2006 compliance assistance conference - ohio epaweb.epa.ohio.gov/ocapp/spccfinalppt3-06.pdf · on...

2006 Compliance Assistance 2006 Compliance Assistance ConferenceConference

Spill Prevention Control & Spill Prevention Control & Countermeasures PlansCountermeasures Plans

(SPCC)(SPCC)

Jim CrawfordJim CrawfordDivision of Emergency & Remedial ResponseDivision of Emergency & Remedial Response

Emergency Response UnitEmergency Response UnitSenior OnSenior On--Scene CoordinatorScene Coordinator

Southwest District OfficeSouthwest District Office

Session OverviewSession Overview

What is SPCC? What is SPCC? Who is regulated under SPCC?Who is regulated under SPCC?What are the SPCC regulations?What are the SPCC regulations?How do I prepare an SPCC Plan?How do I prepare an SPCC Plan?Where can I get help?Where can I get help?Q&AQ&A

What Is SPCC?What Is SPCC?Is It New ?Is It New ?

Promulgated in 1973Promulgated in 1973

Revisions in subsequent yearsRevisions in subsequent yearsAttempts to update rule, early to mid 1990sAttempts to update rule, early to mid 1990sFacility Response Plans (FRPs), July 2002Facility Response Plans (FRPs), July 2002Final rule to extend deadlines, August 11, Final rule to extend deadlines, August 11, 20042004

What is SPCC ?What is SPCC ?

Required by 40 CFR Part 112 (Section 311 of Required by 40 CFR Part 112 (Section 311 of the Clean Water Act)the Clean Water Act)

Required for facilities that store and use oil*Required for facilities that store and use oil*

Designed to be a “Prevention Plan” Designed to be a “Prevention Plan” rather than a “Response Plan”rather than a “Response Plan”

What is SPCC ?What is SPCC ?

Regulatory authority lies with USEPA Regulatory authority lies with USEPA

Ohio EPA has provisions for prevention under Ohio EPA has provisions for prevention under ORC 6111ORC 6111

Ohio EPA has not promulgated regulationsOhio EPA has not promulgated regulationsOhio EPA is conducting compliance Ohio EPA is conducting compliance inspectionsinspections

Facility TriggersFacility Triggers

NonNon--transportation related oil* storagetransportation related oil* storage

Storage ThresholdsStorage ThresholdsAggregate storage capacity of > 1,320 gals. Aggregate storage capacity of > 1,320 gals. Underground storage capacity of > 42,000 Underground storage capacity of > 42,000 gals.*gals.*

Reasonable Expectation of Discharge to Reasonable Expectation of Discharge to Navigable Waters*Navigable Waters*

Definition of OilDefinition of Oil

OILOIL -- Oil of any kind or in any form, including, but Oil of any kind or in any form, including, but not limited to petroleum, fuel oil, sludge, oil refuse not limited to petroleum, fuel oil, sludge, oil refuse and oil mixed with wastes other than dredged and oil mixed with wastes other than dredged spoil.spoil.

Includes animal & vegetable oils, nonIncludes animal & vegetable oils, non--petroleum petroleum oils oils –– synthetic, fish oils, seed oilssynthetic, fish oils, seed oils

Definition of Navigable WatersDefinition of Navigable Waters

NAVIGABLE WATERSNAVIGABLE WATERS means all navigable means all navigable waters of the United States, including: interstate waters of the United States, including: interstate waters, intrastate waters, tributaries of such waters, intrastate waters, tributaries of such waters and adjoining shoreline.waters and adjoining shoreline.

