks 21, 22, 23 and 24. The Central Tank Farm contains Tanks 1, 2, 3, 4, 5, 6, 7, 8, 9, 25, 26, 30, 38, 39, 40, 46, V101,V102,V103, and V104. The North Tank Farm contains Tanks 31, 32, 33, 34, 35, 36 and 37. Storage Tanks (Rupture) - The secondary containment system of the South Tank Farm consists of a dike lined (on the floor and walls) with HDPE liner. The approximate capacity of the containment dike is 7,450,080 gallons. The secondary containment dike provides capacity for the contents of the largest Tank A-21 (6,073,760 gallons) and sufficient freeboard to contain precipitation. The containment dike is sufficiently impervious so that a discharge will not escape the containment system before clean-up occurs. The containment calculations are provided in FIGURE Storage Tanks (Rupture) - The Central Tank Farm secondary containment system consists of the shared capacity of the Central and South Tank Farms. The South and Central Tank Farms are connected by an intermediate dike set at an elevation of 19.5' to provide shared containment capacity, so that in the event of a large spill, the spilled product from the Central Tank Farm could flow into the South Tank Farm dike. The product would flow into the South Farm over the intermediate dike. The intermediate dike has lower elevation (set at elevation of 19.5') than the Central Tank Farm secondary containment dike (set at elevation of 19.8'). The approximate shared capacity of the Central containment dike is 16,792,600 gallons. The secondary containment dike provides capacity for the contents of the Tank A-25 (10,659,000 gallons) and sufficient freeboard to contain precipitation. According to the Secondary Containment Assessment report date July 2009 and certified by EMS Environmental. the containment dike is sufficiently impervious so that a discharge will not escape the containment system before clean-up occurs. The containment calculations are provided in FIGURE The containment calculations are provided in FIGURE Storage Tanks (Rupture) - The North Tank Farm secondary containment system (in which Tanks A-31, A-32, A-33, A-34, A-35, A-36 and A-37 are located) consists of a sealed asphalt liner on the containment floor surrounded by a concrete dike wall. The approximate capacity of the containment dike is 7.6 million gallons. The secondary containment dike provides capacity for the contents of the largest Tank 31 or 32 (7,114,338 gallons) and sufficient freeboard to contain precipitation. The containment calculations are provided in FIGURE According to the "Secondary Containment Assessment" report date July 2009 and certified by EMS Environmental, the North Tank Farm secondary containment dike is sufficiently impervious when cracks are properly sealed. The facility is currently in the process of sealing cracks to comply with permeability requirements. Storage Tanks (Bottom Leakage) - The facility staff continuously monitors the status of the tanks 24 hours per day. A Varec automatic tank monitoring system with main control center located in the control room provides the tank status information for the tanks. Storage Tanks (Bottom Leakage) - The tank monitoring system provides an up to the minute display of each tank contents. Monday through Friday a daily print out is obtained. Data for Friday, Saturday and Sunday is lumped together and reviewed Monday morning. Any irregularities are detected daily with prompt notification to the shift supervisor for a system or tank check. Storage Tanks (Bottom Leakage) - Daily records are then accumulated monthly for the thirty-day check. The Company staff gauges tanks monthly, checks mechanical gauges located at the side of the tanks and finally makes a check of records for a three-fold monthly material balance. The material balance will show a very small change in tank volume that the Varec system will not indicate until the volume of the tank reaches the present low level or a substantial loss of product. Storage Tanks (Bottom Leakage) - The Varec system contains a high/low audible and visual alarm, which sounds and displays by flashing light at a preset level at the control center. The operator acknowledges the alarm and must satisfy built-in requirements for solving the problems or the alarm will reactivate. Storage Tanks (Bottom Leakage) - Tanks that do not have the Varec system with the high/low audible and visual alarms are visibly monitored hourly by Terminal personnel. Storage Tanks (Bottom Leakage) - Tanks 22, 23 and 24 are double-bottomed and have cathodic protection and leak detection tubes installed. Storage Tanks (Bottom Leakage) - Periodically, tanks are taken out of service and are emptied of their contents. The tanks are cleaned by a professional tank cleaning firm and inspected by certified inspectors to determine the extent of corrosion to the steel. Tank inspection reports are located in the Terminal office. Storage Tanks (Bottom Leakage) - Periodic inspections and non-destructive testing is performed on required l tanks in accordance with API 653 procedures and the NYS Petroleum Bulk Storage requirements.

18 Albany SPCC - 16 FIGURE COMPLIANCE WITH SPCC REGULATIONS, CONTINUED 40 CFR, (b) PREDICTION OF THE DIRECTION, RATE OF FLOW, AND TOTAL QUANTITY OF OIL WHICH COULD BE DISCHARGED FROM THE FACILITY AS A RESULT OF EACH TYPE OF MAJOR EQUIPMENT FAILURE Storage Tanks (Overfill) - The following tanks have internal floating roofs (Tank No. - Contents): 21 - Gasoline / Ethanol, 22 - Gasoline / Ethanol, 23 - Gasoline / Ethanol, 24 - Gasoline / Ethanol, 31 Crude oil, 32 Crude oil, 33 Crude oil, 34 - Ethanol, 35 - Ethanol, 36 Crude oil, 37 - Ethanol. Storage Tanks (Overfill) - Storage tanks 31, 32, 33 and 34 are equipped with Varec automatic tank gauging system as well as "hi" and "high high" level alarm. Storage Tanks (Overfill) - Tanks 21, 22, 23 and 24 have Magnetrol automatic level gauging, as well as a high and high-high level alarm system. Storage Tanks (Overfill) - Should overfilling occur, that is, an alarm failure and feeding pumps are not shut down allowing tanks to overfill, the spill will be contained by the secondary containment system. Storage Tanks (Overfill) - Tanks that do not have the Varec system with the high/low audible and visual alarms are visibly monitored before, during and after a transfer of product by Terminal personnel. Tank levels are recorded before and after transfers. Pipeline System (Leak or Rupture of Line) - All product lines are charged all the time except for the asphalt lines. Pipeline System (Leak or Rupture of Line) - Dedicated lines are labeled at the Terminal. Several lines (i.e. asphalt and #6 oil) are not labeled because they are multipurpose and the Company requires that operators must trace lines prior to transfer operations. Tracing assures that pumping occurs to the correct tank and all valves are either closed or opened depending on intended direction of flow. Any detected leaks are immediately isolated and repaired with minimal shutdown and spilled liquid. Pipeline System (Leak or Rupture of Line) - Line rupture would cause an immediate spill from all charged pipelines. All pipelines within the dikes or walled containment areas would have complete spill containment as repairs are undertaken. Ruptured lines would be isolated from the system before an extensive spill would occur. Pipelines rupturing outside diked containment would cause spilled liquid to enter the storm water drainage (SPDES) system for removal. Tank Farm Pumps (Leak at Seal) - All pumps are routinely inspected on a regular basis to determine operation and leakage. The maintenance staff is notified by operators of any problems or leaks that require immediate attention. Operators stop the leaks immediately and the maintenance staff correct the problems on a priority basis. Tank Truck (Overfill) - Sand and absorbent materials are stored in the storage building located south of the loading area for cleanup and removal of small spills. Tank Truck (Overfill) - The Terminal maintains a closed circuit television system at the main gate and at each tank truck bay. All loading operations are monitored with the closed circuit television system to maintain continuous visual contact. Bay A is the scale which is within the Terminal operator's vision. Any irregularities or problems are immediately detected and pumps can be shut down instantly. Tank Truck (Overfill) - The tank truck loading rack is equipped with a Scully electronic overfill protection system which minimized the likelihood of an overfill. This spill prevention system is plugged into the tank truck prior to filling. A float measures the level of the product and automatically shuts off the pumps off to minimize chance of spill. Regularly scheduled preventative maintenance program is in place at the Terminal.

19 Albany SPCC - 17 FIGURE COMPLIANCE WITH SPCC REGULATIONS, CONTINUED 40 CFR, (b) PREDICTION OF THE DIRECTION, RATE OF FLOW, AND TOTAL QUANTITY OF OIL WHICH COULD BE DISCHARGED FROM THE FACILITY AS A RESULT OF EACH TYPE OF MAJOR EQUIPMENT FAILURE Tank Truck (Overfill) - The loading rack area has a containment system consisting of a curbed reinforced concrete pad sloped towards the catch basins which are connected to oil water treatment system (Tank 10 and 11 ). Water from the oily water treatment system is manually discharges through the SPDES outlet 001. The containment system is sufficient to contain the content of the largest tank truck compartment (8,000 gallons) that loads at the rack. Containment calculations are provided in FIGURE Tank Car at the North rail spur (Equipment Failure and Overfill) - Railroad tank cars carrying crude oil are unloaded in this area. there are no loading operations conducted at this location. The unloading operations are monitored by the electronic monitoring and gauging system and are always conducted under Terminal personnel supervision. Drip pans are provided under each hose connection. The secondary containment for this area is a drainage pond and site containment. Tank Car at the Ethanol Rail Area (Equipment Failure and Overfill) - Railroad tank cars carrying ethanol are unloaded in this area. There are no loading operations conducted at this location. Secondary containment for the Unit train ethanol offloading area consists of railroad spill containment pans installed on the rail tracks. The spill pans are designed to catch spills occurring from faulty valves, hoses, couplings, and catch dripping residue from hoses. The spill pans are connected to a collector drain pipe which drains to two test/holding tanks -Tank 17 and Tank 18. The capacity of Tank 17 and 18 is 21,000 gallons each. The secondary containment system is designed to address the most likely spill scenario at the Unit Train ethanol offloading area. The most likely spill scenario for this area is the failure of hose connection. (c) Provide appropriate containment and/or diversionary structures or equipment to prevent a discharge Refer to FIGURE Containment, diversionary structures and equipment to prevent oil from reaching navigable waters are present at the Terminal. The aboveground storage tanks are provided with secondary means of containment for the entire capacity of the largest single container and sufficient freeboard to contain precipitation. The South Tank Farm secondary containment is sufficiently impervious so that a discharge will not escape the containment system before cleanup occurs. The impervious HDPE liner was installed in the South Tank Farm secondary containment dike in March 2011 by PLS Construction Inc. PLS liner installation documentation is provided in FIGURE The Central Tank Farm secondary containment is sufficiently impervious so that a discharge will not escape the containment system before cleanup occurs. The tanks in the Central tank farm store Fuel #6 ans Asphalt products. According to the "Secondary Containment Assessment" report date July 2009 and certified by EMS Environmental, the hydraulic conductivity of the Central tank farm secondary containment system meets the NYSDEC recommended hydraulic conductivity rate for #6 Fuel Oil and Asphalt product storage. Central Tank farm permeability analysis documentation is provided in FIGURE The North Tank Farm is has cracks that are being sealed. Once sealed, according to the Secondary Containment Assessment report dated July 2009 certified by EMS Environmental, once sealed, the containment is sufficiently impervious. The truck loading rack is concrete and provides appropriate secondary containment as required in Section 112.7(h) of this Plan. Containment system consisting of a curbed reinforced concrete pad sloped towards catch basins which are connected to oil water treatment system (Tank 10 and 11). Water from the oil water treatment system is manually discharges through the SPDES outlet 001. The containment system is sufficient to contain the content of the largest tank truck compartment (8,000 gallons) that loads at the rack. Containment calculations are provided in FIGURE The terminal maintains spill response equipment and contracts with emergency spill response contractors. The spill response equipment at the terminal is to be used immediately by facility personnel for emergency spill containment. North rail spur (Crude oil offloading area) - The secondary containment for this area is a drainage pond and general site containment. Ethanol Rail secondary containment consists of railroad spill containment pans system installed on the rail tracks. The spill pans are designed to catch spills occurring from faulty valves, hoses, couplings, and residue from hoses. The spill pans are connected to a collector drain pipe which drains to two test/holding tanks -Tank 17 and Tank 18. All Terminal personnel involved in marine transfers are trained in the procedures, communication required and emergency response for the products that are transferred via rail.

