SPCC:  What You and Your Employees Should Know
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SPCC: What You and Your Employees Should Know ARIPPA Pottsville, PA February 27, 2007 PowerPoint PPT Presentation


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SPCC: What You and Your Employees Should Know ARIPPA Pottsville, PA February 27, 2007. Presented by Jenna Glahn and Carole Hamner. About Trinity Consultants. Trinity Consultants is an environmental consulting company headquartered in Dallas, Texas

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SPCC: What You and Your Employees Should Know ARIPPA Pottsville, PA February 27, 2007

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Spcc what you and your employees should know arippa pottsville pa february 27 2007

SPCC: What You and Your Employees Should Know

ARIPPA

Pottsville, PA

February 27, 2007

Presented by Jenna Glahn and Carole Hamner


About trinity consultants

About Trinity Consultants

  • Trinity Consultants is an environmental consulting company headquartered in Dallas, Texas

  • Offer environmental consulting, environmental data management, BREEZE environmental modeling software, professional education services

  • 250+ employees at 20 offices across major markets of U.S.


Spcc what you and your employees should know arippa pottsville pa february 27 2007

www.trinityconsultants.com


Spcc compliance presentation topics

SPCC CompliancePresentation Topics


Presentation topics

Presentation Topics

  • Spill Prevention Requirements

    • Federal SPCC Requirements

      • SPCC Plan Requirements

    • PADEP Spill Requirements

      • SPR Plan Requirements

      • Storage tank requirements

    • PADEP PPC Requirements


Spcc compliance in pennsylvania

SPCC Compliance In Pennsylvania

Jenna Glahn

February 27, 2007

trinityconsultants.com


What is spcc

What is SPCC?

  • Spill Prevention, Countermeasure, and Control (SPCC) Rule found under 40 CFR 112

    • Prevent environmental contamination

      • Specifically, of navigable waters of the United States or adjoining shorelines

    • Define actions taken to stop or control leaks

    • Describe clean up after leaks and steps to prevent reoccurrence


Who is subject

Who is Subject?

  • SPCC Plans required for facilities with:

    • Aboveground storage capacity of oil > 1,320 gallons (count 55 gallons drums and bigger)

    • Non-transportation related

    • Reasonable expectation of discharge into navigable waters or shorelines

      • Streams, ponds, ditches, sewers, wetlands, etc.


Federal spcc requirements

Federal SPCC Requirements


Spill prevention control and countermeasures spcc

Spill Prevention Control and Countermeasures (SPCC)

  • Oil Pollution Prevention (Jan. 1974)

  • Oil Pollution Act of 1990 (OPA 90)

  • EPA proposed revisions in 1992, 1997, and 2002


Summary of changes

AST > 660 gallons in single tank, 1,320 gallons total

UST > 42,000 gallons

Ambiguous concerning “use” and ‘facility’

AST > 1,320 gallons (containers > 55 gallons)

Don’t count USTs complying with

40 CFR 280-281

Includes “use”, defines “facility”

Summary of Changes

Previous Rule

Revised Rule


Summary of changes cont d

Current and new facilities: 6 mo prep, 6 mo to implement

P.E. certifies GEP, all plan amendments

New facilities: prepare/implement prior to operations

PE certifies plan meets 112, technical amendments only (<10K gal may self-certify)

Summary of Changes (cont’d)

Previous Rule

Revised Rule


Summary of changes cont d1

Revise with a 1,000 spill or 2 reportable spills in 12 mos.

Review every 3 years

Plan must follow sequence in 112.7

Inspection records part of plan

2 Spills > 42 gallons

Review every 5 years

Deviations allowed

Operations log okay

Summary of Changes (cont’d)

Previous Rule

Revised Rule


Summary of changes cont d2

Visual inspection of tank sufficient for integrity testing

No testing after field repairs

Cathodic protection for buried piping required if warranted by soil conditions

Must use visual plus another technique (hydrostatic, radiographic)

Mandates testing after field repairs

Buried piping replaced after August 6, 2002 must have cathodic protection

Summary of Changes (cont’d)

Previous Rule

Revised Rule


Summary of changes cont d3

Required personnel training

Required records of storm water bypass

For petroleum and petroleum products only

Mandates training for oil-handling employees

NPDES records okay

Adds Animal Fats, Vegetable Oils

Summary of Changes (cont’d)

