SPILL PREVENTION CONTROL AND COUNTERMEASURE

Transcription

1 SPILL PREVENTION CONTROL AND COUNTERMEASURE Knife River Asphalt Plant 1 Portable Facility Date of Last Plan Amendment or Technical Revision P.E. Certification: Date of Last Administrative Revision: July 7, 2014 Prepared by Ron Klinker For Knife River 4787 Shadow Wood Drive NE Sauk Rapids, MN Revision Date: 3/20/2017 Page 1 of 37

2 Requirement to Prepare and Implement SPCC Plan (c) The owner or operator of an onshore or offshore mobile Facility will prepare, implement, and maintain a SPCC Plan. A new SPCC Plan is not required each time the Facility is moved to a new site and the SPCC Plan may be a general plan. When the mobile or portable facility is moved to a new location, it will be located and installed using the discharge prevention practices outlined in the Plan for the Facility. Plan Certification 112.3(d) Knife River Asphalt Plant 1 I hereby certify that I or my agent have examined the facility, and being familiar with the provisions of 40 CFR part 112, attest that: This SPCC Plan has been prepared in accordance with good engineering practices, with consideration of applicable industry standards, and meets applicable regulatory requirements; Procedures have been established for equipment inspection & testing; and The Plan is adequate for this facility. Plan Management Approval 112.7(a) This Spill Prevention, Control and Countermeasure (SPCC) Plan will be implemented as herein described. I have personally examined and am familiar with the information contained in the Plan and all attachments, and based on my inquiry of those persons immediately responsible for preparing this Plan; I believe that the information is true, accurate and complete. Date Ron Klinker Environmental Manager Revision Date: 3/20/2017 Page 2 of 37

3 Owner Review and Log 112.5(b) In accordance with 40 CFR 112.5(b), a review and evaluation of this SPCC Plan is conducted at least once every five years. As a result of each review and evaluation, Knife River will amend the SPCC Plan within six months of the review to include more effective prevention and control technology if: (1) such technology will significantly reduce the likelihood of a spill event from the facility, and (2) if such technology has been field-proven at the time of review. I have completed review and evaluation of the SPCC plan for the Knife River Asphalt Plant 1, and (will) or (will not) amend the Plan as a result. Date Reviewed Reviewed By Remarks Next Review Due I have completed review and evaluation of the SPCC plan for the Knife River Asphalt Plant 1, and (will) or (will not) amend the Plan as a result. Date Reviewed Reviewed By Remarks Next Review Due I have completed review and evaluation of the SPCC plan for the Knife River Asphalt Plant 1, and (will) or (will not) amend the Plan as a result. Date Reviewed Reviewed By Remarks Next Review Due Any technical amendment to the SPCC Plan shall be certified by a Professional Engineer within six months after a change in the facility design, construction, operation, or maintenance occurs which materially affects the facility s potential for the discharge of oil into or upon the navigable waters of the United States or adjoining shorelines. Implement any amendment as soon as possible, but not later than six months following preparation of any amendment. Revision Date: 3/20/2017 Page 3 of 37

4 SPCC Plan Availability (e) A complete copy of this SPCC Plan will be kept on-site and made available for on-site review by the USEPA during normal working hours. Copies of the SPCC Plan do not need to be sent to the EPA. SPCC Plan Submittal And Spill Reporting This SPCC Plan will be submitted to the USEPA Region 5 Regional Administrator within 60 days, along with the other information specified in and a written report containing the items shown below, if either of the following occurs: The facility discharges more than 1,000 gallons of oil in a single discharge into or upon the navigable waters of the United States or adjoining shorelines in a single event; and/or The facility discharges more than 42 gallons (one barrel) of oil in each of two discharges into or upon the navigable waters of the United States or adjoining shorelines within any 12- month period. The written report is to contain the following information: Name of the facility; Name(s) of the owner or operator of the facility; Location of the facility; Date and year of initial facility operation; Maximum storage or handling capacity of the facility and normal daily throughput; Description of the facility, including maps, flow diagrams, topographical maps, and other maps; A complete copy of the SPCC Plan with any amendments; The cause(s) of spill(s), including a failure analysis of the system or subsystem in which the failure occurred; The corrective actions and/or countermeasures taken, including an adequate description of equipment repairs and/or replacements; Additional preventive measures taken or contemplated to minimize the possibility of recurrence; Such other information as the Regional Administrator may reasonably require pertinent to the plan or spill event. Revision Date: 3/20/2017 Page 4 of 37

5 CROSS REFERENCE INDEX US EPA SPCC REQUIREMENTS Section in 40 CFR 112 EPA SPCC Requirements Section / Page in this SPCC Requirement to prepare and implement a Spill Prevention, Control, and Countermeasure Plan 3(d) Professional Engineering review and certification Page 2 3(e) Distribution of plan and availability Page 4 Amendment of Spill Prevention, Control, and Countermeasure Plan by Regional Administrator 4(a) Facility discharges submit information to the Regional Administrator Page 4 Amendment of Spill Prevention, Control, and Countermeasure Plan by Owners or Operators 5(a) Amending the SPCC Plan Page 3 5(b) Review and evaluation of the SPCC Page 3 5(c) Professional Engineer certification of technical amendment Page 3 General requirements for Spill Prevention, Control, and Countermeasure Plans 7(a) Management commitment Page 2 7(a)(3) The physical layout of the facility Section 3/Page 8 and Figure 1 response Page 10 Page 13 Page 13 7(b) Plan a prediction of the direction, rate of flow, Section 3/Page 14 and total quantity of oil which could be discharged from the facility as a result of major equipment failure 7(c) Provide appropriate containment and/or Section 3/Page 14 diversionary structures or equipment to prevent a discharge 7(d) Impracticability Determination Section 3/Page 15 7(e) Inspections, tests, and records Section 4/Page 15 7(f) Personnel, training, and discharge prevention Section 4/Page 16 procedures 7(g) Security (excluding oil production facilities) Section 4/Page 16 7(h) Tank truck loading / unloading Section 4/Page 17 7(j) State Regulations Section 4/Page 18 Requirements for onshore facilities (petroleum oils) 8(b) Facility drainage Section 5/Page 18 8(c) Bulk storage containers Section 4/Page 19 8(d) Facility transfer operations, pumping, and facility Section 5/Page 25 process Requirements for animal fats and vegetable oils 12(b) Facility drainage NA 12(c) Bulk storage containers NA 12(d) Facility transfer operations, pumping, and facility process NA Revision Date: 3/20/2017 Page 5 of 37