20 Albany SPCC - 18 FIGURE COMPLIANCE WITH SPCC REGULATIONS, CONTINUED 40 CFR, (d) CONTINGENCY PLANNING All oil stored at the Terminal has appropriate containment to prevent discharged oil from reaching a navigable watercourse. The facility is conducting an evaluation of the secondary containment system for the North Tank Farm as discussed in FIGURE (e) Inspections, Tests, and Records (maintained for at least 3 years) Inspections and tests of petroleum storage tanks and leak detection devices as required by 40 CFR 112, and New York State Petroleum and Chemical Bulk Storage regulations ( 6 NYCRR and 6 NYCRR ) are performed. The inspections are performed in accordance with industry standards. The field constructed aboveground tanks are subject to periodic testing and integral structural inspections at 10-year intervals (20 years for double bottom tanks meeting the new standards) or earlier as required by New York State Petroleum Bulk Storage Regulation (6 NYCRR 613). Chemical bulk storage tanks are being inspected in accordance with the requirements of the New York Chemical Bulk storage regulations (6 NYCRR ). The testing includes cleaning out the tanks that are resting on grade, removing the sludge from the bottom, inspecting for structural integrity and testing for tightness. The tanks storing No.6 Fuel and asphalt are exempt from 10-year integrity inspections required by the NYS Petroleum Bulk Storage regulations. Operating personnel perform daily and monthly inspections of the exterior surface of aboveground oil storage tanks, pipes, valves, and other equipment for leaks or deterioration. Written procedures for inspection have been developed and implemented for the facility. The daily, monthly and annual inspection encompasses the oil storage tanks in use at the Terminal. Tank integrity and monthly inspection records are maintained at Buckeye Albany Terminal for 10 years as required by 613.6(c). All other inspections required by the SPCC plan are maintained at the Terminal for a minimum of three years. Records maintained by the Terminal are as follows: a. Monthly inspection reports on tanks and facility. b. Report of any spill incidents. c. Spill response equipment. (f) PERSONNEL TRAINING AND DISCHARGE PREVENTION PROCEDURES (1) PERSONNEL TRAINING The oil-handling personnel are properly trained in the operation and maintenance of equipment to prevent discharges; discharge procedure protocols; applicable pollution control laws, rules and regulations; general facility operations; and the contents of the facility's SPCC Plan. New employee training New hires receive training for operations and maintenance of equipment to prevent discharges, discharge procedures, pollution control laws, rules and regulations, general facility operations, and the contents of this SPCC Plan. Refresher training is performed for employees on an annual basis. Objective - Review and exercise the spill management team's organization, communication, and decisionmaking in managing a spill response. To learn, review, and perform planned emergency response procedures specific to the response plan for the facility. Implementation - Buckeye training representative shall coordinate the scheduling and logistics requirements for the exercise with Field Operations supervision. The exercise shall be conducted so participants may gain knowledge of the potential response area and evaluate logistics and communications capabilities for the facility. Subject Matter - Demonstrations, classroom discussions, and practical exercises are used as instruction methods.

21 Albany SPCC - 19 FIGURE COMPLIANCE WITH SPCC REGULATIONS, CONTINUED 40 CFR, (f) PERSONNEL TRAINING AND DISCHARGE PREVENTION PROCEDURES (1) PERSONNEL TRAINING The following topics are covered during employees training: Emergency Plan Awareness (FRP, SPCC, SWPPP, BMP) and Response Procedures. Release Recognition. Role of the First Responder. Emergency Notification and Working with Emergency Services. NIIMS Incident Command Structure and ICS Forms. Incident Site Evaluation and Site Security. Ability to access an OSRO). Worst-Case Discharge Scenario (once every three years). Spill Containment and Recovery (Class Room & Field) (Containment and Recovery Areas, Types of Boom, Receptors). Evaluation - Exercises or Drills that are completed as a result of an actual spill response will be documented. If the required objectives are met, the Responsibility(s) and/or Locations shall receive credit for completing the exercise(s) or drill(s). For example, an actual spill response can result in a Notification Drill with Scenario, an Equipment Deployment drill, and an Emergency Response Training Exercise. (2) DESIGNATED PERSON Refer to Facility Information above for the "Designated Personnel Accountable for Oil Spill Prevention at the Facility" The Qualified Individual of the Terminal is accountable for oil spill prevention and containment at the facility. (3) SPILL PREVENTION BRIEFINGS Discharge prevention briefings are conducted with the oil-handling personnel at least annually or as changes in the personnel, the plan, the equipment, or regulations warrant. Scheduled prevention briefings for the operating personnel are conducted frequently enough to assure adequate understanding of the SPCC plan. The briefings highlight and describe known discharges, failures, malfunctioning components and any recently developed precautionary measures. Briefing program consists of: Plant management and supervisors conduct annual briefings on the SPCC Plan. At the briefings a review of techniques and new developments is presented to assist all personnel in preparing for a rapid response during failure situations. At these briefings all personnel are encouraged to raise questions and make suggestions regarding real or hypothetical situations. (g) SECURITY (1) FENCES AND GATES Areas handling, processing, or storing oil or other flammables are fenced. Access to the facility is only possible through the card-activated gate. The main gate has a closed circuit TV immediately accessible to Terminal Operators. (2) CONTAINER VALVES / DRAINS Any valves which permit direct outward flow of a tank's contents are closed or blank flanged off when in nonoperating or standby status. (3) STARTER PUMPS Starter controls on all oil pumps in non-operating or standby status are located at site accessible only to authorized personnel.

22 Albany SPCC - 20 FIGURE COMPLIANCE WITH SPCC REGULATIONS, CONTINUED 40 CFR, (g) SECURITY (4) LOADING / UNLOADING CONNECTIONS The fill ports for the oil storage tanks are securely capped when not in use. (5) FACILITY LIGHTING Site lighting is spaced throughout the facility at heavy traffic areas or areas of continuous operations. These include the following: tank farm, office and loading racks, tanker and barge docks and unit train facility. (h) FACILITY TANK CAR AND TANK TRUCK LOADING/UNLOADING RACK (1) TRANSFER AREA DRAINAGE The transfer of oil between storage tanks and cargo tank vehicles is conducted in accordance with appropriate U.S. Department of Transportation provisions (49 CFR ). There is no tank car loading rack at the facility. Crude oil and ethanol are unloaded from the tank cars by using flexible hoses at the North rail spur and Ethanol Rail unloading areas. General containment is provided at the Ethanol Rail unloading area to address the most likely spill scenario as detailed in FIGURE The containment for crude oil unloading at the North rail spur generally drains to an un-lined retention pond. Spill response equipment is located nearby in the event of a spill. Loading/unloading procedures meet the minimum requirements and regulations of the Department of Transportation. Tank truck loading rack area has a containment system consisting of a curbed reinforced concrete pad sloped toward catch basins which are connected to oil water treatment system (Tank 10 and 11). Tank 11 and Tank 10 are piped in series to allow for oil/water separation by settlement. Oily water is pumped to the top of Tank 11 and fills Tank 10 through the valved line located at the bottom of Tank 11. The capacity of Tank 11 is 109,200 gallons, the capacity of Tank 10 is 109,200 gallons. Water from the oil water treatment system is manually discharged through SPDES outfall 001 to the Hudson River. (2) INTERLOCKED WARNING LIGHT OR PHYSICAL BARRIER Prior to commencement of loading or unloading oil from a cargo tank: By the way of a physical barrier system (per 112.7(h)(2)), the cargo tank wheels shall be securely chocked to prevent vehicular departures before complete disconnect of lines. Prior to commencement of loading or unloading oil from a cargo tank: If the vehicle cab remains attached, the vehicle handbrake shall be securely set. Prior to commencement of loading or unloading oil from a cargo tank: To minimize the release of any material during transfer operations, a drip pan must be placed under each hose connection.

