Spill Prevention, Control and

Countermeasure (SPCC) Training

Goals of SPCC Training

• Overview of the SPCC Requirements

• Summary of Harvard’s SPCC Plan

• Spill Prevention and Response Procedures

• Inspection Requirements

• Roles and Responsibilities

• Information Resources

SPCC Requirements

• Required by EPA if a facility can “reasonably be expected to discharge harmful amounts of oil into navigable waters of the United States or adjoining shorelines”, and stores above a certain volume threshold

• Required at Harvard due to oil storage volume throughout the University and at off-site locations and because oil can reasonably be expected to enter navigable waters

Oil Regulated Under SPCC

• All petroleum based oils – Fuel oil, motor oil, distillate oil, gasoline, hydraulic

fluid

• Oil mixed with wastes

• Animal fats and oils

• Fish and marine mammal oils

• Vegetable oils – Oils from seeds, fruits, nuts and kernels

Containers Regulated Under SPCC

• Any current oil storage container 55 gallons or greater– Bulk Storage - drums, tanks and containers – Operational equipment - transformers,

elevator tanks, electrical switches

• Any empty container 55 gallons or greater capable of storing oil and not rendered unusable

Harvard’s SPCC Plans

• Harvard has five (5) SPCC Plans:– Cambridge/Allston Campuses– Longwood Medical Campus– Southborough Campus– The Arsenal at Watertown– Harvard Forest

• Copies of the Plans are Maintained at:– EHSEM offices at 46 Blackstone Street in

Cambridge– University Operations Center – Security stations at off-site locations

Contents of SPCC Plans

• Identify oil storage and use locations– Tanks (above and underground)– Hydraulic elevator systems– Emergency Generators– Electrical transformers and substations– Electrical switches– Pumps, gear boxes, bearings– Waste Oil Satellite Accumulation Areas– Waste cooking oil containers

• Designate responsibilities for implementation

• Establish spill prevention and response procedures

Roles and Responsibilities

EH&S

Environmental Safety

Compliance Officers

Facility Managers

Contractors/Vendors

Develop SPCC Plan Ensure resource allocation

Update inventory for accuracy

Be familiar with SPCC requirements

Provides SPCC Training and Guidance

Training for Staff Ensure personnel are trained

Provide spill response equipment

Monitor SPCC regulatory changes

Conduct and document inspections

Ensure spill equipment is stocked

Notify the Operations Center of any spills (617-495-5560)

Support spill incident report and follow-up

Coordinate with EH&S on SPCC Requirements

Ensure personnel are familiar with locations of spill equipment

Cleanup spills

Assess human health and environmental hazards and impacts

Maintain training records Assign and monitor monthly inspections

Determine need for regulatory reporting

Maintain facility-specific oil storage/use information and provide updates to EH&S

Ensure contractors are aware of SPCC Reporting requirements

Conduct follow-up Maintain signed copy of Fuel Delivery notice

SPCC Device Inventory

• Harvard facilities are required to keep an accurate and up-to-date inventory of all SPCC devices

• Facilities must review the devices and inventory annually

• EH&S maintains a web-based Facility Equipment Inventory Management System (FEIMS)

http://www.uos.harvard.edu/redir/feims.html

SPCC Training

• Required for any Harvard employee involved in:– Oil handling– Transfer– Storage– Spill response– Maintenance of oil equipment

• Managers or supervisors who have direct reports involved in the activities listed above

• Fuel oil delivery company employees

Spill Prevention

• Routine Inspections– Monthly inspections of SPCC devices– Maintenance and repairs– Reporting all leaks

• Personnel Training– All personnel handling oil must be trained upon hire– Retraining must occur if there are changes to the

Plan• Alarms/Shutoff Valves

– Monitor leak detection and overfill protection systems

– Respond immediately to all alarms– Do not leave monitoring system unsupervised– Perform regular tests on monitoring systems

Spill Prevention

• Continued• Fuel Deliveries– Facility managers should ensure that all fuel

delivery vendors receive the “Notice to Fuel Delivery Vendor”

– Maintain signed “Notice to Fuel Delivery Vendor”

– Must follow Tank Truck Delivery Procedures – Harvard University personnel should be

present and monitor fuel deliveries– Immediately report any leakage or spillage to