6 Contents Requirement to Prepare and Implement SPCC Plan (c)... 2 Plan Certification 112.3(d)... 2 Plan Management Approval 112.7(a)... 2 Owner Review and Log 112.5(b)... 3 SPCC Plan Availability (e)... 4 SPCC Plan Submittal And Spill Reporting Section 1 Facility Owner/Operator... 8 Section 2 Facility Contacts... 8 Section 3 General Requirements for All Facilities 112.7(a)... 8 A. Discussion of Conformance 112.7(a)(1)... 8 B. Deviation from Requirements 112.7(a)(2)... 8 C. Facility Description 112.7(a)(3)... 8 D. Facility Storage Container Description, Capacity, Oil Type 112.7(a)(3)(i)... 9 E. Discharge Management 112.7(a)(3)(ii-vi)... 9 F. Discharge Notification Information and Form 112.7(a)(4) G. Discharge Procedures Organized 112.7(a)(5) H. Potential Spill Predictions, Volumes, Rates and Controls 112.7(b) I. Containment and Diversionary Structures 112.7(c) J. Demonstration of Practicability 112.7(d) SECTION 4 General Requirements - Facility Prevention Measures A. Inspections/Record Keeping 112.7(e) B. Personnel Training and Spill Prevention Procedures 112.7(f) C. Site Security 112.7(g) D. Facility Tank Car/Truck Loading/Unloading Operations 112.7(h) E. Brittle Fracture/Failure Evaluation Field-Constructed Tanks 112.7(i) F. Conformance to Other Discharge Management Requirements 112.7(j) SECTION 5 Specific Requirements; Onshore-Non Production Facilities A. Facility Drainage (b) B. Bulk Storage Tanks/Secondary Containment 112.8(c) C. Facility Transfer Operations, Pumping & Facility Process 112.8(d) SECTION 6 Certification of Applicability of the Substantial Harm Criteria (e) FIGURES Figure 1 - Site Location Map Revision Date: 3/20/2017 Page 6 of 37

7 Figure 2 - Facility Diagram APPENDICES Appendix 1 Unloading Tank Trucks to Aboveground Storage Tanks Appendix 2 Incident Report Appendix 3 Spill Response Duty Card Oil Handling Employees Appendix 4 Spill Response Duty Card Plant Supervisor Appendix 5 Monthly Tank System Inspection Checklist Appendix 6 Drainage Discharge Report Form Appendix 7 Certification of the Applicability of the Substantial Harm Criteria Checklist (e) Appendix 8 Set-up Checklist for New Plant Location Revision Date: 3/20/2017 Page 7 of 37

8 Section 1 Facility Owner/Operator Knife River North Central 4787 Shadow Wood Drive NE Sauk Rapids, MN Section 2 Facility Contacts Ron Klinker, Environmental Manager Dan Ranweiler, Asphalt Plants Manager Knife River North Central 4787 Shadow Wood Drive NE Sauk Rapids, MN (320) (320) Section 3 General Requirements for All Facilities 112.7(a) A. Discussion of Conformance 112.7(a)(1) Knife River is aware of the requirements of 40 CFR 112 and has complied with the requirements for providing a facility diagram, discharge reporting procedures, containment, inspection and testing, personnel training, and security at the oil storage and handling facilities located at this site. B. Deviation from Requirements 112.7(a)(2) There are no deviations from the requirements of 112.7(g),(h),(2), and (i). Subparts B and C of the rule do not apply. C. Facility Description 112.7(a)(3) Knife River Asphalt Plant 1 site is a portable asphalt plant. This plant generally operates within a 90 mile radius of St. Cloud, MN. This facility consists of an asphalt plant and associated equipment, equipment staging, and material stockpiling. Because of the portable nature of the plant, a site location map for the area is not presented as Figure 1. A typical Facility diagram for the temporary site provides an overall schematic for the plant and is provided as Figure 2. Oil and petroleum products are used to fuel Knife River heavy equipment and are used in the production of asphalt. The products are stored in aboveground storage tanks (ASTs) and other bulk containers (e.g., 55-gallons drums). Products are delivered to the site via cargo tank trucks during normal operating hours. Typical hours of operation are 6:00 a.m. to 5:30 p.m., six days per week. Personnel include plant Revision Date: 3/20/2017 Page 8 of 37

