inspection, evaluation, and · pdf fileinspection, evaluation and testing ... apsa/spcc plan...

Section 6Section 6

Inspection, Evaluation Inspection, Evaluation and Testingand Testing

(as applicable to APSA tank (as applicable to APSA tank facilities)facilities)

APSA/SPCC Plan Compliance PrimerAPSA/SPCC Plan Compliance Primer Slide Slide 169169

Inspections and Testing SummaryInspections and Testing SummaryTwo primary requirements for inspecting and testing, Two primary requirements for inspecting and testing, and associated recordkeepingand associated recordkeeping

1.1. Applicable to all SPCC regulated facilities Applicable to all SPCC regulated facilities (40 CFR (40 CFR 112.7(e))112.7(e))::

•• Conduct inspections and tests required by 40 CFR Conduct inspections and tests required by 40 CFR 112 in accordance with written procedures 112 in accordance with written procedures developed for the facility by the owner/operator or developed for the facility by the owner/operator or the certifying engineerthe certifying engineer

Generic: Does not specify any particular standard, but Generic: Does not specify any particular standard, but references any testing/inspecting required by the rulereferences any testing/inspecting required by the ruleMandates written procedures for those tests/inspectionsMandates written procedures for those tests/inspections

•• The written procedures and a record of the The written procedures and a record of the inspections and tests must be kept for 3 yrs inspections and tests must be kept for 3 yrs

Records must be signed by the supervisor or inspectorRecords must be signed by the supervisor or inspectorUsual and customary business recordkeeping practices is OKUsual and customary business recordkeeping practices is OK


Inspections and Testing SummaryInspections and Testing SummaryApplicable to all SPCC regulated facilities Applicable to all SPCC regulated facilities (40 CFR 112.7(e))(40 CFR 112.7(e))::•• Examples of inspections and tests required by 40 CFR 112Examples of inspections and tests required by 40 CFR 112

Test or inspect each aboveground container for integrity on a Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs regular schedule and whenever you make material repairs 112.7(c)(6) 112.7(c)(6) Prior to filling and departure of any tank car or tank truck, Prior to filling and departure of any tank car or tank truck, closely inspect for discharges the lowermost drain and all closely inspect for discharges the lowermost drain and all outlets of such vehiclesoutlets of such vehicles…… 112.7(h)(3) 112.7(h)(3) Regularly test (overfill prevention) liquid level sensing Regularly test (overfill prevention) liquid level sensing devices to ensure proper operation devices to ensure proper operation 112.7(c)(8)(v) 112.7(c)(8)(v) Inspect the condition of the accumulation (in dikes) before Inspect the condition of the accumulation (in dikes) before starting, to ensure no oil will be discharged starting, to ensure no oil will be discharged 112.8(b)(1) 112.8(b)(1) Inspect and may drain uncontaminated retained stormwater Inspect and may drain uncontaminated retained stormwater 112.8(b)(2) 112.8(b)(2) Observe effluent treatment facilities frequently enough to Observe effluent treatment facilities frequently enough to detect possible system upsets that could cause a harmful detect possible system upsets that could cause a harmful navigable water discharge navigable water discharge 112.8(c)(9)112.8(c)(9)Regularly inspect all aboveground valves, piping, and Regularly inspect all aboveground valves, piping, and appurtenances appurtenances 112.8(d)(4) 112.8(d)(4)


Inspections and Testing SummaryInspections and Testing SummaryTwo primary requirements for inspecting and testing, and associaTwo primary requirements for inspecting and testing, and associated recordkeepingted recordkeeping

2.2. Applicable to onApplicable to on--shore facilities shore facilities (40 CFR (40 CFR 112.8(c)(6)):112.8(c)(6)):

This would include all APSA tank facilitiesThis would include all APSA tank facilities

•• Test or inspect each aboveground container for integrity on a Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs regular schedule and whenever you make material repairs

