SPCC Plan

Tier I Qualified Facility SPCC Plan

This template constitutes the SPCC Plan for the facility, when completed and signed by the owner or operator of a facility that meets the applicability criteria in §112.3(g)(1). This template addresses the requirements of 40 CFR part 112. Maintain a complete copy of the Plan at the facility if the facility is normally attended at least four hours per day, or for a facility attended fewer than four hours per day, at the nearest field office. When making operational changes at a facility that are necessary to comply with the rule requirements, the owner/operator should follow state and local requirements (such as for permitting, design and construction) and obtain professional assistance, as appropriate.

Facility Description

Description of operations. Building C is the Honey Badger Logistics warehouse, with five shipping docks, a truck and trailer yard, a fleet of 12 tractors, and a diesel fueling area. The facility operates 5:00 a.m. to 3:30 p.m., Monday through Saturday, with about 24 employees plus drivers. Diesel fuel is stored in two 5,000-gallon double-wall aboveground tanks (D-1 and D-2) and dispensed into fleet tractors at dispenser island DI-1. Forklifts run on propane. Lubricants are kept in containers smaller than 55 gallons.

Facility boundary. Building C shares the Perry Industries campus on the north shore of Lake Tiberius with Buildings A and B. Under the 112.2 definition of facility, contiguous buildings under the same owner or operator may be considered separate facilities. Building C is operated separately by Honey Badger Logistics, LLC and is its own SPCC facility. Storm inlet SI-3, south of the fueling island, drains to Outfall 001 and Lake Tiberius, a navigable water. SI-4 (west drive) is upgradient of Building C and not threatened by Building C operations.

I. Self-Certification Statement (§112.6(a)(1))

The owner or operator of a facility certifies that each of the following is true in order to utilize this template to comply with the SPCC requirements:

I, Dawnn Perry, certify that the following is accurate:

1. I am familiar with the applicable requirements of 40 CFR part 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 §112.3(g)(1)):

a. The aggregate aboveground oil storage capacity of the facility is 10,000 U.S. gallons or less; and

b. The facility has had no single discharge as described in §112.1(b) exceeding 1,000 U.S. gallons and no two discharges as described in §112.1(b) each exceeding 42 U.S. gallons within any twelve month period in the three years prior to the SPCC Plan self-certification date, or since becoming subject to 40 CFR part 112 if the facility has been in operation for less than three years (not including oil discharges as described in §112.1(b) that are the result of natural disasters, acts of war, or terrorism); and

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

7. This Plan does not deviate from any requirement of 40 CFR part 112 as allowed by §112.7(a)(2) (environmental equivalence) and §112.7(d) (impracticability of secondary containment) or include any measures pursuant to §112.9(c)(6) for produced water containers and any associated piping;

8. This Plan and individual(s) responsible for implementing this Plan have the full approval of management and I have committed the necessary resources to fully implement this Plan.

I also understand my other obligations relating to the storage of oil at this facility, including, among others:

1. To report any oil discharge to navigable waters or adjoining shorelines to the appropriate authorities. Notification information is included in this Plan.
2. To review and amend this Plan whenever there is a material change at the facility that affects the potential for an oil discharge, and at least once every five years. Reviews and amendments are recorded in an attached log [See Five Year Review Log and Technical Amendment Log in Attachments 1.1 and 1.2.]
3. Optional use of a contingency plan. A contingency plan: (a) may be used in lieu of secondary containment for qualified oil-filled operational equipment, in accordance with the requirements under §112.7(k), and; (b) must be prepared for flowlines and/or intra-facility gathering lines which do not have secondary containment at an oil production facility, and; (c) must include an established and documented inspection or monitoring program; must follow the provisions of 40 CFR part 109; and must include a written commitment of manpower, equipment and materials to expeditiously remove any quantity of oil discharged that may be harmful. If applicable, a copy of the contingency plan and any additional documentation will be attached to this Plan as Attachment 2.

I certify that I have satisfied the requirement to prepare and implement a Plan under §112.3 and all of the requirements under §112.6(a). I certify that the information contained in this Plan is true.

Management approval (§112.7, introductory paragraph)

Honey Badger Logistics, LLC is a wholly owned subsidiary of Perry Industries, Inc. The parent company approves this Plan and commits the resources needed to implement it, including the outside response contractor listed in Table G-8.