23 Albany SPCC - 21 FIGURE COMPLIANCE WITH SPCC REGULATIONS, CONTINUED 40 CFR, (h) FACILITY TANK CAR AND TANK TRUCK LOADING/UNLOADING RACK (2) INTERLOCKED WARNING LIGHT OR PHYSICAL BARRIER Prior to commencement of loading or unloading oil from a cargo tank: Absorbents, shovels, etc. are available in the storage building for immediate cleanup in the event of a spill. An interlocked warning light, a physical barrier system, or warning signs are provided in tank truck loading/unloading area to prevent vehicular departure before disconnect of transfer lines. The loading procedures at the facility require trucks to use a brake interlock system and warning signs to prevent vehicles from departing before complete disconnection of flexible or fixed oil transfer lines. Prior to filling and departure of any tank truck, drivers closely inspect for discharges. Facility personnel or the truck driver is present during the entire time to observe each loading operation. Spill response materials will be used in the event of a spill. The tank car loading procedures are to set brakes and place wheel chocks to prevent car movement. Drains and outlets on tank cars are checked for leakage before loading/unloading or departure. The unit train unloading procedures are to set brakes and place wheel chocks to prevent car movement. Drains and outlets on tank cars are checked for leakage before unloading and departure. Unloading instruction signs are posted at the tank truck loading are to fully inform drivers of plant procedures. Product signs are in place to identify #6 fuel oil,, crude oil, ethanol and asphalt points of transfer. The truck drivers are responsible for loading and removing the loading arms before capping their tank. The automated closed circuit television system monitors all bays at the tank truck loading rack. (3) TRUCK DRAIN / OUTLET EXAMINATION A cargo tank must be attended at all times during the loading or unloading transfer process. The attendee is an employee familiar with cargo tank loading and unloading procedures including the Scully system which minimizes the likelihood of an overfill. During the loading or unloading transfer process, the cargo tank attendee must: a. Be alert; b. Have an unobstructed view of the cargo tank; c. Be within 25 feet of the cargo tank; d. Visually inspect all hose connections, valves, and pumps to check for leaks or drips. All leaks must be stopped immediately or contained in a drip pan, and; e. Be familiar with procedures to be followed in an emergency. Upon completion of the loading or unloading transfer process, the cargo tank attendee shall ensure that: a. All manhole closures on the truck are closed and secured, and; b. All valves and other closures in liquid discharge systems are closed and free of leaks.

24 Albany SPCC - 22 FIGURE COMPLIANCE WITH SPCC REGULATIONS, CONTINUED 40 CFR, (h) FACILITY TANK CAR AND TANK TRUCK LOADING/UNLOADING RACK (3) TRUCK DRAIN / OUTLET EXAMINATION Prior to departure of any tank truck, the lowest drain and all outlets of such vehicle shall be closely examined for leakage; and, if necessary, tightened, adjusted, or replaced to prevent liquid spillage while in transit. Drains and outlets on tank trucks are checked for leakage before loading/unloading or departure. (i) BRITTLE FRACTURE EVALUATION REQUIREMENTS When a field-constructed aboveground container undergoes a repair, alteration, or change in service, or has discharged oil due to a brittle fracture failure, a brittle fracture evaluation is conducted. (j) STATE DISCHARGE PREVENTION REQUIREMENTS Storage of petroleum products at the Terminal is regulated by the registration, operation and construction provisions of 6 NYCRR 612, 613 and 614. Conformance with the applicable requirements of these standards are discussed in this plan, section 112.7(a)(3)(i). This facility meets the requirements for more stringent state rules, regulations, or guidelines, with respect to oil spill prevention. The facility is subject to 40 CFR and and maintains a Facility Response Plan (FRP) and OSRO agreement with a contractor. Federal Reporting Requirements: If the facility discharges more than 1,000 gallons of oil in a single discharge or has two discharges of more than 42 gallons within 12 months, a report must be submitted to the EPA Regional Administrator within 60 days after the 1,000 gallon discharge or the second larger than 42 gallon discharge. The report must contain the following information and a copy of the report must also be provided to the NYSDEC: Name of the facility; your name; location of the facility; maximum storage or handling capacity of the facility and normal daily throughput; corrective action and countermeasures you have taken, including a description of equipment repairs and replacements; an adequate description of the facility, including maps, flow diagrams, and topographical maps, as necessary; the cause of the discharge, including a failure analysis of the system or subsystem in which the failure occurred; additional preventive measures you have taken or contemplated to minimize the possibility of recurrence; and such other information as the Regional Administrator may reasonably require pertinent to the Plan or discharge. NYSDEC Reporting: Any spill must be reported to the New York State Department of Environmental Conservation's (NYSDEC) spill hotline within two (2) hours of discovery unless the spill meets ALL of the following criteria: Quantity spilled is less than five (5) gallons. The spill is contained and under control. The spill will not reach water or any land (if it occurs on a paved surface such as concrete or asphalt)*. The spill is cleaned up within two (2) hours of discovery. *A spill in a dirt or gravel parking lot is considered to have impacted land and is reportable. The specific reporting requirements are outlined below based on the size of the discharge and the affected media.

25 Albany SPCC - 23 FIGURE COMPLIANCE WITH SPCC REGULATIONS, CONTINUED 40 CFR, (j) STATE DISCHARGE PREVENTION REQUIREMENTS *** MUST provide verbal notice to: Department of Environmental Conservation (800) Federal Clean Water Act Immediate Notice If there is a spill of petroleum into or upon navigable water or adjoining shoreline which: causes a film or sheen, or discoloration of the water or adjoining shoreline, or causes sludge or emulsion to be deposited beneath the water surface OR causes a violation of applicable water quality standards. *** MUST provide IMMEDIATE verbal notice to: National Response Center (800) and Department of Conservation (800) (k) QUALIFIED OIL-FILLED OPERATIONAL EQUIPMENT Not Applicable (1) Qualification Criteria Reportable Discharge History Not Applicable (2) Alternative Requirements to General Secondary Containment Not Applicable (i) Facility Procedures for Inspections / Monitoring Not Applicable (ii) Unless you have submitted a response plan under , provide Contingency Planning: Not Applicable (A) An oil spill contingency plan following the provisions of part 109 of this chapter. Not Applicable (B) A written commitment of manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful. Not Applicable

26 Albany SPCC - 24 FIGURE COMPLIANCE WITH SPCC REGULATIONS, CONTINUED (a)general REQUIREMENTS 40 CFR, This SPCC Plan was prepared in accordance with the general requirements listed in The specific discharge prevention and containment procedures and compliance with all regulations listed in and are discussed in each section of this SPCC Plan. Compliance with specific requirements are detailed in bulleted responses below. (b) FACILITY DRAINAGE (1) DRAINAGE FROM DIKED AREAS Drainage from diked areas of North, Central and South Tanks Farms is accomplished by use of a manually operated pump. Drainage from the South Tank Farm dike is directed to two collection sumps and further to the Highland aboveground oil/water separator tank (12,000 gallon) located at the Central Tank Farm. The drainage at this oil/water separator is manually controlled with a pump and valve. The discharge valve is normally closed. From the oil/water separator the drainage is pumped to NY SPDES permitted outfall #001 which flows into the Hudson River. Drainage from the North Tank Farm is accomplished by transfer from three collection sumps through an API separator which removes traces of oil before discharging clean water to a nearby storm drain from where it flows into Normans Kill under a SPDES permitted outfall #003. Drainage from the Central tank farm (the "V" tanks) is directed to the oil water treatment system consisting of Tank 11 and Tank 10 then drains to NY SPDES permitted outfall #001 which flows into the Hudson River. Records on quantity discharged are reported with the date of discharge. Discharges are manned at all times and all valves are closed and secured following discharges. (2) DRAIN VALVES AND DROP PIPES Drainage from the South Tank Farm dike is directed to two collection sumps and further to the Highland aboveground oil/water separator tank (12,000 gallon) located at the Central Tank Farm. The drainage at this oil/water separator is manually controlled with a pump and valve. The water from the South tank farm is pumped by the sump pumps to the separator them to outfall #001. There isn't a second set of pumps or a discharge valve. Storm water outside containment areas is directed to Tanks 10, 11 Discharge is controlled by manually opening a valve at the tank and the river. An automatic valve closes whenever the water is lowered beyond a preset level. The automatic valve trips an audible alarm, which informs the operator to close the manual valve. Storm water outside the containment areas is directed to TKS. 10 & 11 but not the Highland separator (only the STF sumps go to the Highland). Also there no automatic valve to shut down flow at 10 & 11. (3) FACILITY DRAINAGE SYSTEM FROM UNDIKED AREAS Storm water within the Facility is directed to the oil water treatment system consisting of an oil/water separator and then to Tank 11 and Tank 10 then to NY SPDES permitted outfall #001 which flows into the Hudson River.. Oil is monitored in accordance with a SPDES permit.

27 Albany SPCC - 25 FIGURE COMPLIANCE WITH SPCC REGULATIONS, CONTINUED 40 CFR, (b) FACILITY DRAINAGE (4) DIVERSION SYSTEM Storm water outside containment areas is directed to Tanks 10, 11. Discharge is controlled by manually opening a valve at the tank and the river. Varec automatic system informs an operator (by an audible alarm) whenever the water is lowered beyond a preset low level. If water is lowered beyond the preset level an operator is to close the manual valve. The SPDES permit requires monthly monitoring for oil, grease and flow. Each discharge requires effluent testing and visual observations, which are summarized and sent to the New York State Department of Environmental Conservation monthly (DMRs). (5) TREATED DRAINAGE WATERS Disposal facilities for plant effluents discharged into navigable waters are observed frequently for indication of possible upsets which may cause an oil spill event. Method and frequency of observations: The SPDES discharge permit requires monthly testing for grease and oil. Samples are required to be taken on effluent prior to discharge. The discharge limitation is less than 15 mg/l for grease and oil. Visual observation is required prior to each discharge. The observation is recorded and submitted with the regular monthly monitoring report to New York State Department of Environmental Conservation. Facility Oily Water Treatment Systems: The State Pollutant Discharge Elimination System (SPDES) consists of two 2457 gallon capacity tanks (Tank 10 and Tank 11) and one 9,000 gallons capacity Highland oil/water separator tank located in the Central Tank Farm. The oil/water separators provide treatment for storm water runoff inside and outside diked areas. Storm water is directed to the SPDES system through below ground storm water sewers connected to a series of catch basins. All flow enters a lift station/skimmer which removes small quantities of floating oil. This oil is transferred to the recovered oil chamber of the lift station. Recovered oil is then removed for recycling. The oil/water tanks 10 and 11 are piped in series to permit oil/water separation by settlement. Oily water is pumped to the top of Tank 11 and fills Tank 10 through the valved line located at the bottom of Tank 11.