Previous Rule

Revised Rule


Spcc plan requirements

SPCC Plan Requirements

  • Facility description and diagram showing storage locations/content

  • Predict direction, flow and quantity discharged

  • Follow rule sequence or provide cross-reference

  • Spill history

  • Tank and drum inventory

  • Containment/diversionary structures

  • List emergency equipment


Spcc plan requirements1

SPCC Plan Requirements

  • Contact list and phone numbers

    • Facility Response Coordinator, National Response Center (1-800-424-8802), Cleanup Contractors, and all appropriate Federal, State, and local agencies

  • Provide a contingency plan to enable a person to properly stop and contain a spill and/or report a discharge


Spcc what you and your employees should know arippa pottsville pa february 27 2007

SPCC Plan Requirements

  • Facility operating and loading/unloading procedures

  • Inspection plans

  • Site security (fencing, lights, locks)

  • Training and recordkeeping procedures

  • Management approval

  • P.E. certification

  • Substantial Harm certification


Containment training

Containment / Training

  • Provide containment adequate to contain oil for cleanup

    • Dikes, berms, curbs, culverts, retention ponds, diversion ponds, sorbent materials

  • Annual discharge prevention training for all oil handling personnel

    • Operation and maintenance of equipment to prevent discharges; discharge procedure protocols; applicable pollution control laws, and the content of the facility’s SPCC Plan


Pe certification

PE Certification

  • PE Must Attest That:

    1) Familiar with SPCC requirements

    2) He or his agent visited and examined the facility

    3) Plan prepared in accordance with GEP

    4) Procedures for inspections and testing have been established

    5) Plan is adequate for facility


Substantial harm certification

Substantial Harm Certification

  • Reasonably expected to cause substantial harm to the environment

    • Transfer oil over water to/from vessels with total storage capacity > 42,000 gal.

    • Total oil storage capacity > 1 million gal.

  • Meet either criteria, prepare and submit a Facility Response Plan (FRP) or include certification of non-applicability in SPCC Plan


Oil spill notifications 40 cfr 112 4

Oil Spill Notifications (40 CFR 112.4)

  • Discharge > 1,000 gal. in a single event or > 42 U.S. gallons of oil in 2 events

    • Notice to PADEP and EPA w/in 60 days

      • Name, location, and description of facility

      • Max. storage capacity of facility

      • Corrective actions and countermeasures

      • Cause of discharge


Other notifications

Other Notifications

  • Immediately contact NRC if harmful quantities of oil are released

    • Violate water standards,

    • Cause a film, sheen, or discoloration of water surface, or

    • Cause a sludge or emulsion to be deposited beneath water surface


Current status

Current Status

  • Facilities now have until October 31, 2007 to update and implement their plans in accordance with the new rules (2/17/06 Federal Register Notice, 71 FR 8462)

    • Proposal to delay until July 1, 2009

  • New facilities must have plans before operations


Pennsylvania spill requirements

Pennsylvania Spill Requirements


Pa storage tank and spill prevention act 1989

PA Storage Tank and Spill Prevention Act (1989)

  • Developed and implemented

    • Tank regulations

    • Tank registration/annual fees

    • Certification of tank handling

    • Inspections

    • Procedures for reporting of releases and corrective action by tank owners

  • Established technical and operational standards for tank systems


Padep rules

PADEP Rules

  • Pennsylvania’s Storage Tank and Spill Prevention Program (Title 25, Chapter 245)

  • Regulated substances include: petroleum AND hazardous substances (defined in CERCLA or EPCRA)

  • Register and pay annual fees for ASTs > 250 gallons (some exceptions)


Pa specific requirements 1 of 4

PA Specific Requirements (1 of 4)

  • Facility with total aboveground storage capacity > 21,000 gallons subject to Spill Prevention Response (SPR)

    • Requires annual downstream notifications (20 miles), input by emergency planning committee, and approval by the PADEP

  • Chapter 245, Subchapter F describes technical standards for ASTs

  • Chapter 245, Subchapter G describes a simplified program for small ASTs (<21K gal)


Pa specific requirements 2 of 4

PA Specific Requirements (2 of 4)

  • Visual inspection every 72 hours

    • No potential hazardous environmental conditions exist

    • Containment area for water accumulation

  • Monthly maintenance inspection

    • Inspection of the tank system exterior surfaces for deterioration and maintenance deficiencies