9 operators, truck drivers, and various labor personnel. The facility is attended during hours of plant operation. Correct implementation of this Plan is critical to achieving compliance with the prevention of oil pollution for this Facility. A checklist, which is contained in Appendix 8, has been developed to identify the tasks which are necessary for compliance with SPCC regulations for Facility diagram, secondary containment, spill prediction, spill response and personnel training. The checklist will be completed for each temporary location of the asphalt plant. The checklist will be completed by the Plant Supervisor prior to initiating operations at the Facility. A copy of the completed checklist will be provided to the Environmental Manager and also maintained at the temporary location during the operation of the Facility as part of this SPCC Plan. D. Facility Storage Container Description, Capacity, Oil Type 112.7(a)(3)(i) 1. Aboveground Storage Tanks Tank ID Volume(gal) Contents Tank Materials of Construction Location Tank ,000 Asphalt Cement Single Wall Steel Asphalt Plant Tank ,000 Asphalt Cement Single Wall Steel Asphalt Plant Tank Diesel Single Wall Steel Asphalt Plant Tank ,000 #6 Fuel Oil Double Wall Steel Asphalt Plant Tank ,000 Diesel Single Wall Steel Generator Van Tank ,000 Diesel Double Wall Steel Asphalt Plant A Facility diagram is included as Figure Underground Storage Tanks No underground storage tanks (USTs) exist at this facility. 3. Container Storage Areas Several drums ranging in size from 55 to 100 gallons may be stored in the generator van at any one time. These containers are used for the storage of various oil products (e.g., motor oil, gear oil, transmission fluid, hydraulic fluid) used during maintenance activities. 4. Oil Filled Equipment A 100 gallon tank containing oil for heat transfer is located on the frame of tank is used in a closed loop system. OFE is subject to the requirements of 40 CFR 112 for this Facility. E. Discharge Management 112.7(a)(3)(ii-vi) 1. Discharge Prevention Procedures (Loading & Unloading) (a)(3)(ii) Drivers are subject to Minnesota s Commercial Drivers License (CDL) requirements, including hazardous material endorsements, and have documented knowledge with safe handling of these Revision Date: 3/20/2017 Page 9 of 37

10 materials. Truck loading procedures are presented as Appendix 1 and are consistent with API Recommended Practice Discharge or Drainage Controls (a)(3)(iii) As described in Section 3.G., secondary containment is provided for all oil storage containers at this facility using impervious concrete structures designed and constructed to contain spills until cleanup occurs. Precipitation that accumulates in secondary containment structures will be inspected and drained. 3. Countermeasures for discharge discovery, response and cleanup (a)(3)(iv) In the event of a spill or leak, the following procedures will be followed: Response Procedures The person discovering the spill will immediately report the spill or leak to the Plant Supervisor, or his designate. If the spill occurs during a loading or unloading operation, the employee discovering the spill will attempt to isolate the leak if appropriate and if it is judged safe to attempt to do so. The first employee arriving at the site will Shut down all operations and maintenance activity Shut down all ignition sources, including vehicle operation Establish a perimeter with physical barriers to limit traffic The person discovering the spill may contact the local police department at 911 if necessary to establish and maintain the perimeter. Upon arrival, the Plant Supervisor or his designate will assess the nature and extent of the release and the potential threat to human health or the environment. As necessary, the Plant Supervisor will make arrangements to evacuate personnel, notify local authorities, advise if area control or evacuation of the surrounding area is recommended, and contact medical assistance, if required. The Plant Supervisor will take immediate action to control the spill and to contain the spill within the site property. If the size of the spill presents a threat to leave the site, personnel will be deployed with equipment or shovels to install diversion berms using available soil and earthen materials. Contact the designated spill cleanup contractor to assist in controlling and perform spill cleanup activities. The Plant Supervisor will notify the designated Knife River management personnel. The Plant Supervisor, or his designate will contact environmental regulatory agencies as appropriate, Upon containment and control of the release, the Plant Supervisor will assist the clean-up contractor personnel as appropriate. Revision Date: 3/20/2017 Page 10 of 37

11 To the extent feasible, the spilled material will be recovered and reclaimed. If required, the absorbents and contaminated soil and water will be disposed of at an appropriate facility, in compliance with Federal, state and local requirements. The Plant Supervisor will keep a log of activities during the spill event including the nature and extent of the spill, the response actions, any outside assistance, the quantity and disposition of spill materials, an assessment of environmental damage, and any contact with regulatory personnel. The Plant Supervisor may delegate responsibility to keep this log to other site personnel, but is responsible to review the log for accuracy. The Plant Supervisor, or his designate, is responsible for completing the following notifications and follow-up actions. Notification Any petroleum spill of 5 gallons or more will be immediately reported to the Minnesota Department of Public Safety, Division of Emergency Management at one of the phone numbers provided below. The State Duty Officer then notifies the appropriate federal, state, and local agencies (such as the U.S. EPA National Response Center, MPCA, MNDOT, DNR, State Emergency Response Commission, Local Emergency Planning Committee). Minnesota Duty Officer (within metro area) (612) Minnesota Duty Officer (outside metro area) (800) The Plant Supervisor will be prepared to provide the following: Exact facility address and phone number Date and time of the release Type of material spilled An estimate of the quantity of material released or spilled Exact release location, including the waterways which may be affected An estimate of the quantity spilled into navigable water Source and cause of the release A description of the affected medium (air, water, soil, etc.) Extent of actual and potential water pollution Any damages or injuries caused by the spill Steps being taken or proposed to contain and clean up the spill Steps being taken to minimize impacts Whether evacuation is/was necessary Names of individuals/organizations who have also been contacted A written report will be submitted to the U.S. EPA Regional Administrator within 60 days of the spill incident for any spill that exceeds 1,000 gallons or whenever two spills of 42 gallons or Revision Date: 3/20/2017 Page 11 of 37