28 Albany SPCC - 26 FIGURE COMPLIANCE WITH SPCC REGULATIONS, CONTINUED 40 CFR, (b) FACILITY DRAINAGE (5) TREATED DRAINAGE WATERS As the tanks reach capacity, a high level alarm is activated. Water can be drawn off the bottom of the tanks by opening a manual flow control valve to release clean effluent at a rate of 200 gallons per minute through the effluent line to the Hudson River through permitted SPDES outfall 001. The effluent line to the Hudson River contains manholes that have top elevations equal to the top of the dike. In the event of a spill within South and Central Tank Farm, no spilled product would enter the SPDES discharge line. Storm water within the North Tank Farm secondary containment system is directed towards two sumps located at the north and south portions of the containment area and pumped through an oil/water separator where it is discharged to Normans Kill through permitted outfall 003. All discharges are supervised by on-site operations personnel. All discharges are in accordance with the requirements of the facility's Storm Water Discharge Permit. Records including the date and time of discharge are kept at the facility. The SPDES system requires continuous monitoring with no water discharged until authorized by Terminal management. Monthly monitor testing is required for grease and oil. Before any effluent is discharged, samples are taken and tested. Daily visual observations are also required for each discharge. Discharges are manned at all times and all valves are closed and secured following discharges. (c) BULK STORAGE CONTAINERS (1) CONTAINER CONSTRUCTION AND MATERIALS The aboveground storage tanks (AST's) are constructed of welded steel in accordance with the appropriate API/STI or industry standards and are compatible with the product stored at the pressure and temperature range required. Piping between tanks is made of steel. (2) SECONDARY CONTAINMENT The storage tanks are contained in the North, South and Central Tank Farms. The secondary containment system for the South Tank Farm consists of a sufficiently impervious dike in accordance with five (5) year MOSF permeability testing and certification. The containment capacity of the dike is 7,450,080 gallons which is sufficient to hold the capacity for the contents of the largest tank (Tank A-21 of 6,073,760 gallons) and sufficient freeboard to contain precipitation.

29 Albany SPCC - 27 FIGURE COMPLIANCE WITH SPCC REGULATIONS, CONTINUED 40 CFR, (c) BULK STORAGE CONTAINERS (2) SECONDARY CONTAINMENT The secondary containment system for the Central Tank Farm consists of an earthen dike which is connected to the South Tank Farm by an intermediate dike to provide shared containment capacity. The intermediate dike between the South and Central Tank Farms is set so that in the event of a large spill, the spilled product from the Central Tank Farm could flow into the South Tank Farm dike. The approximate shared capacity of the Central containment dike is 16,792,600 gallons. The secondary containment dike provides capacity for the contents of the Tank A-25 (10,659,000 gallons) and sufficient freeboard to contain precipitation. Containment calculations are provided in the FIGURE The North Tank Farm secondary containment system consists of a sealed asphalt liner on the containment floor surrounded by a concrete dike wall. The approximate capacity of the containment dike is 7.6 million gallons. The secondary containment dike provides capacity for the contents of the largest Tank 31 or 32 (7,114,338 gallons) and sufficient freeboard to contain precipitation. The containment calculations are provided in FIGURE (3) RAINWATER DRAINAGE The drainage of the terminal's containment area is described in 40 CFR 112.8(b). All discharges from the containment areas are supervised by local management. A record of each containment discharge is documented in a log book and kept at the facility for at least three (3) years. (4) BURIED METALLIC STORAGE TANKS There are no underground storage tanks or partially buried tanks at the Terminal subject to SPCC regulations. (5) PARTIALLY BURIED METALLIC STORAGE TANKS There are no underground storage tanks or partially buried tanks at the Terminal subject to SPCC regulations. (6) ABOVEGROUND CONTAINERS Visual inspection of tank exteriors occurs daily and continuous monitoring for volume is accomplished through the Varec automatic tank monitoring system.

30 Albany SPCC - 28 FIGURE COMPLIANCE WITH SPCC REGULATIONS, CONTINUED 40 CFR, (c) BULK STORAGE CONTAINERS (6) ABOVEGROUND CONTAINERS The frequency and type of tank testing and inspections are documented at the facility. The tank inspections are conducted in accordance with industry standards and take into account the container size, configuration and design. Comparison records of aboveground container integrity testing are maintained. Tanks have bottoms tested by the vacuum test or ultrasonic thickness meter, and shells by radiographic methods when a tank is emptied for repairs or modifications. All required tanks are tested at 10 year intervals or when changing service. The tank integrity testing records are available at the facility. (7) INTERNAL HEATING COILS Internal heating coil leakage (on asphalt tanks) is controlled by monitoring the steam return or exhaust lines for oil. (8) FAIL SAFE ENGINEERING Tanks at the Terminal are equipped with high liquid level alarms and visual/level gauges. Filling procedures require the tanks to be gauged prior to receiving product and for the tanks to be filled to a safe fill height determined for each tank. A trained Terminal employee observes each tank filling operations. (9) FACILITY EFFLUENTS Disposal facilities for plant effluents discharged into navigable waters are observed frequently for indication of possible upsets which may cause an oil spill event. (10) VISIBLE OIL LEAKS Visible oil leaks including leaks from container seams, gaskets, piping, pumps, valves, rivets, and bolts are fixed immediately and reported to the management. Any accumulation of oil in diked areas is removed immediately. Cleanup is performed using onsite materials or, for larger spills, by an outside contractor. Oil contaminated rain water is pumped into drums or a vac truck for proper off-site disposal. (11) MOBILE/PORTABLE STORAGE CONTAINERS The Terminal does not have mobile or portable containers. (d) FACILITY TRANSFER OPERATIONS, PUMPING, AND FACILITY PROCESSES (1) BURIED PIPING INSTALLATIONS Corrosion protection for buried pipelines: Pipelines are wrapped and coated to reduce corrosion. When a pipeline section is exposed, it is examined and corrective action taken as necessary. There is no buried piping that has been installed or replaced on or after August 16, 2002.

31 Albany SPCC - 29 FIGURE COMPLIANCE WITH SPCC REGULATIONS, CONTINUED 40 CFR, (d) FACILITY TRANSFER OPERATIONS, PUMPING, AND FACILITY PROCESSES (2) PIPELINE OUT OF SERVICE Pipeline terminal connections are capped or blank-flanged and marked if the pipeline is not in service for extended periods. Criteria for determining when to cap or blank flange: Lines that are not in active service for extended periods of more than six months are capped. Transfer lines at the barge and tanker docks are blank flanged and kept locked as a regular routine when not in use. (3) PIPING SUPPORTS Pipe supports are designed to minimize abrasion and corrosion and allow for expansion and contraction. Pipe support design: Steel pipe supports have provisions for slide support and are painted to minimize corrosion. Facility piping is either painted or jacketed with insulation enclosed in aluminum. (4) ABOVEGROUND VALVES AND PIPELINES Procedures for regularly examining of all aboveground valves and pipelines: All facility piping and valves are inspected daily for problem. All transfer operations require that operations personnel trace the lines completely by opening and closing the correct valves for desired destination. Tracing eliminates flow errors and provides regular examination of piping, valves and fittings. (5) VEHICULAR TRAFFIC Procedures for warning vehicles entering the facility to avoid damaging above-ground piping:

32 Albany SPCC - 30 FIGURE COMPLIANCE WITH SPCC REGULATIONS, CONTINUED 40 CFR, (d) FACILITY TRANSFER OPERATIONS, PUMPING, AND FACILITY PROCESSES (5) VEHICULAR TRAFFIC Tankers enter the facility loading area by one gate and leave by another gate. Piping at the loading rack is elevated above the trucks. Fencing restricts movement to other parts of the facility.

33 Albany SPCC - 31 FIGURE POTENTIAL SPILL SOURCES/ CONTAINERS OF OIL

34 Albany SPCC - 32 FIGURE POTENTIAL SPILL SOURCES/ CONTAINERS OF OIL, CONTINUED

35 Albany SPCC - 33 FIGURE POTENTIAL SPILL SOURCES/ CONTAINERS OF OIL, CONTINUED

36 Albany SPCC - 34 FIGURE POTENTIAL SPILL SOURCES/ CONTAINERS OF OIL, CONTINUED

37 Albany SPCC - 35 FIGURE POTENTIAL SPILL SOURCES/ CONTAINERS OF OIL, CONTINUED

38 Albany SPCC - 36 FIGURE FACILITY DIAGRAM Click here to view Site Plan

39 Albany SPCC - 37 FIGURE SURVEY DIAGRAM Click here to view Secondary Containment Study

40 Albany SPCC - 38 FIGURE PIPING DIAGRAM No Piping Diagram uploaded.

41 Albany SPCC - 39 FIGURE PERMEABILITY STUDY No Permeability Study uploaded.

42 Albany SPCC - 40 FIGURE REPORTABLE SPILL HISTORY* Date of Discharge(s): 4/4/2009 Location (Equipment or Operations): TK V-103 List of Discharge Causes: Material(s) Discharged: Amount of Discharges in Gallons: Amount That Reached Navigable Waters (if applicable): Effectiveness and Capacity of Secondary Containment: Cleanup Actions Taken: A Vac truck off loaded blend stock into TK V-103. Approximately 1400 Gallons was released from a flange to the secondary containment and Into TK l's containment dyke. Steps Taken to Reduce Possibility of Reoccurrence: Total Oil Storage Capacity of Tank(s) or Impoundment(s) From Which Material Discharged: Enforcement Actions: blend stock Approximately 1400 (gallons) 0 (gallons) Approximately 1400 Gallons was released from a flange to the secondary containment and Into TK l's containment dyke. All appropriate Internal and external notifications were made. There were no Injuries or fires. () Effectiveness of Monitoring Equipment: Spill Detection: Brief Summary of the Impact of the Spill: Geographic Area: *Reportable spill, as defined in 40 CFR Part 110, is a discharge of oil that violates applicable water quality standards or a discharge into or upon the navigable waters of the United States or adjoining shorelines in harmful quantities.

