Spill Prevention Control & Countermeasures (SPCC) and Fuel Management Presented by Emily Daigneau, PRIZIM Inc., at the CSHEMA-PRIZIM Regional EH&S Seminar November 1, 2007, at University of Colorado Boulder
Agenda • Why talk about fuel tanks? • What are the requirements of managing fuel tanks? • What are the requirements of an SPCC Plan? • What are some Best Management Practices (BMPs) for fuel management?
Why Fuel Storage? • Complex management requirements • Potential for significant harm – probably most significant spill risk • Potential for clean-up costs and long term liability associated with contamination • A major budget item • Negative publicity
What are the Risks of Tanks? • Leaking or deteriorating tanks • Leaking or deteriorating pipes • Problems with fuel dispensers • Problems in fuel transit • Problems unloading fuel What are you already doing to address these impacts? How could these efforts be improved?
How is Fuel Tank Management Regulated? • Underground Storage Tanks (USTs) are regulated under EPA’s 40 CFR 280 and 281 • Aboveground Storage Tanks (ASTs) may be regulated by National Fire Protection Association (NFPA) codes, International Fire Code (IFC), as well as state or local regulations • Spills from tanks are regulated under EPA’s 40 CFR 112
UST Requirements • Corrosion protection • Leak detection for tank and lines • Spill and overfill protection • Records • Closure
AST Requirements AST codes depend on local and state requirements. Some basics: • Collision protection (bollards) • Proper venting • Fencing or other security system • Overfill alarm and automatic fuel flow shut-off Additional requirements exist for facilities supporting fueling operations over water
SPCC Plan Requirements Which facilities are required to have an SPCC Plan? • Facilities that use or store oil (i.e., petroleum, fuel oil, animal oil, grease, hydraulic oil, vegetable oil) • Non-transportation related facilities (this means you!) • Potential to discharge into navigable waters
SPCC Plan Requirements What are the quantity thresholds that trigger SPCC Plan Requirements? • Aboveground capacity of more than 1,320 gallons • Containers that are 55 gal or larger get included OR • Underground capacity of more than 42,000 gallons • Tanks covered under 40 CFR 280 or 281 (EPA UST regulations) are excluded
SPCC Plan Requirements • SPCC Plan Sections: • Facility diagram • Oil spill predictions • Facility drainage • Facility inspections • Site security • Appropriate secondary containment or diversionary structures • Significant harm determination
SPCC Plan Requirements • SPCC Plan Sections (continued) • Loading/unloading requirements and procedures for tank car and tank trucks • Personnel training and oil discharge prevention briefings • Brittle fracture evaluations • Bulk storage container compliance • Transfer procedures and equipment (including piping) • Review every 5 years • Professional Engineer certification
SPCC Regulation Update • SPCC 2002 revised rule amendments must be implemented by October 31, 2007 • Removes 660 gal container threshold • Exempts containers smaller than 55 gal • Exempts tanks already covered by 40 CFR 280 or 281
SPCC Regulation Update EPA finalized to additional rules effective February 26, 2007. • Facilities with less than 10,000 gal capacity and no reportable spills for 10 years can self-certify SPCC Plan • Eliminate determination of impracticability requirement for secondary containment of oil-filled operational equipment for facilities with no reportable spills in last 10 years
Proposed Rules to SPCC Plan Regulations October 2007 Proposed Amendments: • Exemptions for certain equipment • Clarity on the general secondary containment requirements • Flexibility in the security requirements • Flexibility in the use of industry standards to comply with integrity testing requirements • Additional flexibility in meeting the facility diagram requirements • Clarification on the flexibility provided by the definition of “facility”
Proposed Rules to SPCC Plan Regulations • To view the proposed rules, visit: www.epa.gov/oilspill/pdfs/fr101507.pdf • Comments can be submitted online at www.regulations.gov • Enter docket ID Number EPA-HQ-OPA-2007-0584 Comments due December 14, 2007
Energy Policy Act of 2005 • Subtitle B a.k.a. Underground Storage Tank Compliance Act (USTCA) • More frequent state inspections (at least once every three years) • Certification for UST operators • Illegal fuel deliveries for noncompliant tanks • Secondary containment for tanks 1,000 ft from water system or water well
What Should Campuses Do? • Ensure all tanks, piping, and fuel dispensers are up to code • EPA requirements (USTs) • Fire protection and engineering requirements (ASTs) • Ensure each tank has a method of release detection • Ensure third party testing • Ensure proper UST/AST fuel system maintenance • Ensure SPCC Plan or equivalent is in place • Monitor all fuel deliveries
BMPs for Good Fuel Tank Management What are the issues and what can be done to solve them?
Where to Find Additional Info? • SPCC Plan Guidance for Regional Inspectors www.epa.gov/oilspill/guidance.htm • EPA information on SPCC Plan Requirements www.epa.gov/oilspill/spccrule.htm • NEW proposed rule www.epa.gov/oilspill/index.htm • Must for USTs www.epa.gov/OUST/pubs/ommanual.htm • Straight Talk on Tanks www.epa.gov/OUST/pubs/straight.htm • Where you Live www.epa.gov/epahome/state.htm
Emily Daigneau PRIZIM Inc. email@example.com 301-840-2222, ext. 148 Questions?