SPCC Regulations: Applicability and Requirements

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SPCC Regulations Applicability and Requirements

• Timothy W. Kipp, CHMM
• Senior Consultant
• GZA GeoEnvironmental, Inc.
• 4 Free St
• Portland, ME 04101
• [phone]
• timothy.kipp_at_gza.com

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Spill Prevention, Control, and Countermeasures
(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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Applicability

• 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 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 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 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 have the
potential to discharge?

• YES!

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The SPCC Plan

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

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SPCC Plan Format

• Emergency Action Plan
• SPCC Plan Text
• Tables and Figures
• Appendices

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SPCC Plan Content

• Facility Information
• Oil Spill Contingency Plan
• Preventive Measures

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SPCC 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 Appendices

• Inspection forms
• Secondary containment calculations
• Tank integrity testing schedule

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SPCC 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 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 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
• All OK
• Non-emergency problem detected corrective
  action/maintenance required
• 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 Transfers

• Spills happen when/how?
• DURING TRANSFER OPERATIONS!
• Deliveries, re-fueling, equipment maintenance etc

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Secondary 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 Active
(Temporary) Measure

• Storm drain liner and dam

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Transfer 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 forAboveground Storage
Tanks
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Category 1 Tanks

• Category 1 tanks as defined by Steel Tank
  Institute (STI) are
• Aboveground tanks
• lt 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 Inspection
Standard

• Category 1 tanks lt 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)
• Owners 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 Inspection
and AST Integrity 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/SPCC 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 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 Practical 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 Practical 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 Resources

• EPA SPCC Website
• http//www.epa.gov/emergencies/content/spcc/
• EPA Guidance for Regional Inspectors
• http//www.epa.gov/emergencies/content/spcc/spcc_g
  uidance.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
• [phone]
• timothy.kipp_at_gza.com
• www.gza.com

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SPCC Resources

• EPA SPCC Website
• http//www.epa.gov/emergencies/content/spcc/
• EPA Guidance for Regional Inspectors
• http//www.epa.gov/emergencies/content/spcc/spcc_g
  uidance.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
  owners representative