12 more occur within a one year period. The written report will contain, at the minimum, the following information: Name and location of the facility; Name of owner/operator; Name and address of registered agent of the owner, if any; Date and year of initial facility operation; Maximum storage or handling capacity of oil of the facility; Facility description with maps, flow diagrams and topographical maps; SPCC Plan and any amendments; Cause of spill with failure analysis; Exactly what and how much was spilled; Corrective action taken with description of repairs and replacements; Additional preventive measures taken or contemplated to minimize the possibility of recurrence; and, Other information pertinent to the SPCC Plan or spill event. Follow-up Actions Return all emergency response equipment and materials to their proper location and status. Review emergency, determine the cause of the release, and take actions to prevent a recurrence under similar circumstances. Records The Plant Supervisor will prepare a summary of the incident for entry into the SPCC Plan and incorporation into the annual employee discharge briefings. Incident reports will be kept on file for a period of 3 years from the date of the report. Emergency Response Equipment Equipment Location Loaders, Dump Trucks On-Site Hand Shovel Shop, Trucks, etc. Soil and Earthen Materials Throughout Facility SPCC Plan Response Card Main Office Fire Extinguisher(s) Throughout Facility Equipment Absorbent Socks/Spill Kit SPCC Plan Location Shop Main Office Revision Date: 3/20/2017 Page 12 of 37

13 Additional equipment to respond to a spill such as loaders, dozers, excavators, etc. are available by calling Dispatch located at the Sauk Rapid Corporate Office at the following numbers: (320) or Methods of Disposal of Recovered Material (a)(3)(v) Liquid oil will be recovered via vacuum truck or other means and transported to a permitted facility (e.g., East Side Oil) to be reclaimed/recycled, or processed on site if appropriate. Contaminated soils and absorbent materials will be disposed of at a permitted waste disposal facility that is authorized to accept such waste. Consideration will also be given to land treatment or bioremediation of oil-contaminated soil consistent with federal, state, and/or local regulatory requirements. 5. Contact List and Phone Numbers (a)(3)(vi) Name Primary Telephone Secondary Telephone Minnesota Duty Officer (800) (612) Police/Fire Department 911 N/A Dan Ranweiler, Asphalt Manager (320) (320) Ron Klinker, Environmental Mgr. (320) (320) Bill Ellis, Safety Manager (320) (320) East Side Oil Co. (Oil Recovery) (320) N/A WCEC (888) N/A F. Discharge Notification Information and Form 112.7(a)(4) To assist the Plant Supervisor in compiling the necessary information in the event of a Spill, an Incident Reporting Form is provided in Appendix 2. G. Discharge Procedures Organized 112.7(a)(5) To assist the Plant Supervisor and other response personnel, the Spill Response Duty Cards are provided as pull out sections in Appendix 3 and Appendix 4. H. Potential Spill Predictions, Volumes, Rates and Controls 112.7(b) To assist the Plant Supervisor and other response personnel, the facility storage areas, potential type of failures, volumes, rate and direction of flow are tabularized below. The volume of the containment structure is also presented. Revision Date: 3/20/2017 Page 13 of 37

14 Table 3H Potential Spill Predictions, Volumes, Rates and Controls Tank ID Volume(gal) Contents Aboveground Storage Tanks Tank ,000 Tank ,000 Asphalt Cement Asphalt Cement Tank Diesel Tank ,000 #6 Fuel Oil Tank ,000 Diesel Tank ,000 Diesel Truck Loading/Unloading Operations Tanker Unloading 50 Diesel Vehicle Fueling 25 Diesel Other Equipment/Storage Areas Oil Drums Oil Type of Failure Tank Rupture Tank Rupture Tank Rupture Tank Rupture Tank Rupture Tank Rupture Hose Rupture Hose Rupture Open Drum Topple Rate (gpm) Instantly Instantly Instantly Instantly Instantly Instantly Instantly Flow Direction Contained Contained Contained Contained Contained Contained Site Dependent, See Figure 2 Site Dependent, See Figure 2 Within Van I. Containment and Diversionary Structures 112.7(c) All bulk storage containers at this facility have containment systems. The type of construction, volume, and available freeboard associated with each secondary containment structure is tabularized below. Table 3I Containment area construction and containment volume for storage tanks Secondary Containment Tank ID Volume(gal) Type Length(ft) Width(ft) Height(ft) Volume(gal) Containment Tank ,000 Earth Berm , % Tank ,000 Earth Berm , % Tank Lined Berm % Tank ,000 DW Steel >100% Tank ,000 Steel , % Tank ,000 DW Steel >100% Tanks and contain asphalt cement, a thermoplastic material that softens when heated and hardens upon cooling. Due to the fact that asphalt cement is stored in a heated state, it will exhibit viscous flow behavior. If spilled, asphalt cement rapidly cools and hardens prior to Revision Date: 3/20/2017 Page 14 of 37

