Spill Prevention Control andCountermeasure Plan

(SPCC)

For

Killark ElectricSt. Louis, MO

Revised: 04/15/2016

Table Of Contents

Section Title

1 Facility Owner and Operator2 Facility Conformance Discussion3 Facility Description4 Oil and Non-Oil Storage5 Facility Drainage6 Secondary Containment, Discharge Prevention Measures, and Discharge Response7 Disposal of Recovered Materials8 List of Plant Emergency Personnel, Federal and State Agencies and Cleanup

Contractors9 Notification Procedure10 Emergency Response Due to Major Equipment Failure or Accident11 Commitment to Controlling the Spill12 Inspection, Test and Records13 Personnel Training14 Security Measures15 Record Keeping16 Review, Evaluation and Amendment

Appendix ATruck Transfer and Containment ProceduresAppendix BSpill Clean-Up MaterialsAppendix CAbove Ground Storage Tank Inspection Record and SPCC Equipment/ Storage Inspection ReportAppendix DCertification of SPCC TrainingAppendix ESPCC Review/Evaluation and Amendment LogFigure 1Oil Storage LocationsFigure 2Potential Discharge Volumes and Direction of Flow

SPCC Cross ReferenceProvision Description of Section Section(s)

§ 112.3(d) Professional Engineer Certification Not Applicable§ 112.3(e) Location of SPCC Plan 15§ 112.4 Agency Reporting 9§ 112.5 Plan Review and Revision 16§ 112.6 Qualified Facility Plan Requirements Management

Approval§ 112.7 Management Approval Management

Approval§ 112.7 Cross-Reference with SPCC Rules SPCC Cross Reference§ 112.7(a)(1) Equivalent Environmental Protection 2§ 112.7(a)(2) Deviation from SPCC Requirements Management

Approval§ 112.7(a)(3) Facility Layout/Facility Diagram 4 and Figure 1§ 112.7(a)(3)(i) Container Contents and Capacity 4§ 112.7(a)(3)(ii) Discharge Prevention Measures 6§ 112.7(a)(3)(iii) Discharge/Drainage Controls, Procedures 6§ 112.7(a)(3)(iv) Discharge Response and Cleanup Measures 6§ 112.7(a)(3)(v) Disposal Methods of Recovered Material 7§ 112.7(a)(3)(vi) Agency Contact List and Phone Numbers 8§ 112.7(a)(4) Discharge Notification 9§ 112.7(a)(5) Discharge Response 10§ 112.7(b) Potential Discharge Volumes and Direction of

Flow 10 and Figure 2

§ 112.7(c) Secondary Containment and Diversionary Structures 6

§ 112.7(d) Practicability of Secondary Containment Not Applicable§ 112.7(e) Inspections, Tests, and Records 12§ 112.7(f)(1) Personnel, Training and Discharge Prevention

Procedures 13

§ 112.7(f)(2) Responsible Person for Oil Discharge Prevention 11

§ 112.7(g) Security 14§ 112.7(h) Loading/Unloading 6 and Appendix A§ 112.7(i) Brittle Fracture Evaluation Requirements Not Applicable§ 112.7(j) Conformance with State Requirements 2§ 112.7(k) Oil Filled Operational Equipment Not Applicable§ 112.8(a) General Requirements for Onshore Facilities Management

Approval§ 112.8(b)(1)§ 112.12(b)(1) Drainage from Diked Storage Areas Not Applicable§ 112.8(b)(2)§ 112.12(b)(2)

Use Open/Close valves; Inspect Stormwater before Discharging Not Applicable

§ 112.8(b)(3)§ 112.12(b)(3) Drainage from Undiked Areas Not Applicable§ 112.8(b)(4)§ 112.12(b)(4) Spill Diversion System Not Applicable

