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SPCC Update

SPCC Update. Laura J. Shaffer, P.E., CHMM GZA GeoEnvironmental, Inc IAAP 39 th Annual Convention May 17, 2007. Spill Prevention, Control, and Countermeasures (SPCC) Rule. United States Environmental Protection Agency 40 CFR Part 112

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SPCC Update

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  1. SPCC Update Laura J. Shaffer, P.E., CHMM GZA GeoEnvironmental, Inc IAAP 39th Annual Convention May 17, 2007

  2. Spill Prevention, Control, and Countermeasures (SPCC) Rule United States Environmental Protection Agency 40 CFR Part 112 • On May 10, 2007 the EPA signed a rule to extend the compliance date for owners and operators of facilities preparing or amending and implementing SPCC Plans. This final rule extends the dates by which a facility must prepare or amend and implement its SPCC Plan until July 1, 2009. • EPA expects to propose further revisions to the SPCC rule in 2007.

  3. Applicability Facilities need to have an SPCC Plan if they have • An aboveground oil storage capacity greater than 1,320 gallons or • An underground oil storage capacity greater than 42,000 gallons • Only containers 55-gallons or greater count towards the applicability criteria and need to be included in the SPCC Plan • Includes Oil-Filled Operational Equipment • Includes Mobile Refuelers • Excludes Motive Power Containers

  4. Definition of a Facility A facility is defined as having the same owner/operator. For instance, a property that is on opposites sides of a road but have the same owner, would be considered one facility.

  5. What Oils are Covered under the SPCC regulation? Oils covered under the SPCC regulation include: • 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.

  6. Oil-Filled Operational Equipment 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

  7. Mobile Refuelers A mobile refueler is a bulk storage container onboard a vehicle or towed, that is used soley to store and transport fuel to or from a motor vehicle, ground service equipment, or other oil storage container.

  8. Motive Power Containers Exempt from the SPCC regulations in December 2006 A Motive Power Container is any onboard bulk storage container used primarily to power the movement of a motor vehicle. • Examples of Motive Power Containers • Trucks • Automobiles • Bulldozers • Cherry pickers

  9. SPCC Plan Certification Your SPCC Plan must be certified by a Professional Engineer, unless your facility is a “Qualified Facility” A Qualified Facility must meet the following two conditions for the three years prior to the SPCC Plan certification date: • 10,000 gallons or less aboveground oil storage capacity; and • Must not have had a single discharge of oil to navigable waters exceeding 1,000 gallons, or two discharges of oil to navigable waters each exceeding 42 gallons within any twelve month period.

  10. Qualified Facilities Qualified Facilities which meet the requirements may self-certify their SPCC Plan. • The owner/operator that certifies a facility’s Plan also certifies that: • The Plan has been prepared in accordance with accepted and sound industry practices and standards and with the rule requirements; • Procedures for required inspections and testing have been established; • The Plan is being fully implemented; • The facility meets the qualifying criteria; • The Plan does not deviate from rule requirements except as allowed and as certified by a P.E.; and • Management approves the Plan and has committed resources to implement it.

  11. Qualified Facilities Benefits of being a Qualified Facility • Allows flexibility, in accordance with industry standards, when determining the testing and inspection schedule for tanks. • Does not have to provide secondary containment for oil-filled operational equipment, however does require alternative measures. • Security provisions are less stringent! Don’t have to fence the entire facility, only the area around the oil storage AST.

  12. Qualified Oil-Filled Operational Equipment In lieu of secondary containment for qualified oil-filled operational equipment, you must complete the following: • Implement an inspection and monitoring program • Develop an oil spill contingency plan • Provide a written commitment of resources to control and remove oil discharged.

  13. Facility Security Section 112.7(g)(1) requires that owners/operators fully fence the facility and lock or guard entrance gates. Qualified facilities donot have to fully fence their facility or guard entrance gates. Instead, qualified facilities may describe, in their Plan, how the facility controls access to oil storage areas and secures equipment to prevent acts of vandalism and assist in the discovery of oil discharges. navigable waters or adjoining shorelines: • Fence only around storage areas • Chain and lock storage area fence • Provide exterior lighting in hours of darkness

  14. Facility Drainage Systems Facility drainage must be designed such that flow from undiked areas will enter ponds, lagoons, or catchment basins and prevent oil-contaminated water from escaping the facility and discharging to navigable waters. OR Facility drainage from undiked areas may be directed into an oil-water separator.

  15. Secondary Containment Secondary containment is required around: • Bulk Storage Containers • Oil-Filled Operational Equipment (only if the facility is not a qualified facility) • Loading/Unloading Racks The secondary containment system must have a capacity to contain the largest single oil compartment or container plus “sufficient freeboard”. A sufficient freeboard capacity is the amount of precipitation from a 25-year, 24-hour storm event.

  16. Secondary Containment 112.7(c) SPPC rule states that the entire secondary containment system (walls & floor) must be capable of containing oil and must be constructed so that any discharge from a primary containment system will not escape the containment before clean-up occurs!

  17. Secondary Containment Secondary containment must be “sufficiently impervious” such that it would contain a spill. Concrete and asphalt that is not cracking would be considered “sufficiently impervious”. Secondary containment systems include: • Dikes or berms sufficiently impervious to contain oil • Curbing, culverting, gutters, or other drainage systems • Sorbent materials (for interior equipment or transformers)

  18. SPCC Requirements forAboveground and Underground Piping Aboveground piping must be protected against corrosion, regularly inspected, and must warn all vehicles entering the facility of the piping. Underground piping must be cathodically protected or double-walled with a leak detection system.

  19. Drainage from Diked Areas Diked areas include concrete walls or curbing in which precipitation is not able to escape. Drainage of precipitation from diked areas must be controlled by use of manual valves. The water within the diked area must be inspection for the presence of oil (sheen) prior to being discharged. A record of this drainage event and inspection must be maintained with your SPCC Plan.

  20. Inspections Regular inspections are required to be conducted on containers, associated piping and valves, and other equipment that could be a source or cause of an oil release. Types of inspections Visual Inspections Non-destructive testing (hydrostatic) The SPCC rule does not specify a schedule for visual and non-destructive testing. They rely on the P.E. and the Steel Tank Institute to determine a testing schedule for each tank.

  21. Oil Discharge Reporting Requirements A discharge of a “harmful quantity” must be immediately reported to the National Response Center 1-800-424-8802 A harmful quantity is a discharge of oil to a U.S. waterway that causes a film or sheen on the water’s surface

  22. Oil Discharge Reporting Requirements A discharge must be reported to the EPA Regional Administrator when there is a discharge of oil to navigable waters or adjoining shorelines: • More than 1,000 gallons of oil in a single discharge • More than 42 gallons of oil in each of the two discharges occurring within any twelve-month period. *The gallons specified (1,000 and 42) refers to the amount of oil that reaches navigable waters, not the amount of oil spilled.

  23. Emergency Spill Notification National Response Center 1-800-424-8802 Illinois EPA 1-800-782-7860

  24. Penalties for violations of the Clean Water Act The maximum civil penalty for failing to prepare an SPCC Plan is $25,000!!! Each day of non-compliance constitutes a separate violation. The EPA can fine up to $32,500 per violation per day!!!!

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