    • Keep monthly inspection report for 1 yr

  • In-Service inspection

    • Frequency – w/in ¼ of the corrosion rate life or 5 yrs from the previous inspection or installation


Pa specific requirements 3 of 4

PA Specific Requirements (3 of 4)

  • Provide secondary containment under the tank bottom and around underground piping

    • Permeability < 1x10-7 cm/sec at anticipated hydrostatic head, verified at the time of installation

  • Provide ASTs emergency containment

    • Permeability < 1 x 10-6 cm/sec at anticipated hydrostatic head, sufficient thickness to prevent released substance from penetrating containment structure for 72 hours

    • Contain 110% of the capacity of the largest tank


Pa specific requirements 4 of 4

PA Specific Requirements (4 of 4)

  • Transfers may not exceed the volume available in the receiving tank

    • Transfers must be monitored by designated personnel

    • Gauge or monitoring device with high level alarm

  • Labels consistent with industry standards

  • Written operations and maintenance plan

    • Preventative maintenance and housekeeping program


Simplified program for small tanks

Simplified Program for Small Tanks

  • Tanks < 21,000 gallons

    • Monthly maintenance and operations inspections (inc. method of leak detection)

    • Upgraded with secondary containment by 10/11/2007 (emergency containment by 2000)

  • Tanks > 5,000 gal or >1,100 gal storing highly hazardous substance

    • In-service inspections – every 10 yrs or at ¼ of the corrosion rate life


Recordkeeping

Recordkeeping

  • Permanent records maintain for operational life of tank (+ 1 yr after removal)

    • Original tank system installation and modification records and design specs (+ manufacturer docs)

    • Permits issued

    • Notices of reportable releases

    • Third-party inspection reports

  • Temporary records (12 months)

    • Current registration certificates

    • Leak detection and routine maintenance records

    • In-service inspections


Spill or leak response chapter 245 subchapter d

Spill or Leak Response Chapter 245, Subchapter D

  • Complete an investigation of suspected releases as soon as possible; no later than 7 days after an indication of a release

  • If a release is detected:

    • Immediately contact a supervisor

    • Take action to stop and contain the spill

    • Immediately contact the Oil Spill Coordinator

    • Immediately initiate interim remedial actions necessary to prevent or address an immediate threat to human health or the environment


Reportable release 1 of 2

Reportable Release (1 of 2)

  • Quantity or unknown quantity of regulated substance released to or posing an immediate threat to surface water, groundwater, bedrock, soil, or sediment

  • Does not include: 1) release to interstitial space of a double walled tank, or 2) petroleum release to an aboveground surface < 25 gal

    • Must be completely contained and recovered/removed within 24 hours


Reportable release 2 of 2

Reportable Release (2 of 2)

  • Immediately report to NRC and state or local emergency planning committee, if hazardous substance or EHS released in quantities greater than or equal to its RQ

  • Also, immediately report to PADEP if:

    • > 10 gallons (or less if RQ is less): Hazardous waste liquids or liquids that become hazardous waste when spilled or discharged

    • > 500 pounds (or less if RQ is less): Solid hazardous waste or solids that become hazardous wastes when spilled or discharged

    • Any discharge (regardless of size) or spill of hazardous waste into waters of PA

  • Immediately notify DEP at (800) 541-2050


Reporting requirements

Reporting Requirements

  • Provide written notice w/in 15 days to PADEP and each affected municipality

  • Prepare and submit two copies of site characterization report to PADEP w/in 180 days of reporting release

  • If remedial actions have not remediated the site, prepare and submit remedial action plan w/in 45 days of submitting site characterization


Pennsylvania ppc requirements

Pennsylvania PPC Requirements


Ppc plan

PPC Plan

  • Develop/implement a Preparedness, Prevention, and Contingency (PPC) Plan (25 Pa Code 91.34)

    • Specifically requested as a condition of renewed NPDES permits

    • Identify potential sources of pollution expected to affect stormwater quality

    • See “Guidelines for the Development and Implementation of Environmental Emergency Response Plans”

      • Consider combining plans


Speaker contact information

Speaker Contact Information

Jenna Glahn

Senior Consultant

[email protected]

Phone: (215) 230-3519


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