Provision Description of Section Section(s)§ 112.8(b)(5)§ 112.12(b)(5) Provide 2 Lift Pumps at Treatment Units Not Applicable § 112.8(c)(1)§ 112.12(c)(1) Tank Materials 4§ 112.8(c)(2)§ 112.12(c)(2) Secondary Containment 6§ 112.8(c)(3)§ 112.12(c)(3) Drainage of Uncontaminated Stormwater Not Applicable§ 112.8(c)(4)§ 112.12(c)(4) Corrosion Protection for Buried Storage Tanks Not Applicable§ 112.8(c)(5)§ 112.12(c)(5) Partially Buried and Bunkered Storage Tanks Not Applicable§ 112.8(c)(6)§ 112.12(c)(6)

Integrity Testing of Aboveground Storage Tanks 12

§ 112.8(c)(7)§ 112.12(c)(7) Internal Heating Coils Not Applicable§ 112.8(c)(8)§ 112.12(c)(8) Engineering Controls to Avoid Discharges 6§ 112.8(c)(9)§ 112.12(c)(9) Effluent Treatment Facilities Not Applicable§ 112.8(c)(10)§ 112.12(c)(10) Visible Discharges 10§ 112.8(c)(11)§ 112.12(c)(11) Mobile or Portable Containers 6§ 112.8(d)(1)§ 112.12(d)(1) Corrosion Protection for Buried Piping Not Applicable§ 112.8(d)(2)§ 112.12(d)(2) Cap Piping When Not in Service Not Applicable§ 112.8(d)(3)§ 112.12(d)(3) Pipe Support Design Not Applicable§ 112.8(d)(4)§ 112.12(d)(4) Regularly Inspect Aboveground Piping 6§ 112.8(d)(5)§ 112.12(d)(5) Aboveground Piping and Vehicle Traffic Not Applicable§ 112.9 Requirements for Onshore Production

Facilities Not Applicable§ 112.10 Requirements for Onshore Oil Drilling and

Work over Facilities Not Applicable§ 112.11 Requirements for Offshore Oil Drilling,

Production, or Work over Facilities Not Applicable§ 112.20 Facility Response Plan Requirements Not Applicable

Management Approval

I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system , or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. This plan has the manager’s approval and commitment.

I certify that the following is accurate:1. I am familiar with the applicable requirements of 40 CFR 112;2. I have visited and examined the facility;3. This plan was prepared in accordance with accepted and sound

industry practices and standards;4. Procedures for required inspections and testing have been established

in accordance with industry inspection and testing standards or recommended practices;

5. I will fully implement the plan;6. This facility meets the following qualification criteria under 40 CFR

112.3(g)(1):a. The aggregate aboveground oil storage capacity of the facility is

10,000 gallons or less; andb. The facility has had no single discharge as described in 40 CFR

112.1(b) exceeding 1,000 gallons and no two discharges as described in 40 CFR 112.1(b) each exceeding 42 gallons within a 12 month period in the three years prior to the SPCC Plan Self Certification date.

c. There is no individual oil storage container at the facility with an aboveground capacity greater than 5,000 gallons.

7. This plan does not deviate from any requirement of 40 CFR 112 as allowed by 40 CFR 112.7(a)(2) (environmental equivalence) and 40 CFR 112.7(d) (impracticability of secondary containment) or include any measures pursuant to 40 CFR 112.9(c)(6);

8. This Plan and the individuals responsible for implementing this plan have the full approval of management and I have committed the necessary resources to fully implement this plan.

________________________________ _______________Steve Kerr DateEnvironmental/Safety ManagerKillark ElectricSt. Louis, MO

1. Facility Owner and Operator:

Hubbell Incorporated 40 Waterview Dr.Shelton, CT 06484Phone: 475-882-4000 Fax: 203-882-6634

Facility Operator

Killark Electric3940 Martin Luther King Dr.St. Louis, MO 63113Phone: 314-531-0460Fax: 314-531-7164

Facility contact: Steve Kerr- Health Environmental Safety Manager 314-531-0460 (Ext. 2257)

Latitude: 38 degrees, 39 minutes, 06 secondsLongitude: 90 degrees, 14 minutes, 05 seconds

2. Facility Conformance Discussion

This Spill Prevention, Control and Countermeasures (SPCC) Plan has been prepared and implemented as required by U.S. Environmental Protection Agency (U. S. EPA) regulations contained in Title 40, Code of Federal Regulations, Part 112 (40 CFR112) governing requirements for SPCC Plans. At a minimum, the SPCC plan must address spills for all oil materials that could be discharged in harmful quantities (i.e., violate water quality standards, cause a sheen, etc.) to navigable waterways of the United States.