43 Albany SPCC - 41 FIGURE REPORTABLE SPILL HISTORY*, CONTINUED Date of Discharge(s): 9/14/1993 Location (Equipment or Operations): Barge Moran Rhode Island List of Discharge Causes: Barge Moran Rhode Island while being loaded developed a leak. Material(s) Discharged: Amount of Discharges in Gallons: () Amount That Reached Navigable Waters (if applicable): Effectiveness and Capacity of Secondary Containment: Cleanup Actions Taken: Steps Taken to Reduce Possibility of Reoccurrence: Total Oil Storage Capacity of Tank(s) or Impoundment(s) From Which Material Discharged: Enforcement Actions: () Loading was secured, and DEC/USCG was notified. Boom was deployed and clean-up crew called in. On barge transfer was performed and leak sealed. Inspection completed and barge was released by USCO. No further action required. () Effectiveness of Monitoring Equipment: Spill Detection: Brief Summary of the Impact of the Spill: Geographic Area: *Reportable spill, as defined in 40 CFR Part 110, is a discharge of oil that violates applicable water quality standards or a discharge into or upon the navigable waters of the United States or adjoining shorelines in harmful quantities.

44 Albany SPCC - 42 FIGURE REPORTABLE SPILL HISTORY*, CONTINUED Date of Discharge(s): 7/27/1993 Location (Equipment or Operations): List of Discharge Causes: Material(s) Discharged: SIS Evrotas Sheen discovered on river around dock while SIS Evrotas was berthed. Bilge suspected for spill. Amount of Discharges in Gallons: () Amount That Reached Navigable Waters (if applicable): Effectiveness and Capacity of Secondary Containment: Cleanup Actions Taken: Steps Taken to Reduce Possibility of Reoccurrence: Total Oil Storage Capacity of Tank(s) or Impoundment(s) From Which Material Discharged: Enforcement Actions: () Boom deployed and clean-up crews dispatched. Clean-up was completed and no further action was required. Crew was warned about possible intentional discharge and order to sop. () Effectiveness of Monitoring Equipment: Spill Detection: Brief Summary of the Impact of the Spill: Geographic Area: *Reportable spill, as defined in 40 CFR Part 110, is a discharge of oil that violates applicable water quality standards or a discharge into or upon the navigable waters of the United States or adjoining shorelines in harmful quantities.

45 Albany SPCC - 43 FIGURE REPORTABLE SPILL HISTORY*, CONTINUED Date of Discharge(s): 12/3/1992 Location (Equipment or Operations): List of Discharge Causes: Material(s) Discharged: Great Lakes Vessel Sheen in river was detected by the Great Lakes Vessel. It was determined to be coming from this vessel. Leak was discovered in the barge compartment. Amount of Discharges in Gallons: () Amount That Reached Navigable Waters (if applicable): Effectiveness and Capacity of Secondary Containment: Cleanup Actions Taken: Steps Taken to Reduce Possibility of Reoccurrence: Total Oil Storage Capacity of Tank(s) or Impoundment(s) From Which Material Discharged: Enforcement Actions: () Boom was immediately deployed and authorities were notified. Cleanup performed, No additional action required. Off loading continued as additional boom was placed. () Effectiveness of Monitoring Equipment: Spill Detection: Brief Summary of the Impact of the Spill: Geographic Area: *Reportable spill, as defined in 40 CFR Part 110, is a discharge of oil that violates applicable water quality standards or a discharge into or upon the navigable waters of the United States or adjoining shorelines in harmful quantities.

46 Albany SPCC - 44 FIGURE REPORTABLE SPILL HISTORY*, CONTINUED Date of Discharge(s): 10/31/1992 Location (Equipment or Operations): List of Discharge Causes: Material(s) Discharged: Amount of Discharges in Gallons: Amount That Reached Navigable Waters (if applicable): Effectiveness and Capacity of Secondary Containment: Cleanup Actions Taken: Dock Approximately 5-10 gallons of product released from a discharge hose during the disconnection from the manifold. Approximately, half of the product spilled into the river and the remainder of the product sprayed the area. Steps Taken to Reduce Possibility of Reoccurrence: Total Oil Storage Capacity of Tank(s) or Impoundment(s) From Which Material Discharged: Enforcement Actions: 5-10 (gallons) 2-5 (gallons) Absorbent boom was deployed immediately and absorbed the product. No report was made to DEC as quantity was not significant. () Effectiveness of Monitoring Equipment: Spill Detection: Brief Summary of the Impact of the Spill: Geographic Area: *Reportable spill, as defined in 40 CFR Part 110, is a discharge of oil that violates applicable water quality standards or a discharge into or upon the navigable waters of the United States or adjoining shorelines in harmful quantities.

47 Albany SPCC - 45 FIGURE REPORTABLE SPILL HISTORY*, CONTINUED Date of Discharge(s): 10/13/1992 Location (Equipment or Operations): List of Discharge Causes: Material(s) Discharged: Amount of Discharges in Gallons: Amount That Reached Navigable Waters (if applicable): Effectiveness and Capacity of Secondary Containment: Cleanup Actions Taken: barge Approximately 50 gallons of oil escaped from a barge in New Jersey. The barge pump seal failed. Steps Taken to Reduce Possibility of Reoccurrence: Total Oil Storage Capacity of Tank(s) or Impoundment(s) From Which Material Discharged: Enforcement Actions: oil 50 (gallons) 50 (gallons) Cibro personnel deployed boom, containing the release. All released product was contained and no further action was required. Discharging continued, using a different pump that was approved by the USCG. () Effectiveness of Monitoring Equipment: Spill Detection: Brief Summary of the Impact of the Spill: Geographic Area: *Reportable spill, as defined in 40 CFR Part 110, is a discharge of oil that violates applicable water quality standards or a discharge into or upon the navigable waters of the United States or adjoining shorelines in harmful quantities.

48 Albany SPCC - 46 FIGURE REPORTABLE SPILL HISTORY*, CONTINUED Date of Discharge(s): 1/4/1992 Location (Equipment or Operations): List of Discharge Causes: Material(s) Discharged: Amount of Discharges in Gallons: Amount That Reached Navigable Waters (if applicable): Effectiveness and Capacity of Secondary Containment: Cleanup Actions Taken: Kinston Barge Captain of the Kinston Barge reported that his empty #4 apt compartment was taking on water. A sheen was detected on the water to confirm the leaking compartment. Since the barge was empty, no oil spilled into the river in any measurable quantity. Steps Taken to Reduce Possibility of Reoccurrence: Total Oil Storage Capacity of Tank(s) or Impoundment(s) From Which Material Discharged: Enforcement Actions: Oil 0 (gal) 0 (gal) Boom was immediately placed around the barge. Barge was offloaded and boom pulled. No oil detected on boom. No further action required. () Effectiveness of Monitoring Equipment: Spill Detection: Brief Summary of the Impact of the Spill: Geographic Area: *Reportable spill, as defined in 40 CFR Part 110, is a discharge of oil that violates applicable water quality standards or a discharge into or upon the navigable waters of the United States or adjoining shorelines in harmful quantities.

49 Albany SPCC - 47 FIGURE REPORTABLE SPILL HISTORY*, CONTINUED Date of Discharge(s): 11/16/1990 Location (Equipment or Operations): List of Discharge Causes: Material(s) Discharged: Amount of Discharges in Gallons: Amount That Reached Navigable Waters (if applicable): Effectiveness and Capacity of Secondary Containment: Cleanup Actions Taken: E-20 Barge E-20 Barge found to be leaking product. Estimated 1,000 gallons escaped into the river. Steps Taken to Reduce Possibility of Reoccurrence: Total Oil Storage Capacity of Tank(s) or Impoundment(s) From Which Material Discharged: Enforcement Actions: Estimated 1,000 (gallons) Estimated 1,000 (gallons) Authorities DEC/USCG notified. Boom placed around entire barge, while discharging back to Tank 37. Boom was removed and barge released by USCG. () Effectiveness of Monitoring Equipment: Spill Detection: Brief Summary of the Impact of the Spill: Geographic Area: *Reportable spill, as defined in 40 CFR Part 110, is a discharge of oil that violates applicable water quality standards or a discharge into or upon the navigable waters of the United States or adjoining shorelines in harmful quantities.

50 Albany SPCC - 48 FIGURE REPORTABLE SPILL HISTORY*, CONTINUED Date of Discharge(s): 11/10/1989 Location (Equipment or Operations): List of Discharge Causes: Material(s) Discharged: Barge Cibro-Philly, stall and State Police arrived at the dock due to observation of oil in the river. It was determined that the barge had a hole in it. Area was immediately contained. Amount of Discharges in Gallons: () Amount That Reached Navigable Waters (if applicable): Effectiveness and Capacity of Secondary Containment: Cleanup Actions Taken: Steps Taken to Reduce Possibility of Reoccurrence: Total Oil Storage Capacity of Tank(s) or Impoundment(s) From Which Material Discharged: Enforcement Actions: () () Effectiveness of Monitoring Equipment: Spill Detection: Brief Summary of the Impact of the Spill: Geographic Area: Visual observation *Reportable spill, as defined in 40 CFR Part 110, is a discharge of oil that violates applicable water quality standards or a discharge into or upon the navigable waters of the United States or adjoining shorelines in harmful quantities.

51 Albany SPCC - 49 FIGURE REPORTABLE SPILL HISTORY*, CONTINUED Date of Discharge(s): 7/10/1989 Location (Equipment or Operations): List of Discharge Causes: Material(s) Discharged: Amount of Discharges in Gallons: Amount That Reached Navigable Waters (if applicable): Effectiveness and Capacity of Secondary Containment: Cleanup Actions Taken: utility building An oil spill was detected on ground outside of utility building located near P-207. Initial finding was a sump backed up toll owing heavy rains and spilling approximately gallons of oil. approximately (gallons) 0 (gallons) Spill was reported to DEC and National Response Center. All corrective actions were taken to minimize the spill from becoming worse. Spill clean-up crew was immediately contacted for remediation. Steps Taken to Reduce Possibility of Reoccurrence: Total Oil Storage Capacity of Tank(s) or Impoundment(s) From Which Material Discharged: Enforcement Actions: () Effectiveness of Monitoring Equipment: Spill Detection: Brief Summary of the Impact of the Spill: Geographic Area: *Reportable spill, as defined in 40 CFR Part 110, is a discharge of oil that violates applicable water quality standards or a discharge into or upon the navigable waters of the United States or adjoining shorelines in harmful quantities.

