Harvard Medical School

Spill

Prevention

Countermeasures &

Controls

Training

Beth Israel Deaconess Medical Center

Boston, MA

Harvard Medical School

Today’s Outline

• What is SPCC?• Why are we in this training?• Regulatory summary of SPCC Plan• BIDMC Oil Storage• Potential Oil Spill Pathways• Discharge Prevention Measures• Contingency Plan

Harvard Medical School

What is SPCC?• Spill Prevention Control and Countermeasures

• It is the oil pollution prevention regulation (40 CFR 112) promulgated under the authority of the Clean Water Act (33 USC 1251)

• Establishes equipment, methods, and procedures to prevent discharges of oil into or upon waters of the United States

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Goals of SPCC Training• Familiarize employees with the written SPCC Plan• Identify oil storage locations and handling procedures• Identify spill pathways• Familiarize employees with appropriate spill

response procedures and use of responseequipment

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SPCC Training Requirements

• Training must be provided to new hires and at least annually to personnel involved in oil handling or facility maintenance about proper actions to take in the event of a spill

• Training updates must be conducted whenever a significant change has been made to any oilstorage (e.g., new tank installation)

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Who is subject to SPCC?

• Facilities that store, transfer, consume, or otherwise use oil that “due to its location, could reasonably be expected to discharge into or upon waters of the U.S.”

• And, have aggregate above-ground storage capacity > 1,320 gallons

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What is considered “oil”?

• “oil of any kind or in any form, including fats, oils, greases of animal, vegetable, or nut origin; and other oils and greases, including petroleum oil, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with other waste…”

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What are the penalties if I fail to comply?

• Civil administrative penalties up to $11,000 per day

• Judicial civil penalties up to $32,500 per day

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What are the SPCC requirements for BIDMC?

• Must prepare a Spill Prevention Countermeasures and Controls (SPCC) Plan

• The plan must certified by a licensed Professional Engineer (P.E.)

• Reviewed and recertified every 5 years, or if any technical changes are made.

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What is an SPCC Plan?

• The SPCC Plan is the written document that details the equipment, personnel, procedures, and steps to prevent and/or control discharges of oil; and provides the countermeasures to be implemented in the event of a discharge

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Where is the Plan kept?

• A complete copy of the plan must be maintained at the facility– EH&S department Rose 3rd floor (RO 310)

• The plan does not need to be submitted to EPA, but must be available for review during business hours

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SPCC Plan Contents

• Facility Information• Oil Storage Summary• Potential Spill Pathways• Discharge Prevention Measures• Contingency Planning

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BIDMC Facility Information

• Nearest navigable water is Muddy River (1/10 mile away)

• Oil Storage Capacity – 53,359 gallons• Worst Case Discharge – 25,000 gallons

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BIDMC Emergency Response

• Code Orange Emergency Line

In-house Phone: 2-1212

Outside Phone: 617-632-1212

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Facility Contacts

• Rick Marini – Dir. Maint. Operations

617-667-4453 pager - #31027• Gary Schweon – Dir. EH&S

617-667-5107 pager - #39118

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BIDMC Oil Storage

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BIDMC Oil Storage

Farr Building

6,000-gallon #2 fuel oil UST

75-gallon day tank on roof

50-gallon day tank in sub-basement

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BIDMC Oil Storage

Farr Building (continued)

55-gallon coolant drums (2) in sub-basement

55-gallon coolant tank on 12th floor

220-gallon coolant supply area 12th floor

95-gallon AST for elevator hyd. fluid

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BIDMC Oil Storage

Lowry Medical Office Building

275-gallon #2 fuel oil AST

330-gallon #2 fuel oil AST

30-gallon day tank

55-gallon coolant drums (2) in basement

55-gallon coolant drums (4) on 10th floor

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BIDMC Oil Storage

Clinical Center – West

8,000-gallon #2 fuel oil UST

75-gallon day tanks (2) on 8th floor

187-gallon ASTs (2) for elevator hydraulic fluid

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BIDMC Oil Storage

Deaconess Building

415-gallon AST for elevator hyd. fluid

55-gallon waste oil drums (2)

21-27 Burlington Avenue

no longer leasing facilities

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BIDMC Oil Storage

Shapiro Building

3,000-gallon #2 fuel oil AST

100-gallon day tank on 10th floor

55-gallon waste oil drum in grounds shed

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BIDMC Oil Storage

Feldberg Building

145-gallon AST for elevator hyd. fluid.

