Senergy Petroleum EAP with Experience and Capacity (1).pdf

1470 N HORNE STREET | GILBERT, ARIZONA 85233 | PH. (800) 964-0076 | GoSenergy.com

As a premier Arizona lubricants distributor, Senergy Petroleum has strategic bulk plants, state of the art storage facilities, and sales offices in Phoenix, Tucson, Thatcher, and Yuma.

This allows us to live and serve the entire state for all lubricant business. Senergy has become one of the area’s largest lucricants supply companies because we provide a “one-stop” shop approach for lubricant solutions to companies in every industry. Because of these advantages, we have strong relationships with leading nationwide suppliers and manufacturers.

Senergy Petroleum prides itself on its ability to navigate unforeseen circumstances and continue on its mission to provide quality products and services. Our experienced staff operate under our standard operating procedures, adhering to safety protocols and procedures every step of the way. Our trucks are maintained at the highest level of speculation to ensure a safe and timely delivery for both our employees and our customer.

Our personnel are required to take courses centered around OSHA, safety, and proper storage and handling of the products we sell and distribute on a regular basis. This lowers the risk of contamination or various proponents of injury for products being delivered. Senergy has implemented a health, safety, and environmental program with the intention of communicating risk and establishing controls to eliminate or mitigate potential hazards. The program is designed to be site-specific and serve as a guide to management and employees to ensure continued service to state agencies in emergency conditions and declared state of emergencies by local, county, and state officials. Examples of the program include: spills, safety, emergency action plan, incident reporting, and personal protective equipment.

We only distribute top ranked, quality products. Drivers do pre- and post- delivery inspections for each trip assigned. Our trucks are tracked by GPS, and dispatched in the most economic and efficient way possible. Our fleet is outfitted with top-of-the-line fuel and lubricant dispensing equipment on the market.

To ensure the best quality to our customers: our executive team meets daily to discuss operations, safety, and product procurement. Our procurement department conducts monthly inventory audits to ensure the highest quality and availability of our products. Our sales management team audits on a weekly basis to ensure our account managers and customer service teams are upholding the highest degree of service.

Experience and Capacity

SOLICITATION:

BPM004794

EAP for Senergy Petroleum LLC. Rev. October -2021 - Final

Emergency Action Plan

Statement about Senergy Petroleum Operations Division

Senergy Petroleum LLC (SP) Operations proudly remains privately held with warehouses located throughout the Southwest and Rockies as well as 15 Cardlock locations across Arizona, New Mexico, Texas and Colorado. With regional supply terminals, Senergy serves the Arizona, New Mexico, Nevada, Utah, Texas, and Wyoming markets with one of the largest company owned and operated fleets in the region. SP primarily transports refined hydrocarbon products like petroleum-based oils and lubricants, solvents, Diesel Exhaust Fluid (DEF), and refined fuels, with the later is considered hazardous material. SP operates a large fleet of DOT regulated vehicles with properly trained and endorsed hazmat drivers on the road at any given time hauling materials that if releases can be a major threat to human health and the environment. SP is committed to rapidly responding to all incidents and doing everything we can to mitigate our spills.

Our spill response program is based on two main ideas:

1. All spills are cleaned up safely using whatever resources are warranted, and

2. All spills are reported to the appropriate persons/agencies; including supervisors, managers, safety department, and regulators, as required by law.

Our intent is to provide training and information that will be valuable to our employees in the event of a release or spill.

Prior Training

Whenever we train for responding to spills and releases, our employees have already completed some level of training that relates to safety and product-specific handling procedures that provide an operational knowledge of materials potentially involved in a release. Company employees conducting spill cleanup activities are limited by their level of training. They are also limited to non-emergency incidents where the product involved, hazards and conditions are known.

Prior training may include, but is not limited to the following:

- Safety Training / Annual Refresher Training

- Safety Orientation Training

- Right-to-Know Training

- Annual safety meetings addressing spill response

- DOT Hazardous Materials Endorsement (HME)

- Personal Protective Equipment (PPE) training

- Bloodborne Pathogen training

- First Aid/CPR training

- Confined Space training

- Atmospheric Monitor training

- Other task-specific training

It should be noted that the training that occurs each year, both within and outside of SP, that deals with spill response and hazardous material can count towards an individual’s OSHA Hazmat 8-hour refresher requirements.