52 Albany SPCC - 50 FIGURE REPORTABLE SPILL HISTORY*, CONTINUED Date of Discharge(s): 5/29/1989 Location (Equipment or Operations): List of Discharge Causes: Material(s) Discharged: Amount of Discharges in Gallons: Amount That Reached Navigable Waters (if applicable): Effectiveness and Capacity of Secondary Containment: Cleanup Actions Taken: Steps Taken to Reduce Possibility of Reoccurrence: utility building Spill of approximately gallons crude slope occurred in the utility building. It escaped at the south side of the building. Total Oil Storage Capacity of Tank(s) or Impoundment(s) From Which Material Discharged: Enforcement Actions: Crude slop (gallons) 0 (gallons) Remediation by Domermuth was performed immediately, by vacuuming up the product as by the arrival of DEC. Due to the diligence of the response time, DEC allowed the site to be covered with gravel. The remediation was satisfactory and no further action was required. () Effectiveness of Monitoring Equipment: Spill Detection: Brief Summary of the Impact of the Spill: Geographic Area: *Reportable spill, as defined in 40 CFR Part 110, is a discharge of oil that violates applicable water quality standards or a discharge into or upon the navigable waters of the United States or adjoining shorelines in harmful quantities.

53 Albany SPCC - 51 FIGURE REPORTABLE SPILL HISTORY*, CONTINUED Date of Discharge(s): 4/16/1989 Location (Equipment or Operations): Tank P-40 List of Discharge Causes: Material(s) Discharged: Amount of Discharges in Gallons: Amount That Reached Navigable Waters (if applicable): Effectiveness and Capacity of Secondary Containment: Cleanup Actions Taken: A #6 oil spill was found in the North Tank Farm at P-40 I. It appeared to be from the seal. The estimated spill quantity was 100 gallons. Steps Taken to Reduce Possibility of Reoccurrence: Total Oil Storage Capacity of Tank(s) or Impoundment(s) From Which Material Discharged: Enforcement Actions: #6 Oil 100 (gallons) 0 (gallons) The pump was shut down and isolated. A clean-up crew was contacted. () Effectiveness of Monitoring Equipment: Spill Detection: Brief Summary of the Impact of the Spill: Geographic Area: *Reportable spill, as defined in 40 CFR Part 110, is a discharge of oil that violates applicable water quality standards or a discharge into or upon the navigable waters of the United States or adjoining shorelines in harmful quantities.

54 Albany SPCC - 52 FIGURE REPORTABLE SPILL HISTORY*, CONTINUED Date of Discharge(s): 3/27/1989 Location (Equipment or Operations): List of Discharge Causes: Material(s) Discharged: Spill was noticed and immediately reported to DEC. Test pits were dug and periodically cleaned out. After removal of contaminated soil, test wells were dug. No free product was seen. Amount of Discharges in Gallons: () Amount That Reached Navigable Waters (if applicable): Effectiveness and Capacity of Secondary Containment: Cleanup Actions Taken: Steps Taken to Reduce Possibility of Reoccurrence: Total Oil Storage Capacity of Tank(s) or Impoundment(s) From Which Material Discharged: Enforcement Actions: () Test pits were dug and periodically cleaned out. After removal of contaminated soil, test wells were dug. No free product was seen. () Effectiveness of Monitoring Equipment: Spill Detection: Brief Summary of the Impact of the Spill: Geographic Area: *Reportable spill, as defined in 40 CFR Part 110, is a discharge of oil that violates applicable water quality standards or a discharge into or upon the navigable waters of the United States or adjoining shorelines in harmful quantities.

55 Albany SPCC - 53 FIGURE REPORTABLE SPILL HISTORY*, CONTINUED Date of Discharge(s): 10/25/1982 Location (Equipment or Operations): List of Discharge Causes: Material(s) Discharged: Transfer Line Sheen on the water of about 20' x 100' was observed by the USCG inspector BM2 Rotermund, of PSD Albany. It was determined by the odor that the pollutant was gasoline and traced back to a faulty transfer line gasket. The spill occurred while the line was being drained; a gasket failed, spraying product outside the containment field. Gasonline Amount of Discharges in Gallons: (unknown) Amount That Reached Navigable Waters (if applicable): Effectiveness and Capacity of Secondary Containment: Cleanup Actions Taken: Steps Taken to Reduce Possibility of Reoccurrence: Total Oil Storage Capacity of Tank(s) or Impoundment(s) From Which Material Discharged: Enforcement Actions: (unknown) A gasket failed, spraying product outside the containment field. Immediate action by the responsible party stopped the additional release of product. Due to the high winds and outgoing tide, no cleanup of the gasoline in the water was necessary. The product dissipated with tidal current action. () Effectiveness of Monitoring Equipment: Spill Detection: Brief Summary of the Impact of the Spill: Geographic Area: *Reportable spill, as defined in 40 CFR Part 110, is a discharge of oil that violates applicable water quality standards or a discharge into or upon the navigable waters of the United States or adjoining shorelines in harmful quantities.

56 Albany SPCC - 54 FIGURE REPORTABLE SPILL HISTORY*, CONTINUED Date of Discharge(s): 1/30/1982 Location (Equipment or Operations): List of Discharge Causes: Material(s) Discharged: Amount of Discharges in Gallons: Amount That Reached Navigable Waters (if applicable): Effectiveness and Capacity of Secondary Containment: South Dock Spill at the South Dock yielded approximately gallons of oil which lay on the top of the ice and did not enter the waterway. A clean-up crew (Domermuth) was called and the spill was remediated to the satisfaction of the USCG. Fine assessed, and no further action was required. Cleanup Actions Taken: Steps Taken to Reduce Possibility of Reoccurrence: Total Oil Storage Capacity of Tank(s) or Impoundment(s) From Which Material Discharged: Enforcement Actions: Gasoline (gallons) (gallons) () Effectiveness of Monitoring Equipment: Spill Detection: Brief Summary of the Impact of the Spill: Geographic Area: *Reportable spill, as defined in 40 CFR Part 110, is a discharge of oil that violates applicable water quality standards or a discharge into or upon the navigable waters of the United States or adjoining shorelines in harmful quantities.

57 Albany SPCC - 55 FIGURE REPORTABLE SPILL HISTORY*, CONTINUED Date of Discharge(s): 1/6/1982 Location (Equipment or Operations): List of Discharge Causes: Material(s) Discharged: Amount of Discharges in Gallons: Amount That Reached Navigable Waters (if applicable): Effectiveness and Capacity of Secondary Containment: Cleanup Actions Taken: Tank Black oil on ice reported to us by USCG. Upon inspection, our containment tank was being heated in preparation for pumping out, had a minor leak. Approximately 1 cup of oil was discovered. Steps Taken to Reduce Possibility of Reoccurrence: Total Oil Storage Capacity of Tank(s) or Impoundment(s) From Which Material Discharged: Enforcement Actions: Oil 1 (cup) 0 (gal) An absorbent pad was placed around the containment tank to prevent any further spillage. No further action needed. () Effectiveness of Monitoring Equipment: Spill Detection: Brief Summary of the Impact of the Spill: Geographic Area: *Reportable spill, as defined in 40 CFR Part 110, is a discharge of oil that violates applicable water quality standards or a discharge into or upon the navigable waters of the United States or adjoining shorelines in harmful quantities.

58 Albany SPCC - 56 FIGURE REPORTABLE SPILL HISTORY*, CONTINUED Date of Discharge(s): 6/11/1981 Location (Equipment or Operations): List of Discharge Causes: Material(s) Discharged: Amount of Discharges in Gallons: Amount That Reached Navigable Waters (if applicable): Effectiveness and Capacity of Secondary Containment: Cleanup Actions Taken: Dock While removing the crude oil line from north dock, approximately 5 to 10 gals of oil/water mixture missed the 55 gal drum and entered the water, which was previously boomed for dock line removal. We immediately placed oil absorbent pads into the water. No further action taken. Steps Taken to Reduce Possibility of Reoccurrence: Total Oil Storage Capacity of Tank(s) or Impoundment(s) From Which Material Discharged: Enforcement Actions: oil/water 5 to 10 (gallons) 5 to 10 (gallons) We immediately placed oil absorbent pads into the water. No further action taken. () Effectiveness of Monitoring Equipment: Spill Detection: Brief Summary of the Impact of the Spill: Geographic Area: *Reportable spill, as defined in 40 CFR Part 110, is a discharge of oil that violates applicable water quality standards or a discharge into or upon the navigable waters of the United States or adjoining shorelines in harmful quantities.

59 Albany SPCC COUNTERMEASURES AND SPILL RESPONSE PRACTICES FIGURE RESPONSE ACTIONS First Responder (Designated Person in Charge) Notify Supervisory Personnel/Qualified Individual. Supervisory Personnel/Qualified Individual Assume role of Incident Commander (IC). Conduct preliminary assessment of health and safety hazards. Notify Operations Manager or the next higher level of management. Call out spill response contractors. If safe, direct facility responders to shut down and control the source of the spill. If safe, direct facility responders to stabilize and contain the situation. This may include berming or deployment of containment and/or sorbent boom. Operations Manager (or Next Higher Level of Management) Notify Local Emergency Responders. Obtain the information necessary to complete the Spill / Incident Telephonic Notice (FIGURE 3.4-1). Notify appropriate agencies (FIGURE 3.4-2). National Response Center State Emergency Response Commission (SERC) Local Emergency Planning Committee (LEPC), if applicable External regulatory notifications District Director, Field Operations Notify On-Scene Coordinator and Vice President, Field Operations. Activate the Crisis Response Team, as the situation demands. Make external notifications (some circumstances may warrant the need for the Operations Manager to make the external notifications). On-Scene Coordinator Call out OSROs as needed. It is much better to demobilize equipment and personnel if not needed, than to delay contacting contractors if they are needed. Refer to FIGURE for OSROs. Evaluate incident potential and level of response. Activate all or a portion of the Incident Management Team (IMT), as necessary. Environmental Specialist will maintain contact with notified regulatory agencies. Refer to site-specific Emergency Response Plan for specific, well-defined procedures to facilitate recovery of damages. Incident Management Team Prepare/Update Spill / Incident Telephonic Notice. Initiate documentation procedures. Document all response actions taken, including notifications, agency/media meetings, equipment and personnel mobilization and deployment, and area impacted. Review enforcement measures as provided for by State and local statutes and ordinances. Assist in completion of regulatory agency notifications, if needed. Identify environmentally sensitive areas at risk and recommended protection based on trajectory.