Qualification basis. Aggregate aboveground oil storage capacity counted under 112.1(d)(2)(ii) is 10,000 gallons: D-1 (5,000) and D-2 (5,000). Neither tank is larger than 5,000 gallons. Truck and tractor fuel tanks are motive power containers and are excluded (112.1(d)(2)(ii)(B) and (d)(7)). Lubricant containers under 55 gallons are excluded (112.1(d)(5)). Propane is not oil. The facility has had no single discharge as described in 112.1(b) over 1,000 gallons and no two such discharges over 42 gallons in the three years before January 12, 2026. The fueling area has been in service since April 2016.

II. Record of Plan Review and Amendments

Five Year Review (§112.5(b))

Complete a review and evaluation of this SPCC Plan at least once every five years. As a result of the review, amend this Plan within six months to include more effective prevention and control measures for the facility, if applicable. Implement any SPCC Plan amendment as soon as possible, but no later than six months following Plan amendment. Document completion of the review and evaluation, and complete the Five Year Review Log in Attachment 1.1. If the facility no longer meets Tier I qualified facility eligibility, the owner or operator must revise the Plan to meet Tier II qualified facility requirements, or complete a full PE certified Plan.

Reviews completed March 22, 2021 and January 12, 2026 (Attachment 1.1). Next five-year review due: January 12, 2031.

Changes that end Tier I eligibility (112.6(a)(2)). Adding any oil container of 55 gallons or more would raise the aggregate capacity above 10,000 gallons, and replacing D-1 or D-2 with a tank larger than 5,000 gallons would exceed the Tier I container limit. Either change ends Tier I eligibility. Before such a change, Ellen Ripley notifies Dawnn Perry, and within six months following preparation of the amendment the Plan is rewritten either as a Tier II Plan under 112.6(b) (if the facility still meets 112.3(g)(2)) or as a PE-certified Plan under 112.7 and Subpart B.

III. Plan Requirements

1. Oil Storage Containers (§112.7(a)(3)(i))

ᵃ Aboveground storage containers that must be included when calculating total facility oil storage capacity include: tanks and mobile or portable containers; oil-filled operational equipment (e.g., transformers); other oil-filled equipment, such as flow-through process equipment. Exempt containers that are not included in the capacity calculation include: any container with a storage capacity of less than 55 gallons of oil; containers used exclusively for wastewater treatment; permanently closed containers; motive power containers; hot-mix asphalt containers; heating oil containers used solely at a single-family residence; and pesticide application equipment or related mix containers.

ᵇ Although the criteria to determine eligibility for qualified facilities focuses on the aboveground oil storage containers at the facility, the completely buried tanks at a qualified facility are still subject to the rule requirements and must be addressed in the template; however, they are not counted toward the qualified facility applicability threshold.

ᶜ Counts toward qualified facility applicability threshold.

Not counted: the fuel tanks of the 12 fleet tractors and other vehicles are motive power containers (112.2; excluded by 112.1(d)(7)); propane forklift cylinders hold propane, which is not oil. Oil-filled operational equipment of 55 gallons or more: none at this facility.

2. Secondary Containment and Oil Spill Control (§§112.6(a)(3)(i) and (ii), 112.7(c) and 112.9(c)(2))

ᵃ Use one of the following methods of secondary containment or its equivalent: (1) Dikes, berms, or retaining walls sufficiently impervious to contain oil; (2) Curbing; (3) Culverting, gutters, or other drainage systems; (4) Weirs, booms, or other barriers; (5) Spill diversion ponds; (6) Retention ponds; or (7) Sorbent materials.

Table G-4 below identifies the tanks and containers at the facility with the potential for an oil discharge; the mode of failure; the flow direction and potential quantity of the discharge; and the secondary containment method and containment capacity that is provided.

ᵃ Use one of the following methods of secondary containment or its equivalent: (1) Dikes, berms, or retaining walls sufficiently impervious to contain oil; (2) Curbing; (3) Culverting, gutters, or other drainage systems; (4) Weirs, booms, or other barriers; (5) Spill diversion ponds; (6) Retention ponds; or (7) Sorbent materials.

ᵇ For storage tanks and bulk storage containers, the secondary containment capacity must be at least the capacity of the largest container plus additional capacity to contain rainfall or other precipitation.

