1 New England Healthcare Engineers Society NEHES SPCC Regulations: Applicability and Requirements Timothy W. Kipp, CHMM Senior Consultant GZA GeoEnvironmental,

1New England Healthcare Engineers Society

NEHES

SPCC Regulations: SPCC Regulations: Applicability and RequirementsApplicability and Requirements

Timothy W. Kipp, CHMMSenior ConsultantGZA GeoEnvironmental, Inc.4 Free StPortland, ME 04101(207) [email protected]


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Spill Prevention, Control, and Spill Prevention, Control, and Countermeasures (SPCC) RuleCountermeasures (SPCC) Rule

Federal Rule

Clean Water Act (40 CFR Part 112)

US Environmental Protection Agency

Enforced by EPA Regional Offices– Initial SPCC Rule - 1973– Revisions issued 2002-2009– Compliance deadline for revised rule –

November 10, 2011!


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ApplicabilityApplicability

• SPCC Plan required if you have:• Aboveground oil storage capacity greater than 1,320

gallons; or • Underground oil storage capacity greater than 42,000

gallons (not subject to 280/281 regulations); and• Potential to release oil to navigable waters

of the US– Only count containers 55-gallons or greater

– Includes oil-filled operational equipment


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What Oils are Covered under What Oils are Covered under the SPCC regulation?the SPCC regulation?

• Oils and greases• Petroleum• Fuel oil• Mineral oils• Synthetic oils

– Heat transfer fluids, engine fluids, hydraulic and transmission fluids, metalworking fluids, dielectric fluids, compressor lubricants, and turbine lubricants

• Animal fats and vegetable oils• Sludge• Oil refuse• Oil mixed with wastes other than dredge spoils


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Oil-Filled Equipment – what is it?Oil-Filled Equipment – what is it?

• Oil-filled operational equipment includes an oil storage container in which the oil is present to support the function of the apparatus or device.

• Examples of Oil-Filled Operational Equipment– Hydraulic Systems– Gear Boxes– Machining Coolant Systems– Heat Transfer Systems– Transformers– Circuit Breakers– Electrical Switches


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State RegulationsState Regulations

• May have similar or overlapping regulations– AST regulations– Petroleum bulk storage facilities licensing– State “SPCC” programs

• However, no there are no “authorized” or equivalent state programs – you must comply with the federal requirements irrespective of any state program!


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Navigable waters of the US - do I Navigable waters of the US - do I have the potential to discharge?have the potential to discharge?

YES!


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The SPCC PlanThe SPCC Plan

– Format and Content– PE Certification/Management Approval– Updates and Re-Certification


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SPCC Plan FormatSPCC Plan Format

• Emergency Action Plan

• SPCC Plan Text

• Tables and Figures

• Appendices


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SPCC Plan ContentSPCC Plan Content

• Facility Information

• Oil Spill Contingency Plan

• Preventive Measures


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SPCC Plan Tables and FiguresSPCC Plan Tables and Figures

• Table– oil storage devices and oil-filled equipment– secondary containment– spill pathways

• Site Locus Plan• Site Diagram

– drainage/spill pathways– oil storage devices and oil-filled equipment– piping– emergency/communications equipment


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SPCC Plan AppendicesSPCC Plan Appendices

• Inspection forms

• Secondary containment calculations

• Tank integrity testing schedule


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SPCC Plan CertificationSPCC Plan Certification• Your SPCC Plan must be:

– Approved by company management (corporate officer or designated representative such as EHS manager)

– Certified by a licensed Professional Engineer (PE)* – Some states require that the PE be licensed in the state

where the facility is located (NOT a federal requirement)

• Must identify an Emergency Coordinator (EC)• Grant authority for the EC to commit company

resources for spill response

*Unless your facility is a Tier I or II “Qualified Facility”


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SPCC PlanSPCC Plan

• Annual review recommended• Five-year comprehensive review and

recertification required• Administrative updates (e.g., new phone

numbers) do not require recertification• Plan review and recertification for technical

amendments– New tanks or storage systems– New/different product storage– Changes in facility design/operation


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SPCC Plan ImplementationSPCC Plan Implementation

• Inspections• Secondary Containment• Stormwater Management• Oil Transfers and Active Measures• Tank Integrity Testing


