The Newly Revised SPCC Rules Spill Prevention Control and Countermeasure

1
The Newly Revised SPCC Rules Spill Prevention
Control and Countermeasure

• NON-TRANSPORTATION RELATED ONSHORE AND OFFSHORE
  FACILITIES
• Code of Federal Regulations
• Title 40 CFR Part 112

2
40 CFR Part 112

• Prevention requirements
• The SPCC regulation is codified at 40 CFR part
  112 and
• The original SPCC regulation first effective on
  January 10, 1974.
• New revisions to the rule published July 17,
  2002, Effective August 16, 2002

3
Purpose of 40 CFR Part 112

• To prevent oil discharges from reaching the
  navigable waters of the U.S. or adjoining
  shorelines,
• To ensure effective response to the discharge of
  oil, and
• To ensure that proactive measures are used in
  response to an oil discharge.

4
NON-TRANSPORTATION RELATED FACILITIES

• Regulations apply to
• Drilling
• Producing
• Gathering
• Storing
• Processing

• Refining
• Transferring
• Distributing
• Using
• Consuming

5
(No Transcript)
6
SPCC Applicability

• You must have an SPCC plan if your facility meets
  both of two criteria
• It can reasonably be expected to discharge oil to
  navigable waterways of the U.S. and adjoining
  shorelines, and
• It has over aboveground capacity of 1320 gallons
  of oil, or has over 42,000 gallons underground
  storage capacity

7
PART 112 DOES APPLY

• SPCC-regulated facilities are those that meet the
  following capacity threshold

gt 1320 gallons of oil in a single aboveground
container
gt1320 gallons aboveground in aggregate
8
PART 112 - DOES APPLY
42,000 GALLONS OF OIL

• To facilities having gt 42,000 gallons underground
  storage capacity

9
PART 112 - DOES APPLY

• Non-transportation related facilities which, due
  to their location could reasonably be expected to
  discharge oil into or upon the navigable waters
  of the United States or adjoining shorelines.

10
PART 112 - DOES NOT APPLY

• Non-transportation related facilities which, due
  to their location could not reasonably be
  expected to discharge oil into or upon the
  navigable waters of the United States or
  adjoining shorelines.

11
SPCC Applicability

• Owner/operator makes the decision on
  applicability of SPCC regulations to the facility
• Does the facility meet the two thresholds (oil
  waterway)?
• No requirement to submit SPCC plan to EPA
• EPA does not formally approve or disapprove of
  SPCC plan
• Plan required upon inspection

12
New Compliance Deadline
13
PREVENTION REQUIREMENTS

• SPCC regulations requires preparation and
  implementation of a written Plan to address
• Operating procedures for routine handling of
  products to prevent a discharge of oil
• Drainage control measures to prevent a discharge
  of oil
• Countermeasures to contain, clean up, and
  mitigate an oil spill
• Methods of disposal of recovered materials
• Contact list and phone numbers of company,
  contract response personnel, and National
  Response Center

14
SPCC Rule RevisionMain Changes

• Deminimis container size now 55 gallon
• Any container lt 55 gallons exempt
• Completely buried tanks subject to all of the UST
  technical requirements are now exempted (40 CFR
  280 or 281)
• Permanently closed tanks exempted, if no sludge,
  no liquid, piping is disconnected and blanked
  off, valves are closed/locked, and signs
  indicating closure and date

15
Not Counted
Counted
5-gallon buckets
55-gallon drum
5-gallon container
30-gallon drum
16
Labeled Out of Service
Permanently closed aboveground storage tank
17
SPCC Rule RevisionMain Changes

• Facility Diagram required in SPCC plan
• Physical layout of facility
• Location and contents of each container
• Wells, piping, and transfer stations
• Employee training for oil handling personnel only
• minimum of once a year previous requirement had
  no specific time frame