Harvard University’s Operations Center at (617) 495-5560

Spill Prevention

• Continued• Secondary Containment– Must be an impervious material and contain a

means of discharge (pipe with valve) that is able to be locked

– Required for oil containing devices by Harvard EH&S

– Transformers, electrical switches and elevator tanks are exempt from this requirement of SPCC

Spill Scenarios

• Potential spills at Harvard include:– Damage to or release from oil delivery

equipment during the loading/unloading of oil at fill stations

– Aboveground or underground tank failure– Leaking or failure of drums or containers– Overfill at a fill port– Spillage during transfer from drums or tanks– Leaking and/or failure of piping and pumps– Leaking transformer

Incidental Spills

• Definition:– Spills of known materials that do not pose

potential safety or health hazards (fire, explosion or chemical exposure)

– Spills that can be controlled and cleaned up at the time of release by employees in the immediate area or by maintenance personnel

– Spills that do NOT impact the environment• Management

– Do not endanger yourself or others– Use proper personal protective equipment

(gloves, goggles, etc.) while cleaning up the spill

– Dispose of the waste properly and in accordance with Harvard’s Hazardous Waste procedures

Non-Incidental Spills

• Definition:– A spill that causes material to reach the

environment through a floor drain, storm drain, or the ground surface

– A major spill or release • Quantity greater than 10 gallons of oil or a product

that cannot be readily absorbed, neutralized, or otherwise controlled at the time of release

– Any quantity of spilled or released material which is unknown to personnel or the potential or actual health and safety hazards are unknown

– An actual or suspected injury has occurred as a result of the spill or release

• Immediately report Non-Incidental Spills to the University Operations Center at (617) 495-5560

Response Procedures

• In the event of a spill:– Isolate area to protect people– Identify the source of the spill– Note the material and quantity spilled– Identify potential hazards– Protect potential receptors (storm drains, sumps, floor

drains and soil)– Clean up incidental spills– Ask facility operations for location of nearest spill kit– Call for help if you are unable to clean the spill

Spill Response Supplies

• Speedi-dry• Sorbent booms and socks• Oil absorption pads• Spill mats for covering storm drains/floor

drains• Protective gloves, suits, safety glasses or

goggles• Caution tape• Shovels/collection drums

Inspections

• Monthly documented inspections are required for:– Aboveground Storage Tanks– Bulk Storage Containers

• Drums – 55 gallons or greater, including kitchen grease drums.

– Underground Storage Tanks which are used for heating on site

• Conduct Best Management Practice inspections on:– Transformers – Hydraulic Elevator Systems and Lifts– Electrical Switches– Grease traps – Oil/Water separators

• Records must be kept on site for 3 years

Tank Testing

• Formal inspections by qualified inspectors and leak testing are required every 10 years for tanks greater than 1,100 gallons

• Integrity testing must be conducted under the following conditions:– Regular schedule or when repairs are made to a

tank– On an interval not greater than 10 years– Testing will be in accordance with general industry

guidelines and by a qualified tank inspector• Records of all testing must be maintained by the tank

owner

Security

• Containers must be located in areas that are accessible only to authorized personnel

• Lighting must be sufficient to enable the discovery of spills during hours of darkness and to prevent spills occurring through acts of vandalism

Common SPCC Violations

• Untrained personnel• Failure to report a spill to the environment• Lack of an adequate SPCC Plan• Inadequate secondary containment• Lack of procedures and

control measures to prevent a spill from reaching the environment

Communications

• Internal:– EH&S will communicate regulatory changes

through the SPCC Management Coordinators• Emergencies:– Immediately contact the University Operations

Center (617) 495-5560

• Go to the next slide for more SPCC resources

Information Resources

• EHSEM web-based Facility Equipment Inventory Management System (FEIMS)– http://www.uos.harvard.edu/redir/feims.html

• Technical Assistance on SPCC Plan– http://www.uos.harvard.edu/ehs/environmental/spc

c.shtml

• Hazardous Waste Procedures– http://www.uos.harvard.edu/ehs/environmental/haz

ardous_waste.shtml

• Harvard Environmental Health Safety and Emergency ManagementvDepartment

• Cambridge (617) 495-2060, Longwood (617) 432-1720

Congratulations

• You have now completed the presentation portion of the SPCC Training

• In order to finish the training take the course quiz

• Then print out your certificate of completion