In addition to the applicable requirements under 40 CFR Part 112, the State of Missouri requires more stringent requirements for preventing, controlling, and/or reporting oil product spills or discharges as follows:

According to 10 CSR 26-5.020 Reporting Releases and Suspected Releases. Unless otherwise provided in this rule, owners and operators of aboveground storage tanks (ASTs) shall report any suspected or confirmed release of a regulated substance to the Department of Natural Resources’ Emergency Spill Line at (573) 634-2436 at the earliest practical moment within twenty-four (24) hours of discovery of the suspected or confirmed release. Immediately upon discovery or observation of regulated substances on the ground surface or in groundwater, surface water, or subsurface soils, the owner or operator shall complete the following:

The initial release response measures described in section (7) of this rule;

Section (7) Initial Release Response Measure. Owners or operators of ASTs shall:

Remove as much of the regulated substance from the AST as is necessary to prevent further release to the environment;

Visually inspect any released substances and prevent further migration of the release into surrounding soils and groundwater.

Monitor and mitigate any environmental hazards posed by vapors of free product that have migrated from the AST site and entered subsurface structures utility conduits or trenches;

Remedy hazards posed by excavated or exposed contaminated soils that result from initial release response activities. Any treatment or disposal of contaminated soils shall be in compliance with applicable state and local requirements;

Collect and analyze at least one (1) soil or groundwater sample as necessary to establish the presence of contamination. The sample(s) must be collected in a location where contamination is most likely to be present at the AST site. In selecting the location of the sample(s), the owner or operator shall consider the nature of the stored substance, the type of backfill around the release if outside the secondary containment, or the secondary containment if the secondary containment is not constructed of impermeable material, depth to groundwater, and all other factors appropriate for identifying the presence and source of the release; and

Investigate the site to determine whether free product is present. If free product is present, then free product removal activities shall begin immediately.

3. Facility Description

The Killark Electric facility of Hubbell, Inc. specializes in the production and manufacture of industrial lighting and electrical enclosures. Production and manufacturing activities consist of machining, painting and assembly.

4. Oil and Non-Oil Storage

The plant has an approximate total amount of 6230 gallons of OIL stored/used on site.

All Above Ground Storage Tanks (AST) are constructed of materials that are compatible with the oil material stored and visually inspected for deterioration or leaks.

The plant quantities for oil are listed in Table 1 below. Table 2 lists other materials required to have spill containment per 10 CSR as specified in Section 2.

Table 1:Container Type

Contents Capacity(gallons)

Qty Location Map

Map ID #

AST Used oily water soluble coolant 4000 1 EAST [black circle]AST Used oily water soluble coolant 1000 1 EAST [black circle]AST Diesel fuel 420 1 EAST 14AST Diesel fuel 140 1 EAST 1

Drum Motor oil 55 3 EAST 2Drum Vanishing oil 55 2 EAST 2Drum Machining lubricant 55 1 EAST 2Drum Metal working oil 55 2 EAST 2, 3Drum Hydraulic oil 55 1 EAST 3

Machine Hydraulic oil 65 1 EAST 4TOTAL QTY IN EAST 6120

Drum Machining lubricant 55 1 WEST 15Drum Hydraulic oil 55 1 WEST 15

TOTAL QTY IN WEST 110

Table 2:Container Type

Contents Capacity(gallons)

Qty Location Map

Map ID #

Drum Lacquer Paint 55 1 WEST 11Drum Flange cleaner 35 1 WEST 12Drum Instapak A compound 55 2 WEST 13, 16Drum Instapak B compound 55 2 WEST 13, 16Drum Waylube 55 1 WEST 15Drum All-purpose cleaner 55 4 2ND FLR 5Drum Non-phosphorous conversion

cleaner55 4 2ND FLR 5

Drum Instapak A compound 55 1 3RD FLR 9Drum Instapak B compound 55 1 3RD FLR 9

Jerrican Instapak A compound 15 1 3RD FLR 6Jerrican Instapak B compound 15 1 3RD FLR 6Jerrican Instapak A compound 15 6 3RD FLR 8Jerrican Instapak B compound 15 6 3RD FLR 8