18
SPCC Rule RevisionMain Changes

• Professional Engineer must consider appropriate
  industry standards
• Allowable for Agent of Professional Engineer to
  visit facility for purposes of certification
• Allowance of deviations from some parts of the
  rule if equivalent environmental protection is
  provided and reasons for non-compliance explained
• (Does not include containment but the
  impracticability claim is extended to most
  containment requirements)

19
Qualified Facilities

• Must meet eligibility criteria to use alternative
  option
• Streamlined regulatory requirements
• Self-certified SPCC Plan instead of one reviewed
  and certified by a Professional Engineer
• Streamlined integrity testing requirements
• Streamlined facility security requirements
• May also use qualified oil-filled operational
  equipment option since an impracticability
  determination by a PE is not necessary

20
Qualified Facilities Eligibility Criteria

• Facility must have 10,000 gallons or less in
  aggregate aboveground oil storage capacity
• For the 3 years prior to Plan certification, or
  since becoming subject to the rule if it has
  operated for less than 3 years, the facility must
  not have had
• A single discharge of oil to navigable waters
  exceeding 1,000 U.S. gallons, or
• Two discharges of oil to navigable waters each
  exceeding 42 U.S. gallons within any 12-month
  period

21
Reportable Discharge History

• When determining the applicability of this
  criterion, the gallon amount(s) specified (either
  1,000 or 42) refers to the amount of oil that
  actually reaches navigable waters or adjoining
  shorelines, not the total amount of oil spilled.
• Oil discharges that result from natural
  disasters, acts of war, or terrorism are not
  included
• Facilities that have a reportable oil discharge
  after self-certifying the SPCC Plan do not
  automatically lose eligibility
• However, the Regional Administrator has the
  authority to require a Plan amendment

22
Self-Certification

• Owner/operator attests that he/she is familiar
  with the rule and has visited and examined the
  facility
• Owner/operator 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 PE
• Management approves the Plan and has committed
  resources to implement it

23
Alternative Measures

• May use environmentally equivalent measures and
  make impracticability determinations
• if reviewed and certified by a PE
• Rule provides alternative requirements for
  integrity testing and security
• do not need to be reviewed and certified by a PE

24
Technical Amendments

• May self-certify technical amendments as long as
  a PE has not certified the portion being changed
• If a PE certified the affected portion of the
  Plan, then a PE must certify the technical
  amendment

25
Alternative Integrity Testing Requirements for
Qualified Facilities

• Test and inspect each aboveground container for
  integrity on a regular schedule and whenever
  material repairs are made
• Flexibility to determine, in accordance with
  industry standards
• Appropriate qualifications for personnel
  performing tests and inspections
• Frequency and type of testing and inspections
  that take into account container size,
  configuration, and design
• No longer specifically requires both visual
  inspection and another testing method

26
Alternative Facility Security Requirements for
Qualified Facilities

• To prevent acts of vandalism and assist in the
  discovery of oil discharges, owners/operators of
  qualified facilities may describe how they
• Control access to the oil handling, processing
  and storage areas
• Secure master flow and drain valves and
  out-of-service and loading/unloading connections
  of oil pipelines
• Prevent unauthorized access to starter controls
  on oil pumps
• Address the appropriateness of security lighting

27
Qualified Facilities - Summary
28
Oil-Filled Operational Equipment Definition

• Equipment that includes an oil storage container
  (or multiple containers) in which the oil is
  present solely to support the function of the
  apparatus or the device
• Not considered a bulk storage container
• Does not include oil-filled manufacturing
  equipment (flow-through process)
• Piping might be considered a component of
  oil-filled operational equipment
• Yes, if it is inherent to the equipment and used
  solely to facilitate operation of the device
• No, if it is not intrinsic to the equipment
  (i.e., flowlines, transfer piping or piping
  associated with a process)

29
Oil-Filled Operational Equipment

• Examples hydraulic systems, lubricating systems,
  gear boxes, machining coolant systems, heat
  transfer systems, transformers, circuit breakers,
  electrical switches, other systems containing oil
  solely to enable the operation of the device