ᶜ For oil-filled operational equipment: Document in the table above if alternative measures to secondary containment (as described in §112.7(k)) are implemented at the facility.

Bulk storage container containment (112.6(a)(3)(ii)). D-1 and D-2 are double-wall tanks. Each outer shell encloses the entire capacity of its inner tank, and because the outer shell is closed it takes in no rainfall, so each tank provides secondary containment for the entire capacity of the largest single container plus precipitation. The interstitial space of each tank is monitored.

Transfer areas (112.7(c)). The fueling area is a concrete pad, curbed on the east, west and north sides; the south (drive-through) side is open and slopes toward SI-3. 112.7(c) allows containment to address the typical failure mode and the most likely quantity of oil discharged, and allows active measures. At the dispenser island the most likely discharge is a nozzle, hose or overfill spill stopped by the emergency fuel shutoff, held on the pad with the SK-7 drain cover over SI-3 and sorbents. At the fill port every delivery is attended by a trained Honey Badger employee, and the drain cover from SK-7 is placed over SI-3 before the hose is connected, so it is in place before any discharge can reach the inlet.

3. Inspections, Testing, Recordkeeping and Personnel Training (§§112.7(e) and (f), 112.8(c)(6) and (d)(4), 112.9(c)(3), 112.12(c)(6) and (d)(4))

Oil-handling personnel at Building C are the Fleet & Fueling Supervisor, fueling attendants who attend fuel deliveries, shop mechanics, and the fleet drivers who fuel their own tractors at DI-1. Drivers are trained on the dispenser, the emergency fuel shutoff and the first steps in Table G-7 before they are issued a fueling card. Safety data sheets for diesel fuel and the shop lubricants are in the SDS binder in the dispatch office and on the plant document system from any terminal.

4. Security (excluding oil production facilities) §112.7(g)

5. Emergency Procedures and Notifications (§112.7(a)(3)(iv) and 112.7(a)(5))

6. Contact List (§112.7(a)(3)(vi))

7. NRC Notification Procedure (§112.7(a)(4) and (a)(5))

8. SPCC Spill Reporting Requirements (Report within 60 days) (§112.4)

Submit information to the EPA Regional Administrator (RA) and the appropriate agency or agencies in charge of oil pollution control activities in the State in which the facility is located within 60 days from one of the following discharge events:

• A single discharge of more than 1,000 U.S. gallons of oil to navigable waters or adjoining shorelines or
• Two discharges to navigable waters or adjoining shorelines each more than 42 U.S. gallons of oil occurring within any twelve month period

You must submit the following information to the RA:

(1) Name of the facility;

(2) Your name;

(3) Location of the facility;

(4) Maximum storage or handling capacity of the facility and normal daily throughput;

(5) Corrective action and countermeasures you have taken, including a description of equipment repairs and replacements;

(6) An adequate description of the facility, including maps, flow diagrams, and topographical maps, as necessary;

(7) The cause of the reportable discharge, including a failure analysis of the system or subsystem in which the failure occurred; and

(8) Additional preventive measures you have taken or contemplated to minimize the possibility of recurrence

(9) Such other information as the Regional Administrator may reasonably require pertinent to the Plan or discharge

At this facility, Ellen Ripley prepares the report and Dawnn Perry signs it. The state agency receives a complete copy of the information sent to the RA (112.4(c)).

* * * * *

NOTE: Complete one of the following sections (A, B or C) as appropriate for the facility type.

This facility is an onshore facility (excluding production). Section A is completed. Sections B and C are not applicable.

A. Onshore Facilities (excluding production) (§§112.8(b) through (d), 112.12(b) through (d))

The owner or operator must meet the general rule requirements as well as requirements under this section. Note that not all provisions may be applicable to all owners/operators. For example, a facility may not maintain completely buried metallic storage tanks installed after January 10, 1974, and thus would not have to abide by requirements in §§112.8(c)(4) and 112.12(c)(4), listed below. In cases where a provision is not applicable, write “N/A”.

B. Onshore Oil Production Facilities (excluding drilling and workover facilities) (§112.9(b), (c), and (d))

Not applicable. Building C is not an oil production facility. Table G-11 (General Rule Requirements for Onshore Oil Production Facilities) is not completed.

C. Onshore Oil Drilling and Workover Facilities (§112.10(b), (c) and (d))

Not applicable. Building C is not an oil drilling or workover facility. Table G-12 (General Rule Requirements for Onshore Oil Drilling and Workover Facilities) is not completed.