Availability of PlansAvailability of Plans

If facility is manned a minimum of 4 hrs./dayIf facility is manned a minimum of 4 hrs./day

Or… the nearest field office for onOr… the nearest field office for on--site review site review during normal working hoursduring normal working hours

Implementation dates*Implementation dates*

SPCC ChangesSPCC ChangesCompliance DatesCompliance Dates

Operation on or beforeAugust 16, 2002

YES NO

(1) Must maintain its plan but must amend it;(2) Implement amended plan on or before

August 17, 2005;(3) Implement the amended plan ASAP,

but no later than February 18, 2006

Operational betweenAugust 16, 2002

and February 18, 2006

OperationalafterFebruary 18, 2006

Prepare plan before February 18, 2006Implement plan ASAP butno later than February 18, 2006

YES

NO

YES

Prepare and Implement planprior to start of operations

SPCC ChangesSPCC Changes

The “660 gallons in a The “660 gallons in a single tank” has been single tank” has been deleted. Now based deleted. Now based on aggregate above on aggregate above ground storage of ground storage of 1,320 gallons or 1,320 gallons or larger.larger.Containers of 55 Containers of 55 gallons or larger are to gallons or larger are to be counted.be counted.

SPCC ChangesSPCC Changes

Completely buried tanks subject to UST Completely buried tanks subject to UST regulations (40 CFR 280 or 281) are no longer regulations (40 CFR 280 or 281) are no longer used to calculate the 42,000 gallon underground used to calculate the 42,000 gallon underground storage threshold.*storage threshold.*

SPCC ChangesSPCC Changes

SPCC Plan Preparation SPCC Plan Preparation –– otherwise exempt otherwise exempt facilitiesfacilitiesAlternative Formats for PlanAlternative Formats for PlanFive Year Review, documentation of review *Five Year Review, documentation of review *Business RecordsBusiness Records“Should to Shall to Must”“Should to Shall to Must”Professional Engineers (PEs)Professional Engineers (PEs)

Additional SPCC ChangesAdditional SPCC Changes

Brittle fracture evaluation*Brittle fracture evaluation*

Employee trainingEmployee training

New format New format –– new sections and subpartsnew sections and subparts

“Plain English”“Plain English”

Are you prepared?Are you prepared?

SPCC at GlanceSPCC at GlanceSubpart “A”Subpart “A”

Sections 112.1 through 112.7Sections 112.1 through 112.7

Subpart “B”Subpart “B”Sections 112.8 through 112.11Sections 112.8 through 112.11

Subpart “C”Subpart “C”Sections 112.12 through 112.15Sections 112.12 through 112.15

Subpart “D”Subpart “D”Sections 112.20 through 112.21Sections 112.20 through 112.21

Appendices “A” Appendices “A” –– “F”“F”

SPCC at GlanceSPCC at GlanceSubpartsSubparts

Subpart ASubpart AApplicability, Definitions, General Applicability, Definitions, General Requirements for all facilities and all types Requirements for all facilities and all types of oilof oil

SPCC at GlanceSPCC at GlanceSubpartsSubparts

Subpart BSubpart BFor petroleum oils and non petroleum oilsFor petroleum oils and non petroleum oils

112.8 112.8 –– Onshore (excluding production)Onshore (excluding production)112.9 112.9 –– Onshore production facilitiesOnshore production facilities112.10 112.10 –– Onshore oil drilling and workOnshore oil drilling and work--over facilitiesover facilities112.11 112.11 –– Offshore oil drilling and workOffshore oil drilling and work--over facilitiesover facilities

SPCC at GlanceSPCC at GlanceSubpartsSubparts

Subpart CSubpart CFor animal fats and oils and greases, and For animal fats and oils and greases, and fish and marine oils and for vegetable oils fish and marine oils and for vegetable oils including oils from seeds, nuts, fruits and including oils from seeds, nuts, fruits and kernels (Section 112.12 through 112.15)kernels (Section 112.12 through 112.15)

SPCC at GlanceSPCC at GlanceSubpartsSubparts

Subpart CSubpart C112.12 112.12 –– Onshore (excluding production)Onshore (excluding production)112.13 112.13 –– Onshore production facilitiesOnshore production facilities112.14 112.14 –– Onshore oil drilling and workOnshore oil drilling and work--over facilitiesover facilities112.15 112.15 –– Offshore oil drilling and workOffshore oil drilling and work--over facilitiesover facilities

