Spill Prevention Control & Countermeasures (SPCC) and Fuel Management

1. 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

2. 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?

3. 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

4. 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?

5. 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

6. UST Requirements • Corrosion protection • Leak detection for tank and lines • Spill and overfill protection • Records • Closure

7. 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

8. 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

9. 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

10. 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

11. 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

12. 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

13. 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

14. 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”

15. 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

16. 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

17. 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

18. BMPs for Good Fuel Tank Management What are the issues and what can be done to solve them?

19. BMPs for Good Fuel Tank Management

20. BMPs for Good Fuel Tank Management

21. BMPs for Good Fuel Tank Management

22. 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

23. Emily Daigneau PRIZIM Inc. edaigneau@prizim-inc.com 301-840-2222, ext. 148 Questions?