15 infiltration into the soil beneath it. Similarly, asphalt cement will flow horizontally until it cools and hardens. The flow of asphalt cement can easily be stopped with earthen materials. Under Minnesota Rules ch (Above Ground Storage Tank Rules), asphalt cement tanks are classified as Type C tanks and are mostly exempt from the requirements for secondary containment. For ASTs installed on November 2, 1998, or later, and for ASTs installed before that date which are lifted or moved after that date, the area of secondary containment which is directly under the tank will be designed to allow for visual detection of a release of a substance through the tank floor. Type C tanks are required to have a minimum of three feet of soil at 1 x 10-3 cm/sec hydraulic conductivity soils if the tank is less than 10 feet from the water table or within 100 feet of Class 2 water. If the tank is located more than 10 feet above the groundwater table, there is no hydraulic conductivity requirement for underlying soils. Based on the site-specific, silty-sand soils, it is assumed that the hydraulic conductivity requirement is met for the purposes of compliance with Minnesota Rule Due to the thermoplastic properties of asphalt cement, the material does not infiltrate into the soil and the containment area does not need to be lined. Native soils are sufficiently impervious to asphalt cement to prevent a vertical release from the area of containment. As part of this plan and supplemental to secondary containment, response actions have been designed to manage a discharge of asphalt cement should it occur. These actions, or spill countermeasures, make available personnel and equipment at the Facility. These measures can be effectively implemented in a timely manner to also prevent asphalt cement from reaching the surface water at the Facility. J. Demonstration of Practicability 112.7(d) Knife River is not deviating from secondary containment requirements; therefore, a contingency plan is not required. SECTION 4 General Requirements - Facility Prevention Measures A. Inspections/Record Keeping 112.7(e) The site is inspected and documented by site employees at least monthly. A copy of the monthly inspection checklist is provided in Appendix 5. The monthly tank inspection generally follows the Steel Tank Institute, SP001 standard. The inspection concentrates on the condition of the storage tanks and associated piping systems. During the monthly site inspections, all tanks, containment structures, valves, pipes, and other equipment are inspected. Revision Date: 3/20/2017 Page 15 of 37

16 Because the asphalt tanks are jacketed with insulation material for energy efficiency, the surface of the tank and some appurtenances are not directly visible for inspection. Under Minnesota Rules ch. 7151, asphalt cement tanks are classified as exempt from the requirements for corrosion inspection and integrity testing. This is based on the viscous nature of the asphalt cement which is stored in the tank. The rules state that a monthly visual inspection should include a walk-through to provide a visual examination of the exterior surfaces of tanks, piping, valves, pumps, and other equipment for cracks, corrosion, releases, and maintenance deficiencies. Deviation from Steel Tank Institute, SP001 standard for the asphalt cement tanks is acceptable based on good engineering practices which are codified in Minnesota Above Ground Storage Tank Rules. Length of time records kept: inspection, training, and tank integrity testing records are retained for at least three years. It is recommended the tank integrity testing records (where applicable) are maintained at least ten years, or until another inspection of the tanks has occurred. B. Personnel Training and Spill Prevention Procedures 112.7(f) 1. Personnel instructions: All new employees with oil handling responsibilities will review the oil discharge briefing material within one week of their starting working at the site. Other training deemed appropriate by the Knife River management will be on an as-needed basis. 2. Designated person accountable for spill prevention: Dan Ranweiler, Plant Supervisor, is the designated Plant Supervisor who is accountable for spill prevention and emergency response at the Knife River Asphalt Plant 1 Ron Klinker, Environmental Manager, is designated as the backup to the Plant Supervisor in the event of an emergency response event. 3. Spill prevention briefings: Spill prevention briefings are presented each year to all oil-handling employees during winter training. The briefings will include: Equipment procedures to prevent the discharge oil Discharge procedure protocols spill response Applicable pollution control laws, rules and regulations General facility operations Contents of the facility s SPCC Plan Recent spills and new precautionary measures, if applicable Revision Date: 3/20/2017 Page 16 of 37

17 Employee feedback and recommendations are encouraged in spill prevention and operation. Sign-in sheets, which include the topics of discussion at each meeting, are maintained for documentation. C. Site Security 112.7(g) 1. Oil Handling, Processing, and Storage Area Security Security measures used to prevent releases during off-hours include a locked gate at the site entrance, de-energized dispensing pumps, locked valves, and tanks/drums located inside buildings that are only accessible to authorized personnel. The Facility is illuminated by lights in the evening and is attended by Site personnel during normal business hours. The Facility is designed and operated to provide "Equivalent Environmental Protection" to deter acts of vandalism or unauthorized access. This includes: Topography of the Site prevents vehicle access outside the Facility control points. Restricting access to operational components. Equipment cannot be operated without electrical power. This equipment is secured during non-operational hours. The Facility will typically have night-time security lighting to discourage unauthorized access. These features, combined with impervious concrete dikes that would contain oil and petroleum products in the event a release occurs, provide the necessary security. 2. Flow valves secured: There are no master flow or drain valves on the diesel tanks. The fuel dispensing pumps on the diesel ASTs are connected through dedicated lines on the tank. Other Oil Storage Areas: There are no master flow or drain valves on all other tank. 3. Pump controls or starter controls locked: Dispensing of oil and petroleum products at the facility is limited to the two diesel ASTs. The fuel pump switches for the diesel fuel pumps are de-energized during non-operating hours. 4. Load/Unload connections sealed: Loading/unloading connections on each tank are capped when not in use. Dispensing hose nozzles are stowed upright when not in use. 5. Lighting to detect spills: Adequate lighting is provided in and around the Facility operations areas. D. Facility Tank Car/Truck Loading/Unloading Operations 112.7(h) Revision Date: 3/20/2017 Page 17 of 37