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INSPECTIONS• Inspections are conducted to identify malfunctions,

deterioration, operator error, and deficiencies which may cause or lead to spills/releases of oil

• SPCC requires periodic inspections


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INSPECTIONS (Continued)• Oil-filled equipment, containers, and storage area are

visually inspected on a weekly basis for the following:– All equipment will be examined (where applicable) for leaks

from seams, rivets and bolts and gaskets and for signs of deterioration (e.g., discoloration, corrosion, cracks) of the vessel, aboveground foundation and structure supports;

– All associated piping will be checked for dripping, loose joints, damage to supports, and pipe deflection;

– All connections will be checked for leakage, drainage, tightness, and appropriate capping;

– All pumps will be checked for evidence of leakage, proper operation, and damage;

– All storage areas and containment systems will be inspected for integrity and the accumulation of stored product. If oil is observed in the containment system, the source of the oil will be determined; and

– The security of the containers/areas/equipment will be checked (i.e., valves and equipment locked and secured).


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INSPECTIONS

• Three potential outcomes:1. All OK

2. Non-emergency problem detected – corrective action/maintenance required

3. Actual spill or leak identified


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CONTAINMENT SYSTEMS

• Prevent migration of spill/release from immediate area

• SPCC containment requirements– Oil storage tanks have 100 percent containment (plus

adequate freeboard for precipitation for outdoor tanks)– Drum/container storage areas have containment for 10

percent of total storage capacity– Oil-filled equipment – secondary containment where

practicable– For oil-filled equipment without containment, alternative

measures in place including training, spill response equipment, inspections


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Stormwater

• Stormwater Drainage Procedure– Dike drains must be closed and locked!– Visually inspect for oil sheen/evidence of

contamination– Open valves and allow stormwater to drain– Log each stormwater drainage event


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Oil TransfersOil Transfers

• Spills happen when/how?– DURING TRANSFER OPERATIONS!

– Deliveries, re-fueling, equipment maintenance etc


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Secondary Containment for Transfer AreasSecondary Containment for Transfer Areas

• SPCC requirements – Secondary containment needs to be sized only to address

the typical failure mode and quantity for the item

– Passive or active measures can be utilized

– Specific provisions such as drip pans, sumps, and collection systems are recommended

• Overall result:– Facilities will have discretion in meeting general secondary

containment requirements, consistent with good engineering practices


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Secondary Containment – Example – Secondary Containment – Example – Active (Temporary) MeasureActive (Temporary) Measure

• Storm drain liner and dam


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Transfer Location ChecklistTransfer Location Checklist

• Identify all transfer points?• HIGH-RISK LOCATIONS?• Included in SPCC plan?

– Table and site diagram if fixed location

• Most probable spill?• Spill pathways?• Containment?• Active measures?


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Integrity Inspections forIntegrity Inspections forAboveground Storage TanksAboveground Storage Tanks


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Category 1 TanksCategory 1 Tanks

• Category 1 tanks as defined by Steel Tank Institute (STI) are:

– Aboveground tanks

– < 5,000-gallon capacity

– Steel construction

– Not in direct contact with the ground surface• On legs or cradles• Tank bottom not in contact with soil or concrete/asphalt base

– Has a continuous release detection method (CRDM)• What does this mean?

– Passive system, not requiring sensors or power to operate, that allows inspector to visually detect a release. Examples include secondary containment including vaults, dikes and double-walled tanks.


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Steel Tank Institute (STI) SP001 Steel Tank Institute (STI) SP001 Inspection StandardInspection Standard• Category 1 tanks < 5,000-gallon capacity are recommended only

for periodic visual inspection

• Inspections are to be performed in accordance with STI SP001 standard:

– Monthly inspections– Annual inspections (more detailed)– Owner’s inspector must meet the requirements of the standard

• STI SP001 provides detailed program including:– Inspector qualifications (paragraph 4.1)– Inspection instructions (Section 6)– Monthly and annual inspection checklists (Appendix C)– Recordkeeping– Immediate action items and corrective action recommendations


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12 Steps to Compliance – SPCC Facility 12 Steps to Compliance – SPCC Facility Inspection and AST Integrity Inspection and AST Integrity Inspection/Testing Program Inspection/Testing Program