•• Must determine, in accordance with industry standards:Must determine, in accordance with industry standards:The appropriate qualifications for personnel performing The appropriate qualifications for personnel performing tests and inspections tests and inspections The frequency and type of testing and inspections, which The frequency and type of testing and inspections, which take into account container size, configuration, and designtake into account container size, configuration, and design

•• Examples of integrity tests include: visual inspection, Examples of integrity tests include: visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other systems of nonacoustic emissions testing, or other systems of non--destructive testingdestructive testing

•• Need to specify the above for each tank or group of tanks in Need to specify the above for each tank or group of tanks in the Planthe Plan


Inspections and Testing SummaryInspections and Testing SummaryTwo primary requirements for inspecting and testing, and associaTwo primary requirements for inspecting and testing, and associated ted recordkeepingrecordkeeping

2.2. Applicable to onApplicable to on--shore (and all APSA) facilities shore (and all APSA) facilities (continued):(continued):

•• Must keep comparison recordsMust keep comparison recordsMay need to keep for more than 3 yearsMay need to keep for more than 3 years

NOT the approved NOT the approved recordkeeping methodrecordkeeping method

•• Must also inspect the Must also inspect the container's supports and container's supports and foundationsfoundations

•• Must frequently inspect the Must frequently inspect the outside of the container for outside of the container for signs of deterioration, signs of deterioration, discharges, or accumulation of discharges, or accumulation of oil inside diked areasoil inside diked areas

•• Records of inspections and Records of inspections and tests kept under usual and tests kept under usual and customary business practices customary business practices are OKare OK


Inspections and Testing SummaryInspections and Testing Summary

The inspection and testing program and The inspection and testing program and procedures must be written/described in the procedures must be written/described in the Plan:Plan:

•• For Tier I qualified facilities, Table GFor Tier I qualified facilities, Table G--5 in the Template must 5 in the Template must be completedbe completed

The specific industry standards used must be The specific industry standards used must be referenced referenced •• Plans can still include Plans can still include ‘‘environmentally equivalentenvironmentally equivalent’’ measures measures

if determined/approved/certified by a PE if determined/approved/certified by a PE

Scope, frequency and methods of inspections or Scope, frequency and methods of inspections or testingtesting

Personnel to carry out the inspections/testing and Personnel to carry out the inspections/testing and the qualifications required of themthe qualifications required of them


Periodic, Scheduled Inspections & Periodic, Scheduled Inspections & Integrity TestingIntegrity Testing

Intended to prevent, predict, and detect discharges Intended to prevent, predict, and detect discharges

Somewhat flexible, but must be in accordance with Somewhat flexible, but must be in accordance with industry standardsindustry standards

•• SoSo…… unless an environmental equivalence determination is made unless an environmental equivalence determination is made –– there is a limit to this flexibility there is a limit to this flexibility

Type, scope & frequency of inspections depend on tank or containType, scope & frequency of inspections depend on tank or container er type, containment configuration, and industry reference standardtype, containment configuration, and industry reference standardselected or consideredselected or considered

Could range from periodic visual inspections by facility personnCould range from periodic visual inspections by facility personnel to el to detailed internal and external physical testing (e.g. radiographdetailed internal and external physical testing (e.g. radiographic or ic or ultrasonic plus tank entry) by certified/qualified outside speciultrasonic plus tank entry) by certified/qualified outside specialistsalists

•• Visual inspectionsVisual inspections--only are often all that would be requiredonly are often all that would be required

Performed on a Performed on a ‘‘regular scheduleregular schedule’’, as well as , as well as whenever material repairs are madewhenever material repairs are made


Frequent Visual InspectionFrequent Visual Inspection(40 CFR 112.8(c)(6))(40 CFR 112.8(c)(6))

Applies to:Applies to:Bulk storage containers & tanks, Bulk storage containers & tanks, oiloil--filled equipment, associated filled equipment, associated piping, valves, appurtenances, etc., piping, valves, appurtenances, etc., and other components that could and other components that could be a source or cause of an oil be a source or cause of an oil releaserelease•• Bulk storage tanks and containers Bulk storage tanks and containers

