1 spcc administrative requirements a&wma ss conference callaway gardens, ga august 2015

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SPCC Administrative RequirementsA&WMA SS Conference

Callaway Gardens, GA

August 2015

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Outline

Background SPCC Plan Certifications & Approvals SPCC Plan Reviews & Revisions SPCC Plan Spill Reporting

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USEPA - Region 4 Emergency Response Program

Cadre of 30 Federal On-Scene Coordinators (OSCs)– Based in Atlanta, GA. Outpost locations in Mobile, AL,

Tallahassee, FL, Louisville, KY, Raleigh, NC, Jackson, TN 24/7 On-Call Status Respond to releases of hazardous substances and oil

spills; All environmental hazards response (air, water, land,); Federal disaster and WMD/CT response capability; Planning and Preparedness (Drills) Oil Pollution Prevention (SPCC and FRP

Inspections)

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USEPA – Region 4

For oil and hazardous substance responses, EPA and U.S. Coast Guard (USCG) geographical boundaries are defined by the Region 4 “Memorandum of Understanding”

(MOU).

Coastal ResponsesInland Responsesx

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Oil Pollution Prevention Regulations – SPCC Rule – 40 CFR 112

Spill, Prevention, Control, and Countermeasure (SPCC) regulation (40 CFR 112) requires the preparation and implementation of site-specific plans to prevent oil discharges that could affect navigable waters

Authority: Clean Water Act (CWA) § 311(j)(1)(C) and 501 and codified under 40 CFR Part 112

EPA’s Office of Emergency Management administers the Rule

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Purpose SPCC - (40 CFR Part 112)

To prevent oil discharges from reaching the navigable waters of the U.S. or adjoining shorelines;

To ensure effective and proactive measures are used in response to an oil spill;

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Purpose of SPCC?

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History of Oil Pollution Prevention Regulations

1972 Federal Water Pollution Control Act Amendments1974 Original SPCC Rule Published1988 Ashland Oil Spill – SPCC Task Force Formed1989 Exxon Valdez Spill in Alaska1991/93 Proposed SPCC Rule Revisions1994 Final Facility Response Plan (FRP) Rule published2001 Draft Final SPCC Rule Revisions2002 Final “Revised” SPCC Rule published 7/17/022004 SPCC litigation settlement2006 SPCC Rule Amendments published on 12/26/062008 SPCC Rule Amendments published on 12/5/082009 12/5/08 SPCC Rule amendments delayed2009 SPCC Rule Amendments published 11/5/092010 Final Compliance Date w/ SPCC amendments for FRPs:

11/10/10 2011 Final Compliance Date w/ SPCC amendments: 11/10/112013 Final Compliance Date w/ SPCC amendments for Farms: 5/10/13

2014 Water Resources Reform & Development Act (WRRDA)

18 Photos courtesy ofNOAA Office of Response and Restoration, National Ocean Service

SPCC History: Ashland Oil Spill

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Administrative Requirements for SPCC Plans

Certification of SPCC Plans

SPCC Plans must be certified by a Professional Engineer if the facility stores over 10,000-gallons of oil – 112.3(d)

Owner/operator may self-certify the SPCC Plan if facility stores 10,000-gallons of oil or less* – 112.3(g)

– QUALIFIED FACILITY

*assuming facility meets spill criteria

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PE Certification Attestations

Must Include all attestations in certification - 112.3(d)(1)(i to vi)

(i)PE is familiar with the requirements of this part;(ii)PE or agent has visited and examined the facility;(iii)The Plan has been prepared in accordance with good engineering practice, including consideration of applicable industry standards, and with the requirements of this part;(iv)Procedures for required inspections and testing have been established; and(v)The Plan is adequate for the facility.(vi)If applicable, for a produced water container subject to 112.9(c)(6), any procedure to minimize the amount of free-phase oil is designed to reduce the accumulation of free-phase oil and the procedures and frequency for required inspections, maintenance and testing have been established and are described in the Plan.

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Management Approval of Plan

The Plan must have the full approval of management at a level of authority to commit the necessary resources to fully implement the Plan (112.7)

– Include a management approval statement in the Plan that includes the printed name, date, and signature of approving official

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Management Review of the SPCC Plan

SPCC Plan to be reviewed and evaluated by management at least once every 5-years (112.5(b)

– Document this review with name, date, and signature

– NOTE: review does not require a recertification by a PE

– NOTE: review does not mandate revisions or a rewrite of Plan

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Amendment of SPCC Plans

SPCC Plans must be amended within 6-months of any change in facility design or construction which affects the facility’s potential to discharge oil (112.5(a)

Technical Amendments MUST be certified by a PE (112.5(c) Qualified facilities may self-certify amendments (112.6(g)(2)

Amendments must be implemented no later than 6-months following preparation of the amendment (112.5(a)

NOTE: amendment timeframes are not to be used to account for non-compliance

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SPCC Plan Retention

Maintain Plan at facility or nearest field office– No requirement to submit SPCC Plans to EPA

Plan is required to be available to EPA upon inspection during normal working hours

*Note: EPA does not formally “approve” or disapprove SPCC Plans

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Oil Spill Reporting

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OIL SPILL REPORTING When to Notify?

Notification required: When you have an oil spill (a discharge) in a harmful quantity

40 CFR 110.3 defines “harmful quantity” as:

Causes a film or sheen upon or discoloration of the surface of the water or adjoining shorelines OR

Causes a sludge or emulsion beneath the surface of the water or upon adjoining shorelines OR

Violates water quality standards

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OIL SPILL REPORTING – Who To Notify?

National Response Center (NRC), at 1-800-424-8802 Immediately

Check with your state for

other requirements!

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SPCC Spill Reporting

If your SPCC facility has a reportable discharge over certain volumes within any 12-month period, the facility is required to submit additional reporting information to EPA

– Volumes that trigger this reporting information 1,000-gallons in a single discharge 42-gallons in each of two discharges

Reporting information must be submitted within 60-days of spill

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SPCC Spill Reporting

Information to submit to EPA:– Name of Facility; Name of Owner/Operator; Location of the Facility– Maximum storage capacity of the facility and normal daily throughput– Corrective action taken, including description of equipment repairs and

replacements– Description of the facility, including maps, flow diagrams, topos– Cause of the discharge, including a failure analysis of the system in

which the failure occurred– Additional preventive measures undertaken or considering to minimize

the possibility of recurrence and– Other information as the Regional Administrator may require

Oil Spill Reporting vs SPCC Spill Reporting

Note: reporting a discharge to the National Response Center (NRC) as required WILL NOT meet your SPCC spill reporting requirements– SPCC spill reporting requires additional

information to be submitted to EPA Submit information in written format

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QUESTIONS?

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For Additional Information

Ted Walden EPA R4 404-562-8752

walden.ted@epa.gov

www.epa.gov/oilspill

National SPCC/RCRA Hotline

1-800-424-9346