Smithfield Foods, Inc. Environmental Training Conference September 14, 2010 John Meyer, P.E., Director of Environmental Affairs John Morrell - PowerPoint PPT Presentation

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Smithfield Foods, Inc. Environmental Training Conference September 14, 2010 John Meyer, P.E., Director of Environmental Affairs John Morrell

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... Cleanup/Mitigate Disposal of Recovered Materials Loading/Unloading Activities Security ... the containment system ... or guarded entrance when ... – PowerPoint PPT presentation

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Title: Smithfield Foods, Inc. Environmental Training Conference September 14, 2010 John Meyer, P.E., Director of Environmental Affairs John Morrell


1
Smithfield Foods, Inc.Environmental Training
ConferenceSeptember 14, 2010John Meyer, P.E.,
Director of Environmental AffairsJohn Morrell
Company
  • Spill Prevention, Control, and Countermeasure
    (SPCC) Plan

2
SPCC Plan Who Needs One??
  • Required for facilities with an aggregate
    aboveground oil storage capacity greater than
    1,320 gallons or a completely buried oil storage
    capacity greater than 42,000 gallons and
  • Could reasonably be expected to discharge oil
    into navigable waters of the US or adjoining
    shorelines.

3
SPCC Plan What is Oil??
  • Oil definition includes animal fats, oils, and
    greases, fish and marine mammal oils, and
    vegetable oils including oils from seeds, nuts,
    fruits, and kernels
  • (40 CFR 112.12).
  • Oils also include petroleum, fuel oil, sludge,
    synthetic oils, mineral oils, oil refuse, or oil
    mixed with waste other than dredged spoil (40 CFR
    112.8)
  • Includes oil in transformers, hydraulic
    equipment, and DAF float storage tanks.

4
Oil Filled Transformers
  • Oil filled transformers are considered
    operational equipment not bulk storage
    containers, so they do not require strict
    secondary containment but they
  • must meet other SPCC requirements such as the
    general requirements of 112.7(c), to provide
    appropriate containment and/or diversionary
    structures to prevent discharged oil from
    reaching a navigable watercourse.
  • (Reference Page 47054 Federal Register, 7/17/02)

5
Wastewater Exemption
  • Containers used exclusively for wastewater
    treatment are excluded from SPCC regulations,
    however, the production, recovery, or recycling
    of oil is not wastewater treatment for the
    purposes of this paragraph. (40 CFR 112.1(d)(6)
  • If a wastewater facility or part thereof is used
    for the purpose of storing oil, then there is no
    exemption and its capacity must be counted as
    part of the storage capacity of the facility.
    (Reference Page 47068 Federal Register, 7/17/02)

6
SPCC Plan Components
  • Oil Storage Container List
  • Discharge Prevention Measures
  • Good House Keeping
  • Discharge Controls and Secondary Containment
  • Discharge Countermeasures Cleanup/Mitigate
  • Disposal of Recovered Materials
  • Loading/Unloading Activities
  • Security
  • Overfill Prevention - Tank Alarm Systems
  • SPCC Plot Plan

7
SPCC Plan Requirement
  • Secondary Containment Drainage (Bypass Valve
    Drainage) Records
  • OM of Equipment to Prevent Discharge
  • Quarterly Inspections of containment, curbing,
    valves, pumps, piping, fill/overflow, transfer
    points
  • Annual Training
  • Periodic Spill Prevention Briefings
  • Spill/Release Incident Documentation
  • Records Retention for 3 Years

8
Most Common Violations
  • Lack of Training Records
  • Lack of Secondary Containment Drainage Drainage
    Records
  • Lack of Tank/Transformer Inspection Records
  • No Containment for Transfer Areas
  • No Secondary Containment for Bulk Containers
  • Addressing Spills from Piping
  • No P.E. Certification of SPCC Plan (where
    required)
  • No SPCC Plan

9
SPCC Plot Plan Includes
  • The physical layout of the site including all
    buildings, fencing, security, areas of gravel,
    concrete, and grass, storm water drainage
    ditches, storm sewer inlets, storm water
    outfalls, and spill kit locations
  • Surface drainage flow directions
  • Location of all oil containers gt 55 gallons
  • Location of all transfer stations and connecting
    piping.