Includes mobile/portable tanks, Includes mobile/portable tanks, containers, drums, totes, noncontainers, drums, totes, non--transportation related tanker truckstransportation related tanker trucks

Piping connected to these tanks Piping connected to these tanks and containersand containers


Intended to be a routine (though sufficiently detailed) Intended to be a routine (though sufficiently detailed) walkwalk--around by the owner/operatoraround by the owner/operator…… typically conducted typically conducted by properly trained facility personnelby properly trained facility personnel

Can be used to meet certain industry standard integrity Can be used to meet certain industry standard integrity testing requirements (e.g. STI SP001) testing requirements (e.g. STI SP001)

Must occur frequently to detect signs of deterioration, Must occur frequently to detect signs of deterioration, discharges, or accumulations of oil inside diked areasdischarges, or accumulations of oil inside diked areasRecords for integrity tests and frequent visual inspections Records for integrity tests and frequent visual inspections ––usual and customary business practices will sufficeusual and customary business practices will suffice

Retain for at least 3 years, thoughRetain for at least 3 years, thoughMust be signed by inspector or supervisorMust be signed by inspector or supervisorTemplate contains a (cruddy) log and schedule form in Template contains a (cruddy) log and schedule form in Attachment 3.1 (Table GAttachment 3.1 (Table G--16)16)

Frequent Visual InspectionFrequent Visual Inspection(40 CFR 112.8(c)(6))(40 CFR 112.8(c)(6))


InspectionsInspectionsDescription must be Description must be consistent with practiceconsistent with practice

Forms and details must Forms and details must match, toomatch, tooMust now reference and be Must now reference and be consistent with the relevant consistent with the relevant industry standardindustry standard


InspectionsInspections…… examplesexamples


Field Conditions Consistent with Field Conditions Consistent with Inspections?Inspections?

APSA/SPCC Plan Compliance PrimerAPSA/SPCC Plan Compliance Primer Slide Slide 185185Regularly Scheduled Regularly Scheduled Inspections/Testing at Tier I Inspections/Testing at Tier I Qualified FacilitiesQualified Facilities

Must either use the Must either use the EPA SPCC Plan EPA SPCC Plan Template or fully Template or fully comply with the comply with the ‘‘regularregular’’ integrity integrity testing requirements testing requirements of 40 CFR of 40 CFR 112.8(c)(6) 112.8(c)(6)

Template requirements Template requirements based on 112.8(c)(6) and based on 112.8(c)(6) and STI SPSTI SP--001 4001 4thth Ed.Ed.


More Inspection More Inspection ExamplesExamples


InspectionsInspections


DonDon’’t forget tank t forget tank supports and supports and foundations!foundations!


Regularly Scheduled Integrity TestingRegularly Scheduled Integrity Testing

Applies to:Applies to:•• NonNon--qualified and Tier II qualified facilitiesqualified and Tier II qualified facilities

Large (fieldLarge (field--constructed or fieldconstructed or field--erected) erected) aboveground storage containersaboveground storage containersMedium (shop built, fieldMedium (shop built, field--erected or combo) erected or combo) aboveground storage containersaboveground storage containersSmall (shopSmall (shop--built) aboveground bulk storage built) aboveground bulk storage containerscontainersAboveground bulk storage containers on, partially Aboveground bulk storage containers on, partially in (partially buried, bunkered, or vaulted tanks) in (partially buried, bunkered, or vaulted tanks) and off the ground wherever located and off the ground wherever located Aboveground bulk storage containers storing any Aboveground bulk storage containers storing any type of oiltype of oil•• Examples: mobile/portable containers, drums, totesExamples: mobile/portable containers, drums, totes


Facility Component(s) Covered in Facility Component(s) Covered in Standard or Recommended Practice Standard or Recommended Practice

API API 653653

STI STI SP001SP001

API API 570570

API API RP* RP* 575575

API API RP* RP* 574574

API API 12R112R1

API API 11101110

ASME ASME B31.3B31.3

ASME ASME B31.4B31.4

New equipmentNew equipment UU UU UU UU

Equipment that has been in serviceEquipment that has been in service UU UU UU UU UU UU UU UU