Programs

SP has implemented a health safety & environmental program with the intention of communicating risk and establishing controls to eliminate or mitigate those potential hazards.

The program with written forms/procedures are designed to be site specific and serve as a guidance to management and employees. Examples of the program that relate to spills include Emergency Action Plan, Incident Reporting, Housekeeping, Hazard Communication, Personal Protective Equipment, etc. It is the responsibility of all employees to understand the purpose, requirements and established policies/procedures related to this program.

Another component of program review and inspection is the completion of a monthly safety inspections and audits. These monthly tasks are for managers/supervisors to complete a site inspection with a focus on hazard/risk identification and written documentation spot check to ensure compliance with a variety of environmental, health and safety systems. We encourage participation from all employees in performing risk identification activities and working together to develop solutions and controls.

Types of Legislation

The job-specific tasks that we undertake every day in the refined lubrication and fuel business are subject to a wide variety of State, Federal and Local regulations. When we respond to a spill or release, we are subject to even more stringent regulations. Some examples of regulations include the following:

- OSHA 1910.120

- Health and Safety (e.g., plans, training, forklift, confined space, personal protective equipment, HazCom)

- Transportation (e.g., licensing, placarding, health card, product handling, CHEMTREC)

- Environmental (e.g., CWA, FIFRA, RCRA, CAA, UST/AST, SPCC, RMP, SWPPP, RTK)

- Other (e.g., planning and zoning, fire marshal, NFPA)

Regulatory Agencies

- Federal (DOT, EPA, OSHA, USDA, FWS, DHS, Army Corps, etc.)

- State Environmental Agencies (DEQ, PCA, etc.)

- Local (City, County, Fire Marshal, etc.)

- Tribal

There are many activities going on at once during a spill event and it is extremely difficult to keep all the regulations in mind in addition to the basic cleanup tasks. It is imperative that the SP management and safety department are involved in the decision-making process. The decisions that are made early on can greatly affect the outcome of the spill and should be discussed between the person(s) involved, the location personnel, and executive leadership to avoid potential legal implications.

Actions to Take in the Event of a Spill or Releases

The following four subsections discuss what to do in the event of a spill or release and include:

preparedness, notification, prevention, and response.

1. Preparedness

There are many things SP management can do ahead of time that will make responding to an incident much more efficient and safer. We need to anticipate the variety of problems we could encounter in our everyday work and make plans that we can implement in the event of a problem. The following are valuable preparedness tools that help us respond correctly and safely to an emergency or spill response situation. In addition, make sure that all training and preparedness planning is documented within SP digital recordkeeping platform.

1.1 Facility Planning/Preparation

1.1.1 Facility Response Plans

1.1.2 Site Security Plans

1.1.3 Spill Prevention Control and Countermeasure Plans (SPCC for aboveground oil storage)

1.1.4 Emergency Response Plans (City, County)

1.1.5 Risk Management Plans

1.1.6 Emergency contacts are up to date

1.1.7 Documents, policies, maps, site diagrams, etc.

1.2 Emergency Contacts

1.2.1 Post Emergency Contacts

1.2.2 Set-up third party contracts (e.g., disposal vendors, vac-truck service)

1.2.3 Meet with local emergency personnel (police/fire/LEPC)

1.3 Historical Spills (Root Cause and Lessons Learned)

1.3.1 Leaking totes/containers

1.3.2 Leaking totes/containers

1.3.3 Forklift/loading accidents

1.3.4 Broken hoses

1.3.5 Fill nozzles coming out

1.3.6 Overfills

1.3.7 Vehicle accidents/rollovers

1.3.8 Tank/bin failure

1.3.9 Chronic small spills and leaks

1.3.10 Fire

1.3.11 Weather/freezing conditions

1.4 Training

1.4.1 Safety and health training

1.4.2 Driver safety training (Smith’s Driving, new driver assessment, etc.)

1.4.3 Process specific training courses ( MSHA new miner, annual refresher training, site specific training, etc.)

1.4.4 First aid and CPR, first responder training, etc.

2. Notification

It is every employee’s responsibility to report all spills and releases to your immediate supervisor or safety department. If a major spill the safety department will work with executive management and third-party consultants (where applicable) in reporting reportable quantity spills or releases to government agencies whenever required, including to the National Response Center. An overall all summary of the notification process is listed below:

