Smithfield Foods' Environmental Training Conference on SPCC Plans

1. Smithfield Foods, Inc. Environmental Training Conference June 4, 2012 John Meyer, P.E. Director of Environmental Affairs & Sustainability John Morrell Food Group Spill Prevention, Control & Countermeasures (SPCC)

2. SPCC Plan – Who Needs One?? Required for facilities with an aggregate aboveground oil storage capacity greater than 1,320 gallons or a completely buried oil storage capacity greater than 42,000 gallons and… Could reasonably be expected to discharge oil into navigable waters of the US or adjoining shorelines.

3. SPCC Plan – What is Oil?? Oil definition includes animal fats, oils, and greases, fish and marine mammal oils, and vegetable oils including oils from seeds, nuts, fruits, and kernels (40 CFR 112.12). Oils also include petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with waste other than dredged spoil (40 CFR 112.8 ); Includes: oil in transformers, hydraulic equipment, and DAF float storage tanks.

4. Oil Filled Transformers Oil filled transformers are considered “operational equipment” not bulk storage containers, so they do not require strict secondary containment but they… “… must meet other SPCC requirements such as the general requirements of 112.7(c), to provide appropriate containment and/or diversionary structures to prevent discharged oil from reaching a navigable watercourse.” (Reference Page 47054 Federal Register, 7/17/02)

5. Wastewater Exemption Containers used exclusively for wastewater treatment are excluded from SPCC regulations, however, “the production, recovery, or recycling of oil is not wastewater treatment for the purposes of this paragraph”. (40 CFR 112.1(d)(6) “If a wastewater facility or part thereof is used for the purpose of storing oil, then there is no exemption and its capacity must be counted as part of the storage capacity of the facility”. (Reference Page 47068 Federal Register, 7/17/02)

6. SPCC Plan Components Oil Storage Container List Discharge Prevention Measures Good House Keeping Discharge Controls and Secondary Containment Discharge Countermeasures – Cleanup/Mitigate Disposal of Recovered Materials Loading/Unloading Activities Security Overfill Prevention - Tank Alarm Systems SPCC Plot Plan

7. SPCC Plan Requirement Secondary Containment Drainage Records O&M of Equipment to Prevent Discharge Quarterly Visual Inspections (Tanks and Oil Filled Transformers) Annual Training Annual Review and Revision as Necessary Periodic Spill Prevention Briefings Spill/Release Incident Documentation Records Retention for 3 Years

8. Most Common Violations Lack of Training Records Lack of Secondary Containment Drainage Records Lack of Tank/Transformer Inspection Records No Containment for Transfer Areas Inadequate Secondary Containment Addressing Spills from Piping No P.E. Certification of SPCC Plan (when required) No SPCC Plan

9. SPCC Plot Plan Includes: The physical layout of the site including all buildings, fencing, security, areas of gravel, concrete, and grass, storm water drainage ditches, storm sewer inlets, storm water outfalls, and spill kit locations; Surface drainage flow directions; Location of all oil containers >= 55 gallons; Location of all transfer stations and connecting piping.

10. Secondary Containment Structures required to provide a means of containment for the entire capacity of the largest single container and sufficient freeboard to contain precipitation (40 CFR 112.8(c)(2) & 40 CFR 112.12(c)(2)) “We believe that the proper standard for sufficient freeboard to contain precipitation is that amount necessary to contain precipitation from a 25-year, 24- hour storm event.” (Reference Page 47117, Federal Register, 7/17/02) Diversionary structure to process wastewater is alternatively sufficient.

11. Earthen Containment Structures Earthen containment structures are allowed if they are “sufficiently impervious”. Walls and floors must be capable of containing oil and must be constructed so that any discharge from the primary tank or piping will not escape the containment system before cleanup occurs. Industry Standard: Hydraulic conductivity<10 -7 cm/sec (ASTM D5084 Permeability Test).

12. Loading/Unloading The requirements of 40 CFR Part 112.7(h) do not apply to facilities that do not contain “loading racks”. Loading racks are associated with high-volume loading operations with a system of arms, piping, and pumps as opposed to simple direct connection loading/unloading operations. We generally claim that we don’t have loading racks at our facilities, so this requirement does not apply, but………

13. Loading/Unloading Plant personnel should be present during oil loading/unloading operations. Employees, vendors, and truck drivers should be instructed not to leave the vehicle until the transfer has been completed. Drivers should be instructed not to “top off” the tanks. Fueling and loading operations, including bulk transfer, should be minimized during times of heavy rainfall. Nearby storm sewers can be covered to prevent a release to the environment during loading/unloading events.

14. Security Requirements Security fence surrounding the property with either a locked or guarded entrance when the facility is not attended; Locked valves on drains from secondary containment structures when in non-operating or non-standby status; Locked starter controls on oil pumps in the “off” position when in non-operating or non-standby status; Securely cap or blank flange loading/unloading connections when not in service; Sufficient facility lighting to protect against vandalism and to detect potential discharges during hours of darkness.

15. Tank Integrity Testing EPA allows for equivalent environmental protection to meet the requirements of 40 CFR Part 112.8(c)(6) and 40 CFR Part 112.12(c)(6). For well-designed, shop-built containers with a shell capacity less than or equal to 30,000 gallons, combining proper visual inspections placement of a barrier between the container and the ground (as compared to a container in contact with soil) designed and operated in a way that ensures that any leaks are immediately detected will provide equivalent environmental protection. Reference: Settlement agreement between the American Petroleum Institute and Marathon Oil company and US EPA, dated March 29, 2004.

16. Alarm Systems Fast Response System – direct visual gauge – person present to monitor filling process; High liquid level alarm; High liquid level pump cutoff device; Direct audible or code signal communication; Manual stick for small tanks.

17. Reportable Discharge Events Defined in the Clean Water Act as: Any discharge event which results in an oil discharge to an off- site surface water; Could violate applicable water quality standards; Could cause a film or oil sheen, or discoloration of a surface water; Could cause a sludge or emulsion to be deposited beneath the surface of the water. If you have a reportable discharge event, call NRC (800) 424-8802 immediately, then SERC and LEPC

18. SPCC Plan Certification Self-certification of the SPCC Plan (i.e. no P.E. stamp required) is allowed if: 1. Total aboveground oil capacity is <=10,000 gallons 2. In the last 3 years, no single oil spill event exceeding of 1,000 gallons 3. In last 12 months, no two oil spill events each in exceeding 42 gallons

19. Spills Happen: That’s why we have a SPCC Plan

20. Key: DO YOUR INSPECTIONS

21. Further Information EPA’s Oil Spill Web Site: www.epa.gov/oilspill Oil Information Center Hotline: (800) 424-9346