ShopShop--built ASTbuilt AST UU UU UU UU

FieldField--erected ASTerected AST UU UU UU UU

Plastic tanksPlastic tanks UU

Container supports or foundationContainer supports or foundation UU UU UU UU

Diked areaDiked area UU

Aboveground valves, piping, and Aboveground valves, piping, and appurtenancesappurtenances

UU UU UU UU UU UU UU

Underground pipingUnderground piping UU UU

Offshore valves, piping, and Offshore valves, piping, and appurtenancesappurtenances

UU

Potentially Relevant Industry Standards –Visual Inspections &/or Integrity Testing


STI SPSTI SP--001 Scope001 Scope

Aboveground storage Aboveground storage tankstanksStable, flammable, & Stable, flammable, & combustible liquids combustible liquids

CCovers:overs:ShopShop--fabricated tanksfabricated tanksPortable containersPortable containersFieldField--erected tanks (up to erected tanks (up to 3030’’ diameter & 50diameter & 50’’ high only, high only, shell thickness less than shell thickness less than ½”½”))•• Covered in Appendix B of the Covered in Appendix B of the

StandardStandard


Types of SP001 InspectionsTypes of SP001 Inspections

Periodic AST Inspection (P)Periodic AST Inspection (P)Performed by ownerPerformed by ownerMonthly basisMonthly basisExample checklist provided in SPExample checklist provided in SP--001 standard001 standardRecords maintained for at least 3 yearsRecords maintained for at least 3 years

Formal external inspection (E)Formal external inspection (E)Performed by STI certified inspectorPerformed by STI certified inspectorRecords retained for life of the tankRecords retained for life of the tank

Formal internal inspection (I)Formal internal inspection (I)Performed by certified inspectorPerformed by certified inspectorRecords retained for life of the tankRecords retained for life of the tank

Leak test (L)Leak test (L)Performed by owner or his/her designeePerformed by owner or his/her designee


(by (by ‘‘ownerowner’’s inspectors inspector’’))


For Tier I Qualified FacilitiesFor Tier I Qualified Facilities

The Plan Template specifies the visual The Plan Template specifies the visual inspections inspections (it(it’’s based on STI SP001)s based on STI SP001)


Inspector Qualifications per STI SP001Inspector Qualifications per STI SP001


Example STI SP001 ReportExample STI SP001 Report


Integrity Testing of Other Tank Integrity Testing of Other Tank TypesTypes


Fiberglass Reinforced Plastic Tank Fiberglass Reinforced Plastic Tank InspectionsInspections

FTPIFTPI--20052005--2 2 ““Standard for InStandard for In--service Inspections of service Inspections of Aboveground Atmospheric Fiberglass Reinforced Aboveground Atmospheric Fiberglass Reinforced Plastic Tanks and VesselsPlastic Tanks and Vessels””

Visual inspection in accordance with ASTM D 2563 Visual inspection in accordance with ASTM D 2563 "Standard Test Method for Classifying Visual Defects "Standard Test Method for Classifying Visual Defects in Glassin Glass--Reinforced Plastic Laminate Parts.Reinforced Plastic Laminate Parts.““

Periodic inspection of the inside of the tank is Periodic inspection of the inside of the tank is important when assessing performanceimportant when assessing performance

Once a year is a good frequency for aggressive Once a year is a good frequency for aggressive service conditionsservice conditionsEvery two years in less aggressive service (such as Every two years in less aggressive service (such as water, nonwater, non--high temp oils, etc) high temp oils, etc)


Rotationally Molded Rotationally Molded Polyethylene TanksPolyethylene Tanks

Section 7Section 7

Training & ProceduresTraining & Procedures(as applicable to APSA tank (as applicable to APSA tank

facilities)facilities)


ProceduralProcedural--Related Compliance Related Compliance RequirementsRequirements

Facility must have in place/implement:Facility must have in place/implement:Procedures for routine handling of oilProcedures for routine handling of oil•• Loading, unloading, movement and facility transfers, key Loading, unloading, movement and facility transfers, key

maintenance, etc.maintenance, etc.