18 This facility does not have a loading/unloading rack. Therefore, the requirements of 112.7(h) are not applicable. Areas where oil is transferred but no loading or unloading rack is present are subject to general secondary containment requirements in 40 CFR 112.7(c). In lieu or secondary containment, procedural countermeasures have been established for potential spill control. The design of spill control countermeasures considers the following facility conditions: The reasonably expected sources and causes of a discharge. The reasonably expected maximum rate of discharge. The ability to detect and react to the discharge. The reasonably expected duration of the discharge. Critical Scenario: A fuel truck is pumping diesel from a tanker truck into the on-site storage tank with an attendant present throughout the operation. Details: The truck is pumping at a rate of 100 gallons per minute. The reasonably expected source and cause of a discharge is a ruptured flexible transfer hose. A pump shutoff switch and valve are present and accessible to the attendant. An evaluation determines that the discharge will not impede the attendant s access to the shutoff valve and that he can safely shut down transfer operations within 30 seconds of the hose rupture. Calculations: The maximum reasonably expected discharge is calculated to be: 50 gallons Conclusion: Spill control countermeasures are designed for a most likely discharge event of 50 gallons. This is satisfied by a combination of spill response equipment (absorbent aggregate material) and an immediate active/manual response. E. Brittle Fracture/Failure Evaluation Field-Constructed Tanks 112.7(i) All of the tanks in use at this facility are shop constructed. Therefore, the evaluation specified in 112.7(i) is not applicable. F. Conformance to Other Discharge Management Requirements 112.7(j) The MPCA reporting of spills differs from Federal requirements. The following are general circumstances requiring reporting: Any spill outdoors, including spills to storage tank containment areas. Spills entering storm or sanitary sewer systems. Spills with the potential to directly impact the environment or human health even if thought to be adequately contained. Revision Date: 3/20/2017 Page 18 of 37

19 Any spill exceeding 5 gallons. SECTION 5 Specific Requirements; Onshore-Non Production Facilities A. Facility Drainage (b) 1. Drainage from diked storage areas: Diked storage areas at this facility include earthen berms surrounding AC tanks and Due to the viscosity of the asphalt cement the earthen material will contain it but generally allow any rain water to infiltrate. Typically the net evaporation rate exceeds the precipitation rate; any accumulated precipitation is normally allowed to evaporate. If liquid accumulates beyond a manageable amount, it would be drained from the dike by breaching the berm. Drained water will infiltrate. If the liquid contains free product or oil sheen, it will be manually removed using absorbents, etc. or disposed of at a permitted used oil recycler (e.g., East Side Oil Co.). Liquid that is free of oil or oil sheen can be discharged onto the ground surface, but only after inspection and documentation using the Drainage Discharge Report Form provided in Appendix Valves used on diked area storage Drainage valves are not incorporated into the design of the diked storage areas. 3. Plant drainage systems from undiked areas: Site drainage at all loading/unloading areas is such that any released product would pool and be contained on the property until cleanup occurs. If a spill occurs during delivery operations, drivers shall immediately the Plant Supervisor and initiate Knife River notification, spill cleanup and reporting procedures. 4. Final discharge of drainage: See Section 5.A (3) above. 5. Facility drainage systems & equipment: This facility does not have any drainage water treatment systems or drainage equipment. B. Bulk Storage Tanks/Secondary Containment 112.8(c) 1. Tank compatibility with its contents: The aboveground storage tanks (ASTs) are constructed of materials which are compatible with the various oil and petroleum products that are used and stored at this facility 2. Diked area construction and containment volume for storage tanks: Revision Date: 3/20/2017 Page 19 of 37

20 See Table 3I above. 3. Diked area, inspection and drainage of rainwater: Drainage valves are not incorporated into the design of dikes that surround some of the oil storage tanks. Precipitation that accumulates in the diked areas is typically allowed to evaporate. If a sufficient level of water accumulates, the water will be removed by using a portable pump, or vacuum truck as required. If an oil sheen or small accumulation (less than 1 gallon) of oil is observed, an absorbent pad will be used to remove the oil from the accumulated water. Water that accumulates in the dike will be discharged to the ground using the Drainage Discharge Report Form provided in Appendix 6 and only if free from visible oil sheen. 4. Corrosion protection of buried metallic storage tanks: No buried metallic storage tanks exist at the Knife River Asphalt Plant 1 facility. 5. Corrosion protection of partially buried metallic storage tanks: No partially buried metallic storage tanks exist at the Knife River Asphalt Plant 1 facility. 6. Aboveground tank periodic integrity testing: This section of the SPCC Rule requires that each aboveground container be tested or inspected for integrity on a regular schedule and when a material repair is made. Tanks at this site will be inspected in accordance with the Steel Tank Institute SP001 AST Inspection Standard. 7. Control of leakage through internal heating coils: Internal heating coils are not installed on any tank at this facility. Therefore, the requirements specified in 112.8(c)(7) are not applicable. 8. Tank installation fail-safe engineered: All tanks at the bulk plant are in dedicated service and no automatic controls are used. Fast responding level gauges are provided to monitor product inventory. Filling procedures allow tanks to be filled to a safe height, which is designated to be 95% of the listed tank capacity. The tanks are not equipped with high-level alarms. All filling operations are performed manually with temporary loading hoses. The tank truck driver performs the tank unloading operation, with direct control of the fuel/oil flow. The driver confirms tank liquid level visually to confirm adequate ullage exists in the event of a float level gauge malfunction. 9. Observation of disposal facilities for effluent discharge: There is no discharge of treated effluents at this facility. 10. Visible oil leak corrections from tank seams and gaskets Visible oil leaks are reported to management so that they can be fixed immediately. On-site maintenance personnel may correct minor piping leaks. Repairs to the structural components of Revision Date: 3/20/2017 Page 20 of 37