60 Albany SPCC Source Control and Mitigation Each spill mitigation situation is unique and must be treated according to the circumstance present. In every situation, however, personnel safety must be assessed as the first priority. The potential for ignition and/or toxic exposure must be promptly evaluated. Spill mitigation procedures are listed in FIGURE FIGURE SPILL MITIGATION PROCEDURES TYPE MITIGATION PROCEDURE Failure of Transfer Equipment 1. Personnel safety is the first priority. Evacuate nonessential personnel or personnel at high risk. 2. Terminate transfer operations and close block valves. 3. Drain product into containment areas if possible. 4. Eliminate sources of vapor cloud ignition by shutting down all engines and motors. Tank Overfill/Failure 1. Personnel safety is the first priority. Evacuate nonessential personnel or personnel at high risk. 2. Shut down or divert source of incoming flow to tank. 3. Transfer fluid to another tank with adequate storage capacity (if possible). 4. Shut down source of vapor cloud ignition by shutting down all engines and motors. 5. Ensure that dike discharge valves are closed. 6. Monitor diked containment area for leaks and potential capacity limitations. 7. Begin transferring spilled product to another tank as soon as possible. Piping Rupture/Leak (under pressure and no pressure) 1. Personnel safety is the first priority. Evacuate nonessential personnel or personnel at high risk. 2. Shut down pumps. Close the closest block valves on each side of the rupture. 3. Drain the line back into contained areas (if possible). Alert nearby personnel of potential safety hazards. 4. Shut down source of vapor cloud ignition by shutting down all engines and motors. 5. If piping is leaking and under pressure, then relieve pressure by draining into a containment area or back to a tank (if possible). Then repair line according to established procedures. Fire/Explosion 1. Personnel safety is the first priority. Evacuate nonessential personnel or personnel at risk of injury. 2. Notify local fire and police departments. 3. Attempt to extinguish fire if it is in incipient (early) stage and if it can be done safely. 4. Shut down transfer or pumping operation. Attempt to divert or stop flow of product to the hazardous area (if it can be done safely). 5. Eliminate sources of vapor cloud ignition by shutting down all engines and motors. 6. Control fire before taking steps to contain spill. Manifold Failure 1. Personnel safety is the first priority. Evacuate nonessential personnel or personnel at high risk. 2. Terminate transfer operations immediately. 3. Isolate the damaged area by closing block valves on both sides of the leak/rupture. 4. Shut down source of vapor cloud ignition by shutting down all engines and motors. 5. Drain fluids back into containment areas (if possible).

61 Albany SPCC Spill Volume Estimating Early in a spill response, estimation of spill volume is required in order to: Report to agencies. Determine liquid recovery requirements. Determine personnel and equipment requirements. Estimate disposal and interim storage requirements. Some rapid methods to estimate spill size are: Transfer operations: Multiply the pumping rate by the elapsed time that the leak was in progress, plus the drainage volume of the line between the two closest valves or isolation points (volume loss = pump rate [bbls/min] x elapsed time [min] + line contents [bbl]) Tank overfills: Elapsed time multiplied by the pumping rate Visual assessment of the surface area and thickness (FIGURE 3.3-1); the method may yield unreliable results because: Interpretation of sheen color varies with different observers. Appearance of a slick varies depending upon amount of available sunlight, sea-state, and viewing angle. Different products may behave differently, depending upon their properties. FIGURE SPILL ESTIMATION FACTORS Standard Form OIL THICKNESS ESTIMATIONS Approximate Film Thickness inches mm Approximate Quantity of Oil in Film Barely Visible gals/mile 2 44 liters/km 2 Silvery gals/mile 2 88 liters/km 2 Slightly colored gals/mile liters/km 2 Brightly colored gals/mile liters/km 2 Dull gals/mile 2 1,167 liters/km 2 Dark ,332 gals/mile 2 2,237 liters/km 2 Thickness of light oils: inches to inches Thickness of heavy oils: 0.10 inches to inches

62 Albany SPCC Notifications FIGURE Spill / Incident Telephonic Notice INVOLVED PARTIES Reporting Party Suspected Responsible Party Name: Name: Phone: (Day) Phone: (Day) Position: (Evening) Company: (Evening) Company: Organizational Type: Private Citizen Address: Name: Company/Organization: Person Discovering Incident City: State: Zip: Private Enterprise Public Utility Local Government State Government Federal Government Were materials released? Yes No Calling for Responsible Party Yes No Date: Time: AM PM Incident Address/Location: INCIDENT DESCRIPTION Weather: Latitude: degrees min sec N Longitude: degrees min sec W Mile Post/River Marker: City/County: State: Source and Cause of Incident: Distance from City: Direction from City: Storage Tank Type: Above Ground Below Ground Unknown Tank Capacity: Facility Capacity: MATERIAL INFORMATION CHRIS Code Product Released Released Quantity (Include units of measure) Quantity in Water (Include units of measure)

63 Albany SPCC - 61 FIGURE Spill / Incident Telephonic Notice, CONTINUED INITIAL IMPACT Number of Injuries: Number of Deaths: Were there Evacuations? Yes No Number Evacuated: Was there any Damage? Yes No Damage in dollars (estimate): Is the Spill Contained within the boundaries of the facility? Yes No Direction of Flow: Action(s) Taken to Correct, Control or Mitigate Incident: RESPONSE ACTION(S) ADDITIONAL INFORMATION Any information about the incident not recorded elsewhere in the report (e.g., duration of spill, treatment or disposal measures). COMPLETED NOTIFICATIONS Report Phone Number Date Case Number Time Name Title NRC (800) *

64 Albany SPCC - 62 FIGURE NOTIFICATIONS AND TELEPHONE NUMBERS *24 Hour Number FACILITY RESPONSE TEAM NAME/TITLE PHONE NUMBER RESPONSE TIME (hours) Chris Rodden Assistant Operations Manager / AFSO Alternate Qualified Individual 1 James Allen LTO Qualified Individual Joe Bartczak Jamie Beranger (518) (Office) 1 Austin Blais 0.75 Eric Conklin 0.5 Frank Groff (518) (Office) 0.66 Daniel Bailiff (518) (Office) 0.5 Bob Breedon (518) (Office) 0.5 Edwin Garcia Ashley Gough 0.5 Curtis Graham 0.5 John Klein 0.5

65 Albany SPCC - 63 FIGURE NOTIFICATIONS AND TELEPHONE NUMBERS *24 Hour Number FACILITY RESPONSE TEAM NAME/TITLE PHONE NUMBER RESPONSE TIME (hours) Christopher J. Mullen 0.16 Michael Rottingen (518) (Office) 0.5 Joseph Harder 0.5 William Kolwaite 0.5 Henry Schoonmaker 0.16

66 Albany SPCC - 64 FIGURE NOTIFICATIONS AND TELEPHONE NUMBERS, CONTINUED *24 Hour Number NAME/TITLE Jesse Burdett East District Advisor EMERGENCY RESPONSE PERSONNEL AND BUSINESS UNIT NOTIFICATIONS PHONE NUMBER RESPONSE TIME (hours) 4 ICS POSITION District Work Team - East RESPONSE TRAINING TYPE Breinigsville Control Center N/A Corporate Response Team Eric Kovich Sr. Director of Health, Safety, and Environmental 4-6 Corporate Response Team, Environmental Affairs x x Robert Ingalls VP, Terminal Commercial Operations 4-6 Corporate Response Team Todd Gehringer Manager, Technical Services 4-6 Corporate Response Team, Central District Crisis Response Team x x Carl Ostach Vice President Domestic Operations 4-6 Corporate Response Team, Incident Commander x x x Robert Malecky President, Domestic Pipeline & Terminals Joseph Sauger SVP, Engineering & Compliance Services Karen Fernald Supv. Procurement / Supply Chain John Reinbold Group Leader- Compliance EMERGENCY RESPONSE TRAINING TYPE 1 Corporate Response Team Corporate Response Team, Engineering/Repair Corporate Response Team, Insurance Corporate Response Team, Regulatory Compliance Coordinator There are three different types of training described below including HAZWOPER, OPA, and Qualified Individual/Incident Command Training. An "x" has been placed in the applicable columns (type 1, 2, or 3) in the table above for the type of training completed by each individual. TYPE 1 DESCRIPTION 1 29 CFR HAZWOPER 2 OPA (Training Reference for Oil Spill Response) All Facility Personnel, SMT, QI Components 3 Qualified Individual/Incident Command Training x x x x x

67 Albany SPCC - 65 FIGURE NOTIFICATIONS AND TELEPHONE NUMBERS, CONTINUED *24 Hour Number NAME/TITLE Katherine Zeth Director HSSE EMERGENCY RESPONSE PERSONNEL AND BUSINESS UNIT NOTIFICATIONS PHONE NUMBER RESPONSE TIME (hours) 4-6 ICS POSITION Corporate Response Team/PIO, Safety/Training RESPONSE TRAINING TYPE x x x Jimmy Hausman Mgr., Terminal Operations 4-6 Corporate Response Team x Russell Miller Manager, HSSE Emergency Preparedness 4-6 Corporate Response Team/Planning x x x Todd Russo V.P., General Counsel & Secretary 4-6 Corporate Response Team Greg Stein Manager, Client Technologies 4-6 Corporate Response Team Scott Collier VP, Performance Assurance 4-6 Corporate Response Team Patrick Monaghan Asst. General Counsel & Chief Compliance Officer Craig Brown Corporate Response Team, PIO/Media Relations Corporate Response Team EMERGENCY RESPONSE TRAINING TYPE 1 Sr. Director - Engineering Services There are three different types of training described below including HAZWOPER, OPA, and Qualified Individual/Incident Command Training. An "x" has been placed in the applicable columns (type 1, 2, or 3) in the table above for the type of training completed by each individual. TYPE CFR HAZWOPER DESCRIPTION 2 OPA (Training Reference for Oil Spill Response) All Facility Personnel, SMT, QI Components 3 Qualified Individual/Incident Command Training