30
Oil-Filled Operational Equipment

• Alternative to the general secondary containment
  requirements for qualified oil-filled operational
  equipment
• Prepare an oil spill contingency plan and a
  written commitment of manpower, equipment, and
  materials
• Have an inspection or monitoring program to
  detect equipment failure and/or a discharge
• Individual impracticability determination for
  each piece of equipment is not required

31
Oil-Filled Operational Equipment Eligibility
Criteria

• For the 3 years prior to Plan certification, or
  since becoming subject to the rule if it has
  operated for less than 3 years, the facility must
  not have had
• A single discharge of oil from any oil-filled
  operational equipment to navigable waters
  exceeding 1,000 U.S. gallons, or
• Two discharges of oil from any oil-filled
  operational equipment to navigable waters each
  exceeding 42 U.S. gallons within any 12-month
  period
• Eligibility determined by the reportable
  discharge history from the equipment, not the
  entire facility

32
Contingency Plan

• Detailed oil spill response and removal plan to
  control, contain, and recover an oil discharge in
  quantities that may be harmful to navigable
  waters/adjoining shorelines
• Elements outlined in 40 CFR 109.5
• Authorities, responsibilities, and duties of all
  persons, organizations, or agencies involved in
  oil removal operations
• Notification procedures for the purpose of early
  detection and timely notification of an oil
  discharge
• Provisions to ensure that full resource
  capability is known and can be committed during
  an oil discharge
• Provisions for well-defined and specific actions
  to be taken after discovery and notification of
  an oil discharge
• Procedures to facilitate recovery of damages and
  enforcement measures

33
Written Commitment

• Facilities must be able to implement the
  contingency plan
• Owner/operator must provide a written commitment
  of manpower, equipment, and materials to
  expeditiously control and remove any quantity of
  oil discharged that may be harmful
• Elements also included in 40 CFR 109.5

34
Inspections and Monitoring Program Requirements

• Develop an appropriate set of procedures for
  inspections or a monitoring program for equipment
• Written description of the inspection or
  monitoring program included in SPCC Plan
• Keep a record of inspections and tests, signed by
  the appropriate supervisor or inspector, for
  three years

35
Oil-Filled Operational Equipment - Summary
To use this alternative, a facilitys oil-filled
operational equipment must meet requirements for
its reportable discharge history. The facilitys
oil-filled operational equipment must not have
had (1) a single discharge of oil to navigable
waters exceeding 1,000 U.S. gallons or (2) two
discharges of oil to navigable waters each
exceeding 42 U.S. gallons within any twelve-month
period, in the three years prior to the SPCC Plan
certification date, or since becoming subject to
40 CFR part 112 if operating for less than three
years.
36
TECHNICAL REQUIREMENTSOil Production Facilities
(onshore)
37
TECHNICAL REQUIREMENTS

• Oil Production Facility - Drainage
• If dikes at tank batteries and separation/treating
  areas have drain valves, they must be closed at
  all times except when rainwater is being drained.
• Rainwater must be inspected before being drained
  so that discharge of oil does not occur.
• Accumulated oil on the rainwater must be picked
  up and returned to storage or disposed of in
  accordance with legally approved methods.

38
TECHNICAL REQUIREMENTSOil Production Facility
Drainage (continued)

• Open and close valves under responsible
  supervision
• Keep adequate records of such drainage events
• Inspect field drainage ditches, road ditches, and
  oil traps, sumps, and skimmers at regular
  intervals and remove accumulated oil.