21 the tank shell will be performed by a licensed tank repair and service company after arrangements have been made to pump off the stored liquid to another suitable storage tank. Measures will be taken to minimize and mitigate the leak, while awaiting repair. The facility personnel will make arrangements to clean up any spilled oil immediately. 11. Appropriate position of mobile or portable oil storage tanks: All tanks used at this facility are mobile or portable oil storage containers. Requirements of 112.8(c)(11) are applicable and are met by this facility. C. Facility Transfer Operations, Pumping & Facility Process 112.8(d) 1. Buried piping installation protection and examination: No buried pipe exists or reportedly exists at the facility. The requirements of 112.8(d)(1) are therefore not applicable to this facility. 2. Not-in-service and standby service terminal connections: Due to the relatively short runs of pipe installed at this facility, the origin and direction of flow are apparent to the operators and the contents are clearly visible from the adjacent tank signs. Loading connections are capped when not in use. Dispensing hose nozzles are stowed upright when not in use. 3. Pipe supports design: Pipe supports are constructed of steel. Elbow joints have been installed in each line and provide adequate thermal expansion and contraction for the short run of pipe. 4. Aboveground valve and pipeline examination: All piping used for oil and/or fuel transfer will be maintained in an aboveground state. Piping at the site operates at low pressure and is used intermittently for dispensing. Integrity testing of piping will not be required as it can be visually inspected in its entirety as desired. The aboveground valves and piping are examined during the monthly inspection discussed in Section 4. These inspections are documented (see Appendix 5). 5. Aboveground piping protection from vehicular traffic: All of the aboveground hard piping at this facility is located within the secondary containment structures and protected against impact from vehicular traffic by concrete dikes. The only piping located outside of diked areas is the flexible hoses used for fuel dispensing, which are stored upright when not in use. Therefore, a warning sign is not needed at this facility to protect piping from vehicular traffic. Revision Date: 3/20/2017 Page 21 of 37

22 SECTION 6 Certification of Applicability of the Substantial Harm Criteria (e) An assessment of the applicability of the Substantial Harm Criteria was conducted and found not to apply to this facility. No Facility Response Plan was prepared. The certification is provided as Appendix 7. Revision Date: 3/20/2017 Page 22 of 37

23 FIGURES Figure 1 - Site Location Map Revision Date: 3/20/2017 Page 23 of 37

24 Figure 2 - Facility Diagram Revision Date: 3/20/2017 Page 24 of 37

25 APPENDICES Appendix 1 Unloading Tank Trucks to Aboveground Storage Tanks 1. Introduction Aboveground storage tanks (AST) may be situated in various locations, depending on the regulations of the jurisdiction where the tank is located. Tanks may be located at ground level (or elevated) with diked or walled areas or special enclosures. Aboveground tanks may also be located below the ground level in vaults, or pits. All of these create unique situations and potentials hazards that must be taken into consideration on order to make a safe delivery All clearances should be checked when maneuvering to enter and exit a customer location of deliver petroleum products into aboveground tanks, tanks enclosed in dikes, wall or special enclosures and tanks in vaults, or pits. Drivers should use extreme caution, paying particular attention to clearances to fixed objects, and remaining aware of potential for other vehicles to move unexpectedly. Be particularly observant of the immediate area when backing the tank truck. It may be advisable to get out of the truck and check the rear for obstacles or place traffic cones to mark a path, before backing the truck. Maneuvering in close quarters, particularly backing, presents an increased risk of accidents Vapors are ignitable when mixed with air in the proper portions and a source of ignition is present. Therefore all sources of vapors and ignition must be controlled or eliminated before or during unloading. There are several potential sources of vapors during delivery, including but not limited to: vents, spills, leaks, hose rupture, customer spill at dispenser island or receiving tank overflow. Sources of ignition include, but are not limited to, smoking, open lights, heaters or fires, running engines, fans or electrical equipment. Ensure a fire extinguisher is readily available at the unloading area and in good working order. If unsafe conditions such as leaks or concentration of vapors or sources of ignition occur during unloading, stop immediately until these hazards are controlled or eliminated Preventing product spills or overflows in one of a driver s most important responsibilities when unloading. Even small spills or drips have the potential for severe environmental consequences, as well as creating an unsafe situation, especially enclosed areas. It is recommended that a fully equipped spill kit be readily accessible and is used by the driver in the event a spill or leak occurs on the ground outside the vault, pit or tank enclosure US DOT regulations and state fire codes require that divers remain within 25 feet (8 meters) of and have an unobstructed view of the cargo tank. If for any reason the driver has to leave the immediate unloading area, the driver must shut down the entire operation, close all openings to the tank and return all hoses to the proper storage areas. Revision Date: 3/20/2017 Page 25 of 37