68 Albany SPCC - 66 FIGURE NOTIFICATIONS AND TELEPHONE NUMBERS, CONTINUED *24 Hour Number NAME/TITLE Environmental Products & Services of Vermont, Inc. (EP&S) Mac-Son Industrial Services EMERGENCY RESPONSE CONTRACTORS PHONE NUMBER (800) * (518) (518) * (518) * 1 Miller Environmental Group (800) * 2 National Response Corporation (NRC) (800) * USA , Ext 0 (International) RESPONSE TIME (hours) RESPONSIBILITY DURING RESPONSE ACTION Immediate spill response assistance. Disposal of Wastes. Oil Spill Removal Organization. Immediate spill response assistance. Disposal of Wastes. RESPONSE TRAINING TYPE Tier 2 & 3 Responder x x x Miller Environmental Group (RANDIVE, Inc.) (800) * (732) * 5 EMERGENCY RESPONSE TRAINING TYPE 1 There are three different types of training described below including HAZWOPER, OPA, and Qualified Individual/Incident Command Training. An "x" has been placed in the applicable columns (type 1, 2, or 3) in the table above for the type of training completed by each individual. TYPE CFR HAZWOPER DESCRIPTION 2 OPA (Training Reference for Oil Spill Response) All Facility Personnel, SMT, QI Components 3 Qualified Individual/Incident Command Training

69 Albany SPCC - 67 FIGURE NOTIFICATIONS AND TELEPHONE NUMBERS, CONTINUED *24 Hour Number Initial AFFILIATION PHONE NUMBER National Response Center (NRC) (800) * (202) * TIME CONTACTED Recommended Federal Agencies U.S. Environmental Protection Agency Region II (212) (212) USCG Activities NY (FOSC) New York Department of Environmental Conservation (DEC)(SERC) (718) Day (718) Evening State Agencies (800) * Spill Notification (518) (518) (Albany, NY) 911* NY State OEM (518) NY State Police (800) Local Agencies Local Emergency Planning Committee 911* (518) Local Evacuation Coordinator Fire & Safety Manager 911* Fire Departments Emergency Medical Services Hospital Albany Medical Center (518) USCG Classified OSRO's Environmental Products & Services of Vermont, Inc. (800) * (EP&S) (518) Glenmont, NY Miller Environmental Group (800) * Albany, NY Miller Environmental Group (RANDIVE, Inc.) (800) * Perth Amboy, NJ (732) *

70 Albany SPCC - 68 FIGURE NOTIFICATIONS AND TELEPHONE NUMBERS, CONTINUED *24 Hour Number AFFILIATION Recommended, Continued National Response Corporation (NRC) Great River, NY PHONE NUMBER USCG Classified OSRO's (800) * USA , Ext 0 (International) TIME CONTACTED Non-Classified OSRO's Mac-Son Industrial Services (518) * (518) * Fire Control National Foam - Red Alert (610) * Williams Fire & Hazard Control Information needed when calling in: Caller's name, Company Name, Location of incident, Current situation, Equipment/Foam currently available on site and Contact name and phone number of person in charge (281) * Emergency (409) * Emergency (800) Customer Support Media Relations MWW - Steven Some (609) (609) * Robert A. Simmons, P.E. (Environmental Science Services, Inc) Natural Resource Damage Assessment (985) * Mobile (225) ext 104 (Baton Rouge) (985) (Slidell) (225) (Fax) Radio Stations TV/Radio (Evacuation Notification) (518) Security US Security Associates (800) * Television Stations TV/Radio (Evacuation Notification) (518) Utilities Local Water Supply System Albany (518) Weather Weather Report (518) Wildlife Rehabilitation International Bird Rescue - U.S and International (888) * Barbara Callahan - Barbara.Callahan@ibrrc.org

71 Albany SPCC - 69 FIGURE NOTIFICATIONS AND TELEPHONE NUMBERS, CONTINUED *24 Hour Number AFFILIATION Recommended, Continued TRI-State (Wildlife clean-up & Rehabilitation) - Delaware PHONE NUMBER Wildlife Rehabilitation (800) Pager (800) Pager (302) Office (302) Fax Wildlife Center of Texas (281) Sharon Schmalz - sharonschmalz@wildlifecenteroftexas.com TIME CONTACTED

72 Albany SPCC Incident Management Team The Terminal ICS is based upon the National Incident Management System and is consistent with the ICS procedures utilized by many agencies and the oil industry around the world. First response to an incident at the Facility will be provided by the Local Response Team (LRT). The Crisis Response Team will respond, to the degree necessary, to incidents exceeding local capability. If a response exceeds the Local Response Team's capabilities, the Local Incident Commander (IC) will activate the Crisis Response Team. The first Company employee on scene will function as the Person-in-Charge until relieved by an authorized supervisor who will assume the role of on-scene Incident Commander. Transfer of command will take place as more senior management respond to the incident. For response operations within the control of the Local Response Team, the role of IC will typically be assumed and retained by Terminal Management. The Crisis Response Team (CRT), once fully staffed, is designed to cover all aspects of a comprehensive and prolonged incident response. The number of positions/ personnel required to staff the CRT will depend on the size and complexity of the incident. During a prolonged response, additional personnel may be cascaded in, and more than one level within the Team may be involved to sustain 24- hour operations. The Incident Command System (ICS) will be used as a method of integrating federal, state and local agencies into the IMT. The purpose of this system is to organize diverse responding agencies into one unified team. The IMT organization chart is provided in FIGURE The organization can be expanded or contracted as necessary. The ICS includes a Unified Command Structure consisting of three key On-Scene Coordinators: Federal On-Scene Coordinator (FOSC), State On-Scene Coordinator (SOSC) and the Responsible Party Incident Commander (RP). These three entities will share decision-making authority as Incident Commanders and will consult with each other regarding spill response management issues. The FOSC will coordinate all federal agencies involved in the response. The SOSC will coordinate all state and local agencies involved in the response activities. The Responsible Party Incident Commander will coordinate all company activities. Depending upon the size and complexity of the incident, additional federal and state agency personnel may integrate into the other functions of the IMT.

73 Albany SPCC - 71 FIGURE INCIDENT MANAGEMENT TEAM ORGANIZATION

74 Albany SPCC Response Resources The following response resources listed in FIGURE may be called upon to provide equipment, materials, and supplies that may be required to remove the maximum oil discharge anticipated from this Facility. Contact information for Contractor Response Resources are located in FIGURE Contracts for the companies that may provide response resources are located at the Corporate Office. FIGURE COMPANY AND CONTRACTOR RESPONSE RESOURCES * USCG Classified OSRO for facility COMPANY/CONTRACTOR *Environmental Products & Services of Vermont, Inc. (EP&S) Glenmont, NY Mac-Son Industrial Services Selkirk, NY *Miller Environmental Group Albany, NY *National Response Corporation (NRC) Great River, NY *Miller Environmental Group (RANDIVE, Inc.) Perth Amboy, NJ EQUIPMENT Full Response Capability per U.S. Coast Guard Classification Boom, boats, skimmers Full Response Capability per U.S. Coast Guard Classification Full Response Capabilities per U.S. Coast Guard Classification Commercial Diving Services

75 Albany SPCC Command Post The pre-planned locations for a Command Post and a reliable communications system for directing the coordinated overall response operations will be determined depending on the circumstances. Refer to FIGURE for guidelines in establishing a Command Post. COMMAND POST CHECKLIST Ensure adequate space for size of staff. Ensure 24 hour accessibility. Ensure personal hygiene facilities. Ensure suitability of existing communications resources (phone/fax/radio). Ensure suitability of private conference and briefing rooms. FIGURE COMMAND POST CHECKLIST Identify Command Post security requirements, safe location. Notify other parties of Command Post location; provide maps/driving directions. Determine staging areas and incident base locations. Identify future need to move, upgrade facilities. INITIALS DATE/TIME STARTED DATE/TIME COMPLETED

76 Albany SPCC Communications Normal Company communications to each facility are conducted via telephone lines, cellular telephones, two way radios, , fax machines, and pagers. Additional communications equipment (VHF portable radios with chargers and accessories, command post with UHF, VHF, single sideband, marine, aeronautical, telephone, and hard-line capability) may be provided by the Company or leased from a communications company in the area. Communications with government agencies, state police, and contractors can be conducted on portable radios. Refer to FIGURE for guidelines to establish communications. FIGURE COMMUNICATIONS CHECKLIST COMMUNICATIONS CHECKLIST INITIALS DATE/TIME STARTED DATE/TIME COMPLETED Develop a Communications Plan. Ensure adequate phone lines per staff element - contact local provider. Ensure adequate fax lines - contact local provider. Internet access necessary? Ensure recharging stations for cellular phones. VHF radio communications: Establish frequencies Assign call signs Distribute radios Establish communications schedule Ensure recharging stations for VHF radios. Determine need for VHF repeaters. Ensure copy machine available. Ensure communications resource accountability. Ensure responders have capability to communicate with aircraft.

77 Albany SPCC Waste Management Initial oil handling and disposal needs may be overlooked in the emergency phase of a response, which could result in delays and interruptions of cleanup operations. Initially, waste management concerns should address: Equipment capacity Periodic recovery of contained oil, and Adequate supply of temporary storage capacity and materials Segregation of incompatible waste types A general flow chart for waste management guidelines is provided in FIGURE An overall checklist for containment and disposal is provided in FIGURE FIGURE WASTE MANAGEMENT FLOW CHART