2.1 Incident Notification

2.1.1 Internal SP reporting

2.1.2 911

2.1.3 State Agency

2.1.4 City services (If applicable)

2.1.5 National Response Center (NRC) (when appropriate)

2.2 Emergency Contacts

2.2.1 Contact your supervisor, home office, GM etc. immediately, then the company safety department.

2.2.2 SP management along with the safety department will

coordinate with local, county, and or state agencies on reporting a spill.

2.2.3 SP management will coordinate with insurance and their

approved nationwide spill remediation team.

2.2.4 SP department will coordinate with onsite personnel on

completing a New Incident Report Form.

2.2.4.1 Primary Safety Depart. Phone: # 1-480-721-4789

2.2.4.2 Secondary Safety Depart. Phone # 1-208-391-2347

2.2.4.3 Online: following link to report a spill by completing a New Incident Report at https://bradhallcompanies.sharepoint.com/sites/Senergy- Safety

2.2.5 Reference the SP Incident Response Flow Chart

2.3 General Spill Response Protocol

2.3.1 If it is safe to do so stop the release

2.3.2 Contain the spill

2.3.3 Report the spill to your manager

2.3.4 Contact safety department for assistance on mitigation

actions

2.3.5 Report spill to Regulatory Agency(s) if appropriate

2.3.6 Clean up spill as quickly as possible

3. Prevention / Best Management Practices (BMPs)

Best management practices (BMPs) are control measures used to limit environmental impacts during our day-to-day operations. BMPs include, but are not limited to, housekeeping, environmental risk control improvements, waste management, and operational practices as listed below.

3.1 Housekeeping:

3.1.1 Daily sweeping

3.1.2 Applicator field washing

3.1.3 Load pads

3.1.4 Covered storage

https://bradhallcompanies.sharepoint.com/sites/Senergy-Safety https://bradhallcompanies.sharepoint.com/sites/Senergy-Safety

3.1.5 Age dating poly totes and tanks

3.2 Environmental Risk Control Improvements:

3.2.1 Load pads and secondary containment beyond regulatory

requirements

3.2.2 Spill kits

3.2.3 Drip pans

3.2.4 Load securement

3.2.5 Equipment washing procedures

3.3 Waste Management (Waste Management Program)

3.3.1 Rinsate (label use and application rates)

3.3.2 Used or residual hose product

3.3.3 Unused/outdated petroleum products properly disposed of

3.3.4 Don’t mix wastes

3.3.5 Recycle whenever possible

3.3.6 Label containers

3.3.7 Prevent accumulation (used oils, cleanup waste, may need it someday materials)

3.4 Operations

3.4.1 Understand the equipment being operated

3.4.2 Have clear operating policies

3.4.3 Ask and encourage questions on whatever isn’t understood

3.4.4 Watch stress and fatigue factors

3.4.5 Keep equipment maintained

3.4.6 Key program reviews

4. Response

To properly respond to a spill, the following steps are discussed below: be familiar with the SP Incident Reporting Policy; ensure your own safety; stabilize the spill if possible;

and document and investigate the incident as thoroughly as possible.