Finard Building

6,000-gallon #2 fuel oil UST

205-gallon day tank in basement

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BIDMC Oil Storage

Stoneman Building

25,000 gallon emergency gen UST

3-200 gallon ASTs with 3 emergency generators (Reisman Roof)

Rose Building

55-gallon coolant drums in meter room (4)

600-gallon AST for kitchen grease in basement

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BIDMC Oil Storage

Research North

450-gallon #2 fuel oil AST

75-gallon day tank in penthouse

145-gallon ASTs (2) for elevator hyd. fluid.

55-gallon coolant drums (4) in penthouse

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Potential Spill Pathways

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Potential Spill Pathways

Farr Building UST: Overfills during delivery could flow out to the riverway.

Farr Building Emergency Generators: Spill on the roof could enter roof drain.

Clinical Center West UST: Overfills during delivery could enter Muddy River.

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Potential Spill Pathways

Finard Building UST: Overfill during delivery could enter storm drains or Muddy River.

Stoneman Building: Piping or day tank failure could enter catch basin (entire contents of UST could be emptied into day tank if level controls fail and go to roof drain and catch basin 25,000 gal).

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Discharge Prevention Measures

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Facility Drainage Control

• Surface drain covers used during fuel oil deliveries

• Floor drains discharge to sanitary sewer

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Bulk Container Management

• Containers compatible with contents• Secondary containment provided • Corrosion protection for USTs• Integrity testing for ASTs• High-level alarms on all tanks

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Facility Transfer Operations

• Transfer piping protected against corrosion and vehicular damage

• Out-of-service lines blank-flanged and locked• Piping regularly inspected for leaks

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Tanker Unloading Procedures

• All deliveries are attended• Spill response kits are nearby• Surface drains covered/locked• Tanks have overfill protection• Tanker inspected for leakage before leaving

facility

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Inspections and Records

• Tanks and piping inspected by Maintenance• Tanks integrity tested every ten years• Spill response equipment inspected quarterly• Secondary containment inspected monthly• Records kept for five years

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Site Security

• Fencing; flow valves locked; starter controls locked; pipeline connections securely capped

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Training

• New hires and annually as appropriate

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Contingency Planning

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Contingency Planning

• Identification of Sensitive Areas• Spill Response Equipment• Emergency Coordinator Duties• Emergency Assessment• Notifications• Post-Emergency Actions

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BIDMC Sensitive Areas

• The “Muddy River”

Endangered Species Habitat

Recreational Use (boating)

Wetlands Resources

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Spill Response Priorities

• Respond to injuries• Protect self and others• Secure the source• Make required notifications• Contain spilled material• Protect the environment• Conduct clean-up activities

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Notifications - Internal

• Contact your supervisor• Contact Code Orange Emergency Line

@ 2-1212

whenever there is a spill, or threat of a spill, fire, or explosion involving oil (or other hazardous material)

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Situation Assessment

• Type of situation (spill, fire, etc.)• Material involved• Location• Potential hazard to personnel or environment• Corrective action needed

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Small Spill Response

• Small < 55 gallons• Extinguish ignition sources• Isolate the area• Contain and absorb spilled material• Transfer spent sorbent to a drum• Clean the area of residue• Properly dispose of spilled material

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Large Spill Response

• Large spills > 55 gallons• Extinguish ignition sources• Contain spilled material to the extent practical• Stop the source of the leak (if safe to do so)• Summon external resources

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Spill Response Equipment

• Absorbents, Pigs, Booms• Shovels, brooms, empty steel drums• PPE (gloves, goggles, boots)• Cleaner and/or degreaser

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Emergency Coordinator Duties

• Assess the situation• Make notifications, external if needed• Direct small spill response actions• Request Contractor assistance for large spills• Conduct post-emergency actions

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Notifications - External

• for releases to soil > ten gallons• for releases to water that cause a sheen

The designated Emergency Coordinators will contact:

MA DEP (617)556-1133US EPA (617)223-7265

National Response Center (888)304-1133

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Post Emergency Actions

• Ensure notifications have been made• Identify cause of emergency• Implement corrective actions to prevent

recurrence• Evaluate emergency response• Evaluate effectiveness of SPCC Plan

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Recap

• What is SPCC?• Why are we in this training?• Regulatory summary of SPCC Plan• BIDMC Oil Storage• Potential Oil Spill Pathways• Discharge Prevention Measures• Contingency Plan