Location Map Key:EAST = SPILL MAP 1 EAST-Layout1 (First Floor Plan – East), see Figure 1WEST = SPILL MAP 1 WEST-Layout1 (First Floor Plan – West), see Figure 12nd FLR = SPILL MAP 1 2ND FL-Layout1 (Second Floor-Building 1), see Figure 13RD FLR = SPILL MAP 1 3RD FL-Layout1 (Third Floor-Building 1), see Figure 1

5. Facility Drainage

The ground elevation surrounding the facility is flat. The working area around and in the shipping, receiving and dock areas are concrete and paved. The flat topography of the facility makes response and containment very achievable.

6. Secondary Containment, Discharge Prevention Measures, and Discharge Response

All floor drains in the plant have been sealed, preventing discharge of oil outside the plant.

In the case of minor leaks or spills, the plant maintains spill response kits (see

Appendix B, SPCC Spill Clean-Up Materials). Any visible discharges that result in the loss of oil from oil containers are promptly corrected. See Section 10 for emergency response due to major equipment failure or accident.

a) Oil Reservoirs

The machines that have oil reservoirs have oil level gauges to be used by maintenance personnel and operators to determine the level of oil in the machine. This prevents the machines from being overfilled.

In addition, a person designated and trained in proper filling of the machines machine oiling and refilling. If oil is discharged onto the floor, the transfer will be stopped and immediate measures will be taken to stop the spread of the oil and to soak it up with absorbent material.

b) Used oil

The used oil and water mixture is stored in the East Warehouse in a 4000-gallon AST that has a 1000-gallon overflow AST next to it (see Figure 1: SPILL MAP 1 EAST-Layout1).

The East warehouse storage clerk monitors the transfer of used oil to the used oil storage tank to ensure that the tank is not overfilled.

The tank is also equipped with an overflow flashing light and audible alarm. In the event of an overflow incident, the material automatically flows to the 1000 gallon AST next to it.

The tank is drained every three weeks to ensure that it does not reach 75% of capacity.

SPCC Truck Transfer and Containment Procedures for transferring used oil and water mixture from the storage tank to tank truck are in Appendix A.

All aboveground valves, piping, and appurtenances are inspected to assess general condition before each transfer from the storage tank to the tank truck.

Used oil is stored in a 55 gallon drum stored on platforms designed as secondary containment containers that will hold contents in case of spill (see Figure 1: SPILL MAP 1 EAST-Layout1).

c) New Oil

New oil is stored on platforms designed as secondary containment containers that will hold contents in case of spill (see Figure 1: SPILL MAP 1 EAST-Layout1).

The only outside storage of new oil is diesel fuel for the Emergency generator, which is a double-walled storage tank where outer tank will contain the contents if inner storage tank ruptures (see Figure 1: SPILL MAP 1 EAST-Layout1). The inside storage of new oil is diesel fuel for the Sprinkler Fire Pump. The storage tank is installed above a metal container that can hold the contents if the storage tank ruptures (see Figure 1: SPILL MAP 1 EAST-Layout1). The area is monitored and inspected weekly by maintenance personnel.

Note: The materials in Table 2 in Section 4 are also stored on platforms designed as secondary containment containers that will hold contents in case of spill.