39
(No Transcript)
40
TECHNICAL REQUIREMENTS Oil Production Facility -
Bulk Storage Containers

• Requirements the same as old rule
• Bulk storage tanks shall be compatible with the
  material stored and the conditions of storage.
• Storage tanks in good condition
• No large scale corrosion no holes, flaking or
  pitting
• No leaking oil

41
(No Transcript)
42
(No Transcript)
43
TECHNICAL REQUIREMENTSBulk Storage Containers
(continued)

• All tank battery, separation, and treating
  facilities must have secondary containment for
  the entire capacity of the single largest
  container plus freeboard for precipitation (new
  requirement).
• No specific freeboard value or required (for
  example 110). Use local climate conditions and
  sound engineering.
• Means tanks, separators, heater treaters, gun
  barrels
• Includes most salt water tanks (if any oil in
  them)

44
TECHNICAL REQUIREMENTS

• Bulk Storage Containers (continued)
• Large volumes of water in containment not allowed
• Soil ok if not permeable (good idea to have some
  clay content)
• No large rooted plant systems (cactus, shrubs,
  etc.)
• Vegetation kept down (must be able to inspect
  berm integrity and tanks
• Keep berm from eroding, developing low spots

45
(No Transcript)
46
(No Transcript)
47
(No Transcript)
48
TECHNICAL REQUIREMENTS

• Bulk Storage Containers (continued)
• All tanks containing oil should be visually
  examined for condition and need for maintenance
  on a scheduled periodic basis.
• Check base, tank bases susceptible to corrosion
• Keep soil from piling up around base
• Keep vegetation away from base (cant inspect it
  if you cant see it)
• Supports and foundations in good condition
• Level
• No large gaps underneath

49
(No Transcript)
50
(No Transcript)
51
(No Transcript)
52
TECHNICAL REQUIREMENTS Bulk Storage Containers
(continued)

• New and old tank battery installations should be
  fail-safe engineered to prevent spills.
• One or more of the following is required
• Adequate tank capacity
• Overflow equalizing lines between tanks
• Adequate vacuum protection
• High level sensors where part of an automated
  system

53
(No Transcript)
54
TECHNICAL REQUIREMENTS

• Facility Transfer Operations
• Aboveground valves, fittings, stuffing boxes,
  pipelines must be inspected periodically and kept
  from leaking.
• Inspect saltwater disposal facilities
  periodically to detect problems that could cause
  an oil discharge.

55
(No Transcript)
56
TECHNICAL REQUIREMENTS Facility Transfer
Operations

• Production facilities must have a program of
  flowline maintenance to prevent spills.
• No large scale corrosion (pitting, flaking)
• Leaking/corroded flowlines repaired or replaced
• Under new rule, secondary containment is required
  for flowlines
• Sorbent materials, drainage systems, other
  equipment are possible forms of containment
  (engineer approval)

57
TECHNICAL REQUIREMENTS Facility Transfer
Operations

• We recognize that containment is often
  impracticable
• If not practicable,
• Impracticability Claim must be made
• Written contingency plan (commitment of manpower
  and materials)

58
(No Transcript)
59
Tank Truck Loading/Unloading

• General containment is required (no specific
  size volume required)
• P.E. will have final determination as to whats
  appropriate containment

60
TECHNICAL REQUIREMENTS

• Oil Drilling and Workover Facilities
• Drilling and workover rigs required to have SPCC
  plan
• Secondary containment required, catchment basins
  or diversion structures necessary to intercept
  and contain spills of fuel, crude oil, or oily
  drilling fluids.
• A blowout prevention (BOP) assembly and well
  control system should be installed that is
  capable of controlling any well head pressure
  that may be encountered while that BOP assembly
  is on the well.

61
(No Transcript)
62
(No Transcript)
63
Produced Water

• Oil Production
• Produced water tanks at oil production facilities
  are subject to the rule, and are not eligible for
  the wastewater treatment exemption.
• Dry Gas
• Produced water tanks at dry gas production
  facilities are eligible for the wastewater
  treatment exemption if they do not contain oil.

64
(No Transcript)
65
Contacts at EPA

• Donald Smith 214-664-6489
• Richard Franklin 214-665-2785
• Don Sharp 214-665-7219
• Jim Trusley 214-665-2253
• Tom McKay 214-665-2180
• Mike Ryan 214-665-8380
• USEPA Homepage www.epa.gov/oilspill
• Oil Information Hotline - 1-800-424-9346