4.1 Initial steps to follow – When a spill occurs

4.1.1 Notify your supervisor or office that you have a spill/release

4.1.2 Get help on the way (call 911 if warranted)

4.1.3 Notify SP safety department of the spill/release – SP Incident

Reporting Policy

4.1.4 Report to proper authorities (usually done with help from your office)

4.1.5 Stop release if can be done safely

4.1.6 Try to minimize affected area/stop spread or migration of spill

4.1.7 Determine responsible party

4.1.8 Secure contaminated material

4.1.9 Await disposal decisions

4.2 Safety first – always!

4.2.1 No one should ever get hurt responding to a release

4.2.2 Never respond to a spill without first calling in the problem to your office

4.2.3 Don’t respond alone; have someone there to help in case of problems

4.2.4 Respond only to what you are equipped and qualified to

handle

4.3 Assess the potential hazards

4.3.1 Review SDS and labels

4.3.2 Complete an “all hazards review”

4.3.2.1 T – toxic

4.3.2.2 R – radiological

4.3.2.3 A – asphyxiant

4.3.2.4 C – chemical

4.3.2.5 E – etiological

4.3.2.6 M - Mechanical

4.3.3 Communicate the hazards

4.4 Stop and contain release

4.4.1 Shut off pump or valve as soon as possible

4.4.2 Dike, dam, or divert

4.4.3 Use absorbents

4.4.4 Containerize waste or put on poly/plastic

When the spill is stabilized and the waste contained, stop and review with management about disposal options for the impacted media. Do not do anything in this regard until reviewing the situation with SP management and an approved plan is finalized.

Improperly disposing of impacted media can cause major business disruption and can be a criminal offense.

4.5 Documentation

When safe to do so, always take as many pictures as you can of the spill event. This includes close up pictures of the release site/area to far away pictures to show any impact to surrounding area. As soon as possible, write down a written account of the spill event, what you did in response, times, date, weather, people you talked to etc.

Don’t wait to compile the documentation or you will forget many important details. All these details and pictures are to be compiled and sent to the Company safety department for review and safe keeping. See SP Incident Reporting policy for additional details.

4.6 Investigation

Whenever we have an incident, we need to look at the facts surrounding the release to determine if there are actions, we can do to prevent future incidents. This may involve maintenance, training, changes in procedures, or use of different equipment. The investigation is usually a collaborative effort between the person(s) involved, location personnel, and SP. Results are then entered into the Company’s data base so other locations can learn from the experience.

5. Waste Disposal Guidance

The Company assembled a waste management program for use by SP locations. The purpose of the program was to help identify waste streams at locations and determine whether they are solid or hazardous wastes. This program was created to provide guidelines on how to properly dispose of various types of waste that are commonly generated at SP locations. The program was broken down into four sections for ease of reference:

5.1 Provided a list of helpful acronyms.

5.2 Provided specific waste materials and how to properly dispose or recycle.

This section also included state-specific regulations, if any, for each waste type that may be more specific than federal regulations.

5.3 Included were appropriate contacts, websites, articles, and phone #’s to use if there were questions.

5.4 Provided a means to document a location’s site-specific waste materials and related disposal activities.

6. Environmental Expectations

The following environmental-related expectations apply to all SP employees. It is considered a basic requirement of each employee to meet these minimum expectations. Failure to do so may result in disciplinary action. It is expected that each SP employee will:

6.1 Follow Compliance: Understand and comply, to the best of your ability, with all environmental regulations and company environmental procedures.

6.2 Emergency Response Procedures: Follow your location’s emergency response procedures in accordance with your specific training, provided you have the proper resources and can do so safely.

6.3 Spill and Release Reporting:

6.3.1 Contact your supervisor, home office, GM etc. immediately, then the company safety department.

6.3.2 SP management along with the safety department will

coordinate with local, county, and or state agencies on reporting a spill.

6.3.3 SP management will coordinate with insurance and their

approved nationwide spill remediation team.

6.3.4 SP department will coordinate with onsite personnel on

completing a New Incident Report Form.

6.3.4.1 Primary Safety Depart. Phone: # 1-480-721-4789

6.3.4.2 Secondary Safety Depart. Phone # 1-208-391-2347

6.3.4.3 Online: following link to report a spill by

completing a New Incident Report at https://bradhallcompanies.sharepoint.com/sites/S energy-Safety

6.3.5 Reference the SP Incident Response Flow Chart

6.4 Waste Disposal: Not dispose of any material by burning or burying on-site unless you receive prior approval from SP operations and safety management. When the spill is stabilized and the waste contained, stop and review with management about disposal options for the impacted media. Do not do anything in this regard until reviewing the situation with SP management and an approved plan is finalized.

6.5 New Work Activities: Understand what the environmental requirements are for new work activities prior to engaging in that activity.

6.6 New Business Activities: Not engage in any property purchasing, or leasing, construction, or demolition activities without explicit approval from your manager.

If you have any questions about environmental requirements or procedures, and how they affect you, ask for help. It is SP responsibility to operate its locations in a responsible manner; it is your responsibility to ensure that you follow the established environmental procedures.