SPCC at GlanceSPCC at GlanceSubpartsSubparts

Subpart DSubpart DFor response requirements (Section 112.20 For response requirements (Section 112.20 through 112.21)through 112.21)112.20 112.20 –– Facility response plansFacility response plans112.21 112.21 –– Facility response training and drills / Facility response training and drills / exercisesexercises

Substantial Harm (FRP)Substantial Harm (FRP)

Transfer over water from vessel & have > 42,000 Transfer over water from vessel & have > 42,000 gallon storage capacity gallon storage capacity -- YESYES

Total Storage Capacity > 1 million gallons Total Storage Capacity > 1 million gallons Secondary containment?Secondary containment?Sensitive area?Sensitive area?Nearby public water intake?Nearby public water intake?Reportable spill of 10,000 gallons in last 5 years?Reportable spill of 10,000 gallons in last 5 years?

Substantial Harm (FRP)Substantial Harm (FRP)If yes to any of the above, you need to If yes to any of the above, you need to develop a Federal Response Plan (FRP)develop a Federal Response Plan (FRP)

Preparing an SPCC PlanPreparing an SPCC Plan

Prep for PlanPrep for Plan

Decide what Decide what youyou can docan do

Gather informationGather information

Contact either/or Contact either/or consultant consultant Professional Engineer* Professional Engineer*

A “Working” PlanA “Working” Plan

The PlanThe PlanSection 112.1 Section 112.1

General ApplicabilityGeneral Applicability

Section 112.2Section 112.2DefinitionsDefinitions

Section 112.3Section 112.3Requirement to prepare & implementRequirement to prepare & implement

The PlanThe Plan

Section 112.4Section 112.4Amendment by Regional AdministratorAmendment by Regional Administrator

Section 112.5Section 112.5Amendment by Owners/OperatorsAmendment by Owners/Operators

Section 112.6Section 112.6[Reserved][Reserved]

The PlanThe Plan

Section 112.7 Section 112.7 “The Nuts & “The Nuts & Bolts”Bolts”Required by Required by “all” facilities“all” facilities

The “Nuts & Bolts”The “Nuts & Bolts”COVER PAGE(s)COVER PAGE(s)

Site locationSite location

Original date of plan, date of last plan reviewOriginal date of plan, date of last plan review

Date of last amendment/P.E. certificationDate of last amendment/P.E. certification

Designated facility contact personDesignated facility contact person

P.E. certificationP.E. certification

The “Nuts & Bolts”The “Nuts & Bolts”

COMPLIANCE REVIEW/MANAGEMANT COMPLIANCE REVIEW/MANAGEMANT APPROVALAPPROVAL

Citation of 40 CFR 112.5(b), plan review Citation of 40 CFR 112.5(b), plan review every five years minimumevery five years minimum

Statement of commitment by managementStatement of commitment by management

Signature of management Signature of management

The “Nuts & Bolts”The “Nuts & Bolts”

Required Elements:Required Elements:Operating procedures that prevent oil spills;Operating procedures that prevent oil spills;Control measures installed to prevent spills Control measures installed to prevent spills from reaching navigable waters; and,from reaching navigable waters; and,Countermeasures to contain, clean up, and Countermeasures to contain, clean up, and mitigate spills reaching waterways.mitigate spills reaching waterways.

Each SPCC Plan must be “unique to the Each SPCC Plan must be “unique to the facility.”facility.”

Part 112.7Part 112.7112.7 (a)(3)112.7 (a)(3)

Description of the physical layout and facility diagramDescription of the physical layout and facility diagram

112.7 (a)(3)(vi)112.7 (a)(3)(vi)Contact list & phone numbersContact list & phone numbers►► Facility contacts (facility response coordinators & Facility contacts (facility response coordinators &

backups)backups)►► Agency contacts (Local, State & Federal)Agency contacts (Local, State & Federal)

Part 112.7Part 112.7

112.7 (a)(4)112.7 (a)(4)

Written reporting procedureWritten reporting procedure►► This section spells out reporting This section spells out reporting

requirementsrequirements

Part 112.7Part 112.7

112.7 (b) 112.7 (b)

Predictions of direction, rate & flow, and Predictions of direction, rate & flow, and total quantity of oil that could be total quantity of oil that could be discharged, where experience indicates a discharged, where experience indicates a potential for equipment failure.potential for equipment failure.