10
Secondary Containment
  • Structures required to provide a means of
    containment for the entire capacity of the
    largest single container and sufficient freeboard
    to contain precipitation (40 CFR 112.8(c)(2) 40
    CFR 112.12(c)(2))
  • We believe that the proper standard for
    sufficient freeboard to contain precipitation is
    that amount necessary to contain precipitation
    from a 25-year, 24-hour storm event.
  • (Reference Page 47117, Federal Register,
    7/17/02)
  • Diversionary structure to process wastewater is
    alternatively sufficient.

11
Earthen Containment Structures
  • Earthen containment structures are allowed if
    they are sufficiently impervious.
  • Walls and floors must be capable of containing
    oil and must be constructed so that any discharge
    from the primary tank or piping will not escape
    the containment system before cleanup occurs.
  • Industry Standard Hydraulic conductivitylt10-7
    cm/sec (ASTM D5084 Permeability Test).

12
Loading/Unloading
  • The requirements of 40 CFR Part 112.7(h) do not
    apply to facilities that do not contain loading
    racks.
  • Loading racks are associated with high-volume
    loading operations with a system of arms, piping,
    and pumps as opposed to simple direct connection
    loading/unloading operations.
  • We generally claim that we dont have loading
    racks at our facilities, so this requirement does
    not apply, but

13
Loading/Unloading
  • Plant personnel should be present during oil
    loading/unloading operations.
  • Employees, vendors, and truck drivers should be
    instructed not to leave the vehicle until the
    transfer has been completed.
  • Drivers should be instructed not to top off the
    tanks.
  • Fueling and loading operations, including bulk
    transfer, should be minimized during times of
    heavy rainfall.
  • Nearby storm sewers can be covered to prevent a
    release to the environment during
    loading/unloading events.

14
Security Requirements
  • Security fence surrounding the property with
    either a locked or guarded entrance when the
    facility is not attended
  • Locked valves on drains from secondary
    containment structures when in non-operating or
    non-standby status
  • Locked starter controls on oil pumps in the off
    position when in non-operating or non-standby
    status
  • Securely cap or blank flange loading/unloading
    connections when not in service
  • Sufficient facility lighting to protect against
    vandalism and to detect potential discharges
    during hours of darkness.

15
Tank Integrity Testing
  • EPA allows for equivalent environmental
    protection to meet the requirements of 40 CFR
    Part 112.8(c)(6) and 40 CFR Part 112.12(c)(6).
  • For well-designed, shop-built containers with a
    shell capacity less than or equal to 30,000
    gallons, combining proper visual inspections
    placement of a barrier between the container and
    the ground (as compared to a container in contact
    with soil) designed and operated in a way that
    ensures that any leaks are immediately detected
    will provide equivalent environmental protection.
  • Reference Settlement agreement between the
    American Petroleum Institute and Marathon Oil
    company and US EPA, dated March 29, 2004.

16
Alarm Systems
  • Fast Response System direct visual gauge
    person present to monitor filling process
  • High liquid level alarm
  • High liquid level pump cutoff device
  • Direct audible or code signal communication
  • Manual stick for small tanks.

17
Reportable Discharge Events
  • Defined in the Clean Water Act as
  • Any discharge event which results in an oil
    discharge to an off-site surface water
  • Could violate applicable water quality standards
  • Could cause a film or oil sheen, or discoloration
    of a surface water
  • Could cause a sludge or emulsion to be deposited
    beneath the surface of the water.
  • If you have a reportable discharge event, call
    NRC (800) 424-8802 immediately, then SERC and
    LEPC

18
SPCC Plan Certification
  • Self-certification of the SPCC Plan (i.e. no P.E.
    stamp required) is allowed if
  • 1. Total aboveground oil capacity is lt10,000
    gallons
  • 2. In the last 3 years, no single oil spill
    event exceeding of 1,000 gallons
  • 3. In last 12 months, no two oil spill events
    each in exceeding 42 gallons

19
Further Information
  • EPAs Oil Spill Web Site
  • www.epa.gov/oilspill
  • Oil Information Center Hotline
  • (800) 424-9346
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