7. Disposal of Recovered Materials

After cleanup of small spills, used absorbents are placed in an empty 55 gallon drum. The drums with the used/contaminated clean up materials are temporarily stored in the Satellite Accumulation Area until a contractor picks them up. (See First Floor Plant West drawing)

8. List of Plant Emergency Personnel, State Agencies, and Cleanup Contractors

The EHS Manager, Steve Kerr, will be in charge of all efforts to mitigate an oil spill.Mike Button is the secondary coordinator. The phone numbers for the coordinators are as follows:

Steve Kerr (314) 531-8839 x2257 (work) (314) 452-7844 (Cell)Mike Button (314) 531-8839 x2209 (work) (314) 566-9850 (Cell)

During the normal working hours all personnel in the maintenance department will respond to any oil spill emergencies. If outside help is needed then call:

Police Department 911 Fire Department 911Emergency 911Cleanup Contractor:Illini Environmental Inc.- (24 hour Emergency) (618) 216-8600Illini Environmental Inc.- - Hazardous Waste pick up (618) 216-8600Illini Environmental Inc.- Hazardous Waste pick up- oil (618) 397-1234

If oil is likely to leave the plant and/or get into the soil or water call:

Hubbell Inc. EHS Director – (475) 882-4134/(475) 422-2894US Coast Guard National Response Center- (800) 424-8802Brown & Caldwell – (414) 203-2908Missouri Department of Emergency Services - (573) 526-9100

2302 Militia Drive, Jefferson City, MO 65101 U. S.

Missouri Department of Natural Resources – (800)-361-48271107 Riverside DriveJefferson City, MO 65102-0176

EPA Region VII Emergency Response Hotline- 800-223-0425

9. Notification Procedure

In the event an outside agency is contacted for help use the following checklist to provide information about the spill. Fill in the blanks and provide this information as time permits. (Do not wait for this information before calling the Police Department.)

Plant address, plant point of contact and phone number Date of the spill______________ Time of the spill______________ Estimate of the total quantity spilled___________gallons Total capacity of tank:___________ Estimate of quantity that has entered the storm ditch____________ The cause of the discharge_____________ Damage caused______________ Injuries caused_______________ Actions being taken to stop the oil/diesel spill_____________________ Actions being taken to stop the oil/diesel fuel from reaching local waterways

____ Is an evaluation needed? YES_____ No______ Individuals and organizations who have been notified___________________ Additional individuals and organizations you will be notifying_____________

Whenever Hubbell Killark has a discharge greater than 1,000 gallons of oil or two discharges of more than 42 gallons of oil occurring within any 12-month period the following information regarding the spill must be submitted. The following information is to be submitted to the Regional Administrator, EPA Region VII Office, 11201 Renner Blvd. Lenexa, KS 66219. Link to contact form http://www.epa.gov/rgytgrnj/contact.htm

Name of facility Name(s) of owner or operator of facility Location of 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, and topographical

maps A complete copy of the SPCC plan with any amendments The cause(s) of such spill, including a failure analysis of system or subsystem in

which the failure occurred. The corrective actions and/or countermeasures taken, including an adequate

description of the equipment repairs and/or replacement.

10. Emergency Response Due to Major Equipment Failure or Accident.

An oil release would not normally be expected under most plant operations. Minor leaks may be expected during normal operations and should be readily cleaned up.

A major oil release requiring spill response would be expected to occur as a result of catastrophic events such as natural disasters, major equipment failure, or accident.

A diagram of the potential discharge volume and direction of flow of the storage tank in the East Warehouse is in Figure 2.

The person discovering an oil spill should quickly determine if the flow of oil could be stopped without assistance. Determine the need to shut off any equipment and if an evacuation of the area is needed. Take appropriate action. If the oil flow can be stopped immediately, spread the absorbent material and continue efforts to clean up the oil spill.

If the oil flow cannot be immediately stopped the plant radios will be used to notify appropriate employees of actions to take.

Floor dry and spill kit materials are available to stop the spread of the oil. A list of Spill Response Equipment can be found in Appendix B. The Spill Response Equipment is located in the paint department (second floor building 1), east warehouse, east plant drill press area, and receiving area west (see plant diagrams). The Environmental Coordinator (EHS Manager) and secondary coordinator are

authorized to act on Hubbell’s behalf for cleanup actions. Employees are trained in emergency response measures, including equipment location and usage. Hubbell Killark personnel are trained to use spill kits to handle minor oil spills. All trained employees have access to the spill kits.