• STEP 1: Establish routine periodic (weekly or monthly) visual inspection program• STEP 2: Get a copy of STI SP001 standard for your facility• STEP 3: Ensure that your SPCC monthly checklist includes all required items• STEP 4: Provide hands-on training to facility personnel involved in inspections• STEP 5: Do your monthly inspections!• STEP 6: Maintain signed inspection records on file for at least three years• STEP 7: Perform annual comprehensive tank condition inspection using STI

checklist and protocol• STEP 8: Utilize facility manager/engineer or someone with technical training to

perform the annual inspection if available• STEP 9: Maintain signed annual inspection forms on file for at least three years• STEP 10: Be proactive about tank housekeeping and preventive maintenance• STEP 11: Keep good records of repairs and preventive maintenance• STEP 12: Relax and feel good that you are in compliance!!!


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Inspections and Testing/Inspections and Testing/SPCC RecordkeepingSPCC Recordkeeping

• Keep written procedures and records of the inspections and tests for at least 3 years.

• Inspection forms and training records must be signed by the inspector or supervisor.

• Records and forms include:– Daily/weekly/monthly visual inspections– Containment area drainage logs/stormwater discharge forms– Tank construction records– Tank testing records– Tank repair/alteration history– Training records


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Personnel TrainingPersonnel Training

• Oil-handling personnel must be adequately trained in:

– The operation and maintenance of equipment to prevent discharges;

– Discharge procedure protocols;– Applicable pollution control laws, rules, and regulations;– General facility operations;– Contents of the facility SPCC Plan; and– Spill briefings (lessons learned, malfunctions at your and other

facilities, and precautionary measures).

• Initial and annual refresher training for all personnel involved in oil-handling

• Discharge prevention meetings held at least once per year


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Personnel Training – Personnel Training – Practical ConsiderationsPractical Considerations• Training should include practical, facility-specific

information on what do in case of a spill:– Who is the EC and who are the alternates– Where is the spill response equipment located– Who is your spill response contractor– Who needs to be notified, and who makes the notifications– AND MOST IMPORTANTLY, SAFETY CONSIDERATIONS:

• what size spill is too big to address with training levels of personnel and available materials/equipment

• evacuation – how to decide, how to evacuate, where to muster• when to call 911 and get out!

• If you have not established procedures and provided training for facility personnel, the odds of a successful spill response are very poor!


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Personnel Training – Personnel Training – Practical ConsiderationsPractical Considerations

• If facility personnel are expected to provide anything beyond initial response (identification, closing valves/shutting off controls, and evacuating the area), they need additional spill response training:– Industry standard is OSHA 24-hour emergency response

training– Personnel expected to operate in protective clothing such as

SCBAs may need additional training (e.g., OSHA 40-hour HAZWOPER)

– 8-hour annual refresher required for these qualifications– Facilities subject to FRP requirements have additional

requirements for annual spill response drills and exercises– Personnel expected to be involved in longer-term responses

should have Incident Command System (ICS) training


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SPCC ResourcesSPCC Resources

• EPA SPCC Website– http://www.epa.gov/emergencies/content/spcc/

• EPA Guidance for Regional Inspectors– http://www.epa.gov/emergencies/content/spcc/spcc_guidance.htm– This has not been updated to reflect the latest amendments

but is still a great resource • OR

– Tim Kipp, CHMM– GZA GeoEnvironmental, Inc.– 4 Free St– Portland, ME 04101– (207) 358-5121– [email protected]– www.gza.com


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SPCC ResourcesSPCC Resources

• EPA SPCC Website– http://www.epa.gov/emergencies/content/spcc/

• EPA Guidance for Regional Inspectors– http://www.epa.gov/emergencies/content/spcc/spcc_guidance.htm– This has not been updated to reflect the latest amendments

but is still a great resource

• Steel Tank Institute– http://www.steeltank.com/– STI Standard SP001 for inspection of shop-fabricated tanks– Includes inspection requirements/forms for periodic visual

inspection of Category 1 tanks by owner’s representative

1 New England Healthcare Engineers Society NEHES SPCC Regulations: Applicability and Requirements Timothy W. Kipp, CHMM Senior Consultant GZA GeoEnvironmental,

Documents

examples of oil

oil storage container

recertification slide

engine fluids

dielectric fluids

metalworking fluids

transmission fluids

revised rule