ATTACHMENT 1Five Year Review and Technical Amendment Logs

Attachment 1.1 — Five Year Review Log

I have completed a review and evaluation of the SPCC Plan for this facility, and will/will not amend this Plan as a result.

Attachment 1.2 — Technical Amendment Log

Any technical amendments to this Plan will be re-certified in accordance with Section I of this Plan template.

ATTACHMENT 2Oil Spill Contingency Plan and Checklist

An oil spill contingency plan and written commitment of resources is required for:

• Flowlines and intra-facility gathering lines at oil production facilities and
• Qualified oil-filled operational equipment which has no secondary containment.

Not applicable to this facility. Building C is not an oil production facility and has no oil-filled operational equipment, so no contingency plan under 40 CFR part 109 is required and the checklist below is not completed. If oil-filled operational equipment without secondary containment is added and the 112.7(k) alternative is used, this attachment will be completed.

Complete the checklist below to verify that the necessary operations outlined in 40 CFR part 109 - Criteria for State, Local and Regional Oil Removal Contingency Plans - have been included.

ᵃ The contingency plan must be consistent with all applicable state and local plans, Area Contingency Plans, and the National Contingency Plan (NCP).

ATTACHMENT 3Inspections, Dike Drainage and Personnel Training Logs

Attachment 3.1 — Inspection Log and Schedule

This log is intended to document compliance with §§112.6(a)(3)(iii), 112.8(c)(6), 112.8(d)(4), 112.9(b)(2), 112.9(c)(3), 112.9(d)(1), 112.9(d)(4), 112.12(c)(6), and 112.12(d)(4), as applicable.

Schedule for this facility: monthly visual inspection of D-1, D-2, piping, valves, dispensers, fill port, interstitial monitors, gauges, pad, SI-3 area, spill kits SK-7 and SK-8, and security lighting (STI SP001 monthly items); annual inspection with alarm and EFS function tests (STI SP001 annual items); test-button check of the high-level alarm before each delivery (delivery log).

ᵃ Indicate in the table above if records of facility inspections are maintained separately at this facility. (The SP001 monthly and annual checklists, kept in the dispatch office binder, are the separate records for this facility.)

Attachment 3.2 — Bulk Storage Container Inspection Schedule – onshore facilities (excluding production)

To comply with integrity inspection requirement for bulk storage containers, inspect/test each shop-built aboveground bulk storage container on a regular schedule in accordance with a recognized container inspection standard based on the minimum requirements in the following table.

ᵃ Examples of leak detection include, but are not limited to, double-walled tanks and elevated containers where a leak can be visually identified.

Applied to this facility: D-1 and D-2 are 5,000-gallon shop-built tanks with sized secondary containment and a means of leak detection (double wall with interstitial monitor). Inspection requirement: monthly visual inspection plus the annual inspection elements of STI SP001. SP001 Category 1 (double wall with interstitial monitoring): formal external inspection every 20 years; last formal external inspection March 24, 2021 (Arrakis Fuel & Lubricants service report); next due March 2041. Additional formal inspection or test interval set by SP001 for these tanks: none beyond the 20-year formal external inspection.

Attachment 3.3 — Dike Drainage Log

Not applicable. This facility has no diked areas; D-1 and D-2 are double-wall tanks. The log is kept in the Plan in case a diked area is added.

Attachment 3.4 — Oil-handling Personnel Training and Briefing Log

ATTACHMENT 4Discharge Notification Form

In the event of a discharge of oil to navigable waters or adjoining shorelines, the following information will be provided to the National Response Center [also see the notification information provided in Section 7 of the Plan]:

ATTACHMENT 5Facility Diagram (supplemental)

Figure 1 — Facility Diagram, Building C (drawing PI-C-201). Not required by the Tier I template; included for response use. Storm sewer and Outfall 001: campus site plan PI-C-001.

ATTACHMENT 6Certification of the Applicability of the Substantial Harm Criteria

40 CFR 112.20(e) requires an owner or operator who determines that the facility does not meet the substantial harm criteria to complete and keep at the facility the certification form in Appendix C to Part 112 (Attachment C-II). The questions and certification below are from that form. The basis for each answer is given in italics.

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 this information, I believe that the submitted information is true, accurate, and complete.