Procedures for overfill prevention and discharge Procedures for overfill prevention and discharge controlcontrolProcedures for inspections and periodic testingProcedures for inspections and periodic testingProcedures for inspecting and discharging Procedures for inspecting and discharging contained or accumulated stormwatercontained or accumulated stormwater

Significant flexibilitySignificant flexibilityMust be Must be ‘‘adequateadequate’’ for the facilityfor the facility

Reference and describe in PlanReference and describe in PlanNot addressed in the Template (Not addressed in the Template (dohdoh!)!)


ProceduresProceduresIn Plan:In Plan:

Just reference or Just reference or summarizesummarize

In practice?In practice?Criteria for good Criteria for good procedures:procedures:•• Complete/adequateComplete/adequate•• Appropriately Appropriately

communicated and communicated and well knownwell known

•• VerifiableVerifiable•• Accessible at time of Accessible at time of

needneed•• Implemented Implemented

consistentlyconsistently


What you say vs what you doWhat you say vs what you do


ProceduresProcedures


TrainingTrainingTwo types of training required by 40 CR 112.7(f)Two types of training required by 40 CR 112.7(f)

‘‘DetailedDetailed’’ SPCC Plan and implementation trainingSPCC Plan and implementation training•• No specified frequencyNo specified frequencySpill prevention briefingsSpill prevention briefings•• Annual Annual

1.1. Detailed SPCC Training Detailed SPCC Training (40 CFR 112.7(f)(1))(40 CFR 112.7(f)(1))

Training for Training for oiloil--handlinghandling employees and those with employees and those with oil spill oil spill prevention responsibilitiesprevention responsibilities. At a minimum, must include:. At a minimum, must include:•• Applicable pollution control laws and regulationsApplicable pollution control laws and regulations•• Operation & maintenance of oil discharge prevention Operation & maintenance of oil discharge prevention

systems/equipmentsystems/equipment•• Discharge prevention procedures and protocolsDischarge prevention procedures and protocols•• General facility operationsGeneral facility operations•• SPCC plan contents and understanding of the PlanSPCC plan contents and understanding of the Plan


TrainingTraining2.2. Annual spill prevention briefings for oil handling Annual spill prevention briefings for oil handling

personnel personnel (40 CFR 112.7(f)(1))(40 CFR 112.7(f)(1))……to assure adequate understanding of the SPCC Plan for the to assure adequate understanding of the SPCC Plan for the facilityfacilityBriefings must highlight and describe:Briefings must highlight and describe:•• Known discharges as described in Known discharges as described in §§112.1(b) or 112.1(b) or •• Failures, malfunctioning components, andFailures, malfunctioning components, and•• Any recently developed precautionary measuresAny recently developed precautionary measures

Should describe the training and briefing program Should describe the training and briefing program in the Planin the Plan

•• Plan template contains a training/ Plan template contains a training/ briefing log as Attachment 3.4)briefing log as Attachment 3.4)

•• Records of training not specifically Records of training not specifically required nonrequired non--qualified facilities or qualified facilities or Tier II qualified facilities Tier II qualified facilities


Designated Accountable PersonDesignated Accountable Person

The facility must designate a person The facility must designate a person at the facility who is accountable for at the facility who is accountable for discharge prevention and who discharge prevention and who reports to facility managementreports to facility management40 CFR 112.7(f)(2)40 CFR 112.7(f)(2)

Identify name and title in Plan (or Table Identify name and title in Plan (or Table GG--5 of Template)5 of Template)

Section 8Section 8

Spill Planning, Spill Planning, Notifications, and Notifications, and

ResponseResponse(as applicable to APSA tank (as applicable to APSA tank

facilities)facilities)


Control/Response Measures or Control/Response Measures or ProceduresProcedures

Response provisionsResponse provisionsMust have a plan/procedures to respond to oil spillsMust have a plan/procedures to respond to oil spills……generally describe them in the Plan (or Table Ggenerally describe them in the Plan (or Table G--7 in 7 in Template)Template)•• May consist of use of outside response agencies and May consist of use of outside response agencies and

contractorscontractors•• Must include internal notification and communicationMust include internal notification and communication