Worst Case ScenariosWorst Case ScenariosCan’t use the “But… I’ve never had a spill”Can’t use the “But… I’ve never had a spill”

Part 112.7Part 112.7112.7 (b)112.7 (b)

Table format Table format ►► Tank # Tank # ►► Volume, contentsVolume, contents►► Material of construction Material of construction ►► External protection External protection ►► Level indicators Level indicators ►► Secondary containment Secondary containment ►► Type of failure Type of failure ►► Volume of spill Volume of spill ►► Flow direction Flow direction ►► Flow rateFlow rate

Part 112.7 Part 112.7 112.7 (c)112.7 (c)

Provide appropriate containment and/or Provide appropriate containment and/or diversionary structures or equipment to prevent a diversionary structures or equipment to prevent a discharge discharge

System, System, including walls and floorincluding walls and floor, must be capable , must be capable of containing oil and must be constructed so that of containing oil and must be constructed so that any discharge from a primary containment system, any discharge from a primary containment system, such as a such as a tank or pipetank or pipe, will not escape the , will not escape the containment system before cleanup occurs.containment system before cleanup occurs.

Part 112.7Part 112.7

Part 112.7 (c)Part 112.7 (c)

OnOn--Shore facility minimums:Shore facility minimums:Dikes, berms or retaining wallsDikes, berms or retaining wallsCurbing; culverts, gutters or other drainage systemCurbing; culverts, gutters or other drainage systemWeirs, booms, other barriersWeirs, booms, other barriersSpill diversion ponds, retention pondsSpill diversion ponds, retention pondsSorbent materialsSorbent materials

ContainmentContainment

Part 112.7Part 112.7

Part 112.7 (d)Part 112.7 (d)

Statement of impracticability provided you meet:Statement of impracticability provided you meet:1 1 -- Oil spill contingency plan;Oil spill contingency plan;2 2 –– Written commitment of manpowerWritten commitment of manpower

Part 112.7Part 112.7Part 112.7 (e)Part 112.7 (e)

Inspections, tests, and recordsInspections, tests, and recordsDeveloped by the facility and/or engineerDeveloped by the facility and/or engineerSigned by appropriate supervisorSigned by appropriate supervisorKept with plan for three (3) yearsKept with plan for three (3) yearsInspection records kept under usual and Inspection records kept under usual and customary business practicescustomary business practices

Part 112.7Part 112.7

Part 112.7 (f)Part 112.7 (f)

Personnel training and discharge prevention Personnel training and discharge prevention proceduresprocedures

Train “oil handling” personnel*Train “oil handling” personnel*►►To include: operations; discharge To include: operations; discharge

procedures; pollution control laws, rules procedures; pollution control laws, rules regulations; contents of SPCC Planregulations; contents of SPCC Plan

Part 112.7Part 112.7

Part 112.7 (g)Part 112.7 (g)SecuritySecurity

Fenced*Fenced*Master flow valves controlledMaster flow valves controlledLocked starter controlsLocked starter controlsLighting*Lighting*►► To allow discovery of spill at nightTo allow discovery of spill at night►► Reduces vandalismReduces vandalism

Part 112.7 (g)Part 112.7 (g)

Part 112.7Part 112.7

Part 112.7 (h)Part 112.7 (h)

Facility tank car & tank truck loading/unloading rackFacility tank car & tank truck loading/unloading rackContainment at point of loading/unloadingContainment at point of loading/unloading►► Must contain largest single compartment of truck Must contain largest single compartment of truck

or tank caror tank carWarning system or physical barrier to prevent Warning system or physical barrier to prevent departure before disconnectingdeparture before disconnectingInspection prior to transitInspection prior to transit

Part 112.7 (h)Part 112.7 (h)