In the event of a spill, the following general procedures should be followed:

1. Secure the Area and Personnel : Access to the spill area should be immediately controlled to prevent unknowing facility personnel from entering the area. All facility personnel in the vicinity of the spill should be notified that a spill has taken place and that all activities that might create sparks or flame should cease until the risk of fire is determined. The first priority in the event of a spill is to ensuring worker safety, and all steps in the response process must reflect adequate regard for worker safety.

2. Determine the Type and Approximate Quantity of Material Spilled: Using appropriate caution, the type and approximate quantity of spilled material should be ascertained to determine the degree of the hazard present. This should require only a quick cursory examination of the spill area that can be made without risking direct contact with the spilled material. If possible, the amount already released and the rate at which the oil continues to be released will be measured or estimated.

3. Notify the Manager or Emergency Contact : A list of the emergency phone numbers is provided in section 8.

4. Contain the Spill: Employees are trained to use the spill kits, as shown on the plant diagrams.

11. Commitment to Controlling Spills

The management at Hubbell/Killark is committed to supply the equipment, manpower and materials to expeditiously control and remove any quantity of oil discharged. The EHS Manager has been designated to be accountable for oil spill prevention at Hubbell/Killark.

12. Inspections, Test and Records

On a monthly basis a maintenance employee will inspect the machine reservoirs, the used and new oil storage drums, and spill containment for signs of deterioration and/or leaks, which might cause a spill. These monthly inspections will be documented using the log in Appendix C, SPCC Above Ground Storage Tank Inspection and SPCC Equipment/Storage Inspection Record. In addition operators will check these items on a daily basis and report any potential problems to the EHS Manager immediately. The daily inspections include: A walk through of the areas related to this plan to ensure that no hazardous

conditions exist An inspection of floor/grounds surfaces for signs of leakage, spillage, or stains A visual inspection of the tanks’ shells to look for signs of leakage or damage An evaluation of the condition of the above ground tanks and other storage

areas.

13. Personnel Training

All personnel working with oil or oil products are familiar with this SPCC Plan and will follow the procedure established for oil or oil products to prevent oil discharges. Hubbell/Killark is responsible for properly instructing their personnel in the operation and maintenance of equipment to prevent the discharges of oil and applicable pollution control laws, rules and regulations. All personnel involved in the handling and disposing of oil or oil products are trained to:

1. Utilize Safety Data Sheets2. Know hazards of materials3. Use labels correctly on materials4. Handle, dispense, store, and dispose of materials correctly5. Proper use of safety equipment

Training also consists of:

1. Operation and maintenance of equipment to prevent discharges2. Discharge procedure protocols3. Applicable pollution control laws, rules, and regulations4. General facility operations5. Review of SPCC Plan6. Highlight and describe known spill events or failures, malfunctioning

components, and recently developed precautionary measures.

7. Emergency spill response8. Review of chain of responsibility for spill events9. Review of spill events or other potential spill problems10. An AST is not to be filled without checking reserves prior to

commencing the filling operation and;11. Filling operations are continuously attended.

Training will be conducted on hiring of new employees and on an annual basis. The EHS Manager will conduct training. The training program will be reviewed annually by the EHS Manager and the Hubbell EHS Department.

Trained employees will fill out the SPCC Plan Certification (Appendix D), certifying they have been trained in the above areas.

14. Security Measures

The Hubbell Killark Saint Louis facility is monitored for security 24 hours/day, 365 days/year. The entire facility, main plant, shipping and receiving is enclosed by perimeter fencing and gates that are secured to prevent unauthorized entry to the facility. In addition, security monitoring is provided for the main plant by Tyco Security Systems alarm-monitoring services. The facility lighting is adequate to 1) discover spills occurring during hours of darkness, both by operating personnel and non-operating personnel (public, local police, etc) and 2) prevent spills through vandalism.

15. Record Keeping

The EHS Manager will keep this Plan, completed Appendices, training records, all inspection reports and correspondence associated with the Plan with the environmental records. All records must be kept for at least 3 (three) years. This plan must be maintained at this facility.