–– Table GTable G--8 in Template8 in Template

•• Must include outside agency notificationMust include outside agency notification–– Tables GTables G--9 & G9 & G--20 in Template (but that20 in Template (but that’’s federal onlys federal only……))

•• Should include some interim control measuresShould include some interim control measures–– Describe in Table GDescribe in Table G--7 in Template7 in Template

•• Full secondary containment compliance eases contingency Full secondary containment compliance eases contingency plan requirementsplan requirements


Control/Response Measures or ProceduresControl/Response Measures or Procedures

Response provisionsResponse provisionsUse of Business Use of Business Emergency Plan?Emergency Plan?•• OKOK……summarize in the Plan summarize in the Plan

or Template and include the or Template and include the BEP as a referenceBEP as a reference……butbut

•• Must include sufficient detail Must include sufficient detail (such as clean up, use of (such as clean up, use of contractors, repair/ contractors, repair/ reinspection, EPA notification reinspection, EPA notification for navigable water spills, for navigable water spills, etc.)etc.)

•• Must also have Must also have ‘‘management management commitmentcommitment’’ statementstatement

Look! ItLook! It’’s Kristen s Kristen ReigelReigel! We! We’’re saved! re saved!

Oh Great Holy Oh Great Holy SmokinSmokin’’Monkey, weMonkey, we’’re SAVED!!!re SAVED!!!


Control/Response Measures or Control/Response Measures or ProceduresProcedures

Countermeasures provisionsCountermeasures provisionsWritten management commitment of manpower, Written management commitment of manpower, materials, equipment, $$ to control spills and assure materials, equipment, $$ to control spills and assure cleanupcleanup


Importance of Secondary ContainmentImportance of Secondary Containment

Besides the obviousBesides the obvious…… If secondary containment and other If secondary containment and other diversionary means are determined by the PE to be diversionary means are determined by the PE to be ‘‘impracticalimpractical’’::

Impracticality determination must be detailed in the PlanImpracticality determination must be detailed in the Plan

Must do integrity testingMust do integrity testing…… and:and:

Plan must include a specific Plan must include a specific ‘‘Oil Spill Contingency PlanOil Spill Contingency Plan’’•• Must meet requirements of 40 CFR 109Must meet requirements of 40 CFR 109 (EPA guidance available):(EPA guidance available):

–– Authorities, responsibilities, and duties of all persons, organiAuthorities, responsibilities, and duties of all persons, organizations, zations, or agencies involved in oil removal operationsor agencies involved in oil removal operations

–– Notification procedures for the purpose of early detection and tNotification procedures for the purpose of early detection and timely imely notification of an oil dischargenotification of an oil discharge

–– Provisions to ensure that full resource capability is known and Provisions to ensure that full resource capability is known and can can be committed during an oil dischargebe committed during an oil discharge

–– Provisions for wellProvisions for well--defined and specific actions to be taken after defined and specific actions to be taken after discovery and notification of an oil dischargediscovery and notification of an oil discharge

–– Procedures to facilitate recovery of damages and enforcement Procedures to facilitate recovery of damages and enforcement measuresmeasures


40 CR 10940 CR 109

NOT your NOT your simple BEP!simple BEP!


Spill and Release ReportingSpill and Release ReportingIn addition to any local & state reporting In addition to any local & state reporting

Two main federal oil discharge requirements:Two main federal oil discharge requirements:1.1. Specific to SPCC facilities:Specific to SPCC facilities:

•• Report to the EPA Regional Admin. discharges of:Report to the EPA Regional Admin. discharges of:–– More than 1,000 gallons of oil in a single discharge to More than 1,000 gallons of oil in a single discharge to

navigable waters or adjoining shorelinesnavigable waters or adjoining shorelines–– More than 42 gallons of oil in each of two discharges to More than 42