Subpart BSubpart B

Part 112.8Part 112.8

For petroleum oils and non petroleum oilsFor petroleum oils and non petroleum oils112.8 112.8 –– Onshore (excluding production)Onshore (excluding production)

Sections Sections –– (a) through (d)(a) through (d)

Part 112.8Part 112.8

Part 112.8 (a)Part 112.8 (a)

Meet the general requirements of Part 112.7Meet the general requirements of Part 112.7

Part 112.8Part 112.8

Part 112.8 (b) Part 112.8 (b) -- Facility drainageFacility drainage

(1) Discharges from diked areas(1) Discharges from diked areas(2) Use of valves on diked areas(2) Use of valves on diked areas(3) Drainage from undiked areas(3) Drainage from undiked areas(4) Alternate drainage systems(4) Alternate drainage systems(5) Multiple “treatment” system transfers(5) Multiple “treatment” system transfers

Part 112.8Part 112.8

Part 112.8 (c) Part 112.8 (c) –– Bulk Storage containersBulk Storage containers

(1) Compatibility(1) Compatibility(2) Secondary containment (defines capacity)(2) Secondary containment (defines capacity)(3) Discharge of dike water and record keeping(3) Discharge of dike water and record keeping(4) UST corrosion protection(4) UST corrosion protection(5) Protection of partially buried tanks(5) Protection of partially buried tanks

Part 112.8Part 112.8

Part 112.8 (c) Part 112.8 (c) –– Bulk Storage containersBulk Storage containers

(6) Integrity testing(6) Integrity testing

►► Gives guidance on frequency, method, Gives guidance on frequency, method, inspections, and record keeping of field inspections, and record keeping of field constructed tanksconstructed tanks

Part 112.8Part 112.8

Part 112.8 (c) Part 112.8 (c) –– Bulk Storage containersBulk Storage containers

(7) Internal heating coils(7) Internal heating coils(8) Alarm systems and their testing(8) Alarm systems and their testing(9) Effluent treatment systems(9) Effluent treatment systems(10) Prompt response to small spills(10) Prompt response to small spills(11) Portable or mobile tank site storage (11) Portable or mobile tank site storage

Part 112.8Part 112.8

Part 112.8 (d) Part 112.8 (d) –– Facility transfer operations, pumping, Facility transfer operations, pumping, and facility processand facility process

(1) Buried piping (1) Buried piping –– protection of underground pipingprotection of underground piping(2) Sealing “not(2) Sealing “not--inin--service” pipingservice” piping(3) Piping supports(3) Piping supports(4) Inspection of piping(4) Inspection of piping(5) Piping “warning signs”(5) Piping “warning signs”

Multiple PlansMultiple Plans

Different substances Different substances stored at a facility couldstored at a facility couldrequire other types ofrequire other types ofplans, such as; OSHAplans, such as; OSHAChemical Process Safety,Chemical Process Safety,Storm WaterStorm WaterManagement Plan,Management Plan,RCRA Hazardous Waste RCRA Hazardous Waste Contingency Plan or aContingency Plan or aRisk Management Plan.Risk Management Plan.

PreventionPrevention

Where Can I Get Help?Where Can I Get Help?USEPA’s Web Page ………..USEPA’s Web Page ………..

www.epa.gov/oilspillwww.epa.gov/oilspill

Ohio EPA Spill Prevention ContactsOhio EPA Spill Prevention ContactsBowling Green (NWDO) Bowling Green (NWDO)

Mike Czeczele 419Mike Czeczele 419--352352--31463146

Twinsburg (NEDO) Twinsburg (NEDO) Bruce Miller 330Bruce Miller 330--963963--12211221

Logan (SEDO)Logan (SEDO)Mark Stello 740Mark Stello 740--385385--85018501

Dayton (SWDO)Dayton (SWDO)Jim Crawford 937Jim Crawford 937--285285--60396039

Columbus (CDO)Columbus (CDO)Chris Bonner 614Chris Bonner 614--728728--38293829

Jim Crawford

937.285.6039

Jim.Crawford@epa.state.oh.us