16. Review, Evaluation and Amendment

This plan will be reviewed at least once every five years. If no changes to plan are required, it will be documented in the SPCC Review/Evaluation and Amendment Log in Appendix E with statement, “I have completed review and evaluation of the SPCC Plan for Killark on (date) with will not amend the Plan as a result.”

This plan will be amended When review of plan requires plan to be changed. Review resulting in changes

to plan will be documented in the SPCC Review/Evaluation and Amendment Log in Appendix E with statement, “I have completed review and evaluation of the SPCC Plan for Killark on (date) with will amend the Plan as a result.”

When there is a change in the facility design, construction, operations, or maintenance that materially affects the potential for diesel fuel/oil discharge

If the facility no longer meets the requirements of a Tier 1 Qualified Facility as designated in the Management Approval section

When an amendment is required, it will be prepared within six months of the events causing the amendment. The amendment will be implemented as soon as possible

but not later than six months following preparation of the amendment. Amendments will be documented in the SPCC Review/Evaluation and Amendment Log in Appendix E.

SPCC Truck Transfer and Containment Procedures

Used Oil Tank

1.    Check the capacity of the vacuum truck.2.    Check the level in the used oil tank.3.    Verify the vacuum truck has the capacity to hold the contents of the used tank.4.    Verify the truck is chocked.5.    Check the overall condition of the truck.  If there are any indications that the truck may

leak, refuse the pickup.6.    Unlock the fill spill containment.7.    The driver may now connect the vacuum hose and transfer the used oil to the vacuum

truck.8.    Have the driver place a spill guard under the pump.9.    Commence transfer until the used oil tank is empty.10.  Monitor the transfer process.11.  Disconnect all hoses before truck departs.12.  Prior to departure of tank truck, the lowermost drain and all outlets of such vehicles is

closely examined for leakage and if necessary, tightened, adjusted or replaced to prevent liquid leakage while in transit.

Note: If a leak develops or anything out of the ordinary happens, stop the filling immediately and take appropriate actions.

Appendix A

Appendix B

SPCC Spill Clean-Up Materials

Spill kits are in the Emergency Equipment Cabinets located in the maintenance department and also in anodize, receiving, and wastewater treatment.

These kits contain the following materials and supplies: Shovel Safety Absorbent Waste Receptacle Absorbent Sock Safety goggles Gloves Tyvek coveralls

SPCC Above Ground Storage Tank Inspection and SPCC Equipment/ Storage Inspection Record

Year:Inspection Point Jan Fe

bMar

Apr May Jun Jul Aug Sep Oct Nov Dec

Are ground surfaces around all oil storage tanks, piping, containment areas, and transfer areas free from signs of leaks?Are all oil storage tanks in good condition when inspected? Check tank shell surfaces, peeling areas, welds, rivets/bolts, seams and foundations for rust and other signs of deterioration.Are oil storage containment areas free of excess standing water or oil?Are all level indicators and oil storage tank gauges working properly?Are spill kits fully stocked?

Is there good housekeeping in the oil storage areas?

Is the depth of oil in the used tanks below 75%? (Note: Notify the maintenance supervisor if the oil depth is above 75%.)Inspector’s Signature: RemarksJanuaryFebruaryMarchAprilMayJuneJulyAugustSeptemberOctoberNovemberDecember

Appendix C

Appendix D

Certification of SPCC Training

I have attended the Hubbell Killark, St. Louis, MO Spill Control and Countermeasure Plan training session. I understand the plan and can carry out the requirements of the plan as addressed by the training.

Signed__________________________________ Date_________________

Print Name: _______________________________________

The employee, as signed above, has attended the Hubbell Killark, St. Louis, MO Spill Control and Countermeasure Plan training session. I have full confidence that they understand the plan and can carry out the requirements of the plan.

Signed_________________________________ Date_________________Steve KerrEHS Manager/Environmental Coordinator

SPCC Review/Evaluation and Amendment Log

DateReview or

Amendment Description Signature

Appendix E

FIGURE 1

Oil Storage Locations

FIGURE 2

Potential Discharge Volumes and Direction of Flow