26 2. Spotting the Vehicle Drivers should pay special attention to personnel and vehicles, both parked and moving to control potential hazards and prevent interruption of delivery. Drivers should also pay attention to avoid obstacles such as canopies, building overhangs, guard posts/rails, pumps, trash dumpster, etc., when moving the tank truck at the customer s location The deliver tank truck should, if possible, be spotted on level grade and 25 feet (8meters) upwind from any vent that emits vapors. The tank truck should not be parked or left standing near a building in a depressed or enclosed area that will tap vapors or liquids, which are ignitable The driver should apply the parking brake, place transmission in lowest gear and place wheel chocks, if provided, to prevent accidental movement. Place the transmission in the lowest gear if the power take off (PTO) pump will not be used. Turn off all unnecessary lights and electronic devices. Turn off the ignition. Even if the truck s engine will be used to pump off the product, excessive idle time will be eliminated by shutting off the truck and restarting it when after preparing to begin pumping. If PTO is not to be used, turn off engine and remove keys. 3. Before Unloading Some tank trucks are equipped with unloading valves on both the curbside and the street side of the tank truck. Unloading fittings should not be kicked or thrown from one side of the tank truck to the other as this will damage the edges and cause leaks. Drivers should: 3.1. Check for hot brakes and then strategically place no smoking signs and/or traffic cones around the tank truck and the unloading area to warn vehicles and pedestrians from entering the delivery area Check the area for possible sources of ignition (i.e. smoking, open lights, heaters or fires, other running engines, fans or electrical equipment). Allow no sources of ignition and do not allow anyone to smoke in the vicinity of unloading Verify that you are at the correct customer location. Correctly identify the product designation of each receiving tank, using the color-coding or the product nametag. NOTE: Some locations may utilize a color-coding or other system different from API The driver should check with the customer or service station management to assure familiarity with the color-coding or other system used Be sure the receiving tank(s) will hold the full load. Ask consignee, when available, the following questions: Will the receiving tank hold the entire quantity to be unloaded Revision Date: 3/20/2017 Page 26 of 37

27 Is the receiving tank vented? Are the valves open? How do you dispose of residue? If the consignee is not available, and you are required to manually gauge the receiving tank(s), be sure to calculate the inventory using the correct conversion charts to be certain there is ample outage to safely receive the delivery without danger of spillage or overfill Use extreme caution if required to climb over dikes or walls, into vaults pits and onto tops of aboveground tanks. See Caution. The driver must decide whether these are safe to climb. Use caution when walking on dikes or walls or around pits and vaults particularly if they are wet or icy. If climbing is necessary, maintain 3 points of contact with the ladder. 4. Unloading CAUTION: Aboveground storage tanks located in vaults, pits and enclosures shall be provided with filling connections and gauges without having to enter into the vault, pit or enclosure. Drivers should be aware that vaults, pits and enclosures are considered confined spaces and entry may require permits and special precautions. Employers shall identify each aboveground tank located in a vault pit or enclosure, determine whether or not the area around the tank should be classified as permit required confined space or non-permit required confined space, and indicate this on the tank identification card. Drivers shall be trained and educated concerning confined space entry requirements and prohibitions, should entry into such spaced be required for gauging, sampling or spill cleanup Whenever possible, drivers should use the customer s (consignee s) pump and follow their procedures. NOTE: If the customer s procedures are not clear, drivers should contact the customer (consignee) or the dispatcher/supervisor for further instructions If drivers use the PTO pump on the tractor, the valves on the consignee s unloading lines will be set to bypass the pump, if present Close all valves not being used. Connect the bonding cable from the tank truck to the tank fill pipe or other bonding connection before beginning any other operations Connect the vapor recovery hose (if so equipped), closing both camlock ears completely, before unloading product. The vapor recovery system shall be the first piece of equipment connected and the last piece disconnected. If there is a problem with the receiving tank s vapor recovery system that causes it to be unusable, contact the dispatcher or terminal manager before continuing. If the customer location is not equipped with vapor recovery, remove the dust cap from the tank truck vapor- Revision Date: 3/20/2017 Page 27 of 37

28 inlet-line to prevent a vacuum from being created in the tank truck while unloading Connect a pressure hose to the above ground storage tank fill connection, then to the pump outlet. Precautions should be taken to ensure the hose connection and locking devices and are properly secured. Check for the presence of a check valve in the unloading line. CAUTION: High-pressure hoses will be used on the pump discharge Connect the suction hose to the pump inlet, then to the tank truck compartment to be unloaded. Double check to assure that the truck tank compartment and the receiving tanks contain the same product Open the safety valves and the valve on the tank truck compartment to be unloaded Start the engine (or customer s pump). Check all hose connections for tightness and ensure they are positioned without sharp bends. Hoses larger than 2 inches in diameter should be supported to prevent strain and/or flexing from vibration. Also make sure camlocks are secured with a flexible cord (for example, a tiedown strap) if the cam and grove coupler is not already equipped with a locking device such as a clip or an automatic lock Increase engine speed to the manufacturers specified fast idle setting for PTO operation (typically rpm). Check hose connections and valves for leaks, and verify that product is flowing to the proper receiving tank. Make sure the vents are functioning properly on both the receiving tank and the truck tank. During the remainder of the of the unloading process, remain in the immediate unloading area within 25 feet (8 meters) and have an unobstructed view of and access to the hoses/fittings until delivery is completed and hoses are returned to the truck As each tank truck compartment is emptied, turn the product/compartment indicator dial to empty, if so equipped. Check the sight glass (if equipped) to be sure product has stopped flowing. Check the air safety valve pressure gauge,(if so equipped) to be sure the valve did not close before the tank truck compartment emptied. Drain the suction line into the pump. Disengage the PTO, and move the hose to the next tank compartment (if necessary) When pumping is finished, the driver should walk the suction hose to the pump. Walk the pressure hose to the AST fill connection and shut AST fill connection valve. Disengage the PTO and shut off engine. Disconnect suction line. Disconnect pressure line carefully, relieving the pressure, and cap the AST fill connection. Place any residual product into approved container Disconnect the ground cable. Return all equipment to storage. Revision Date: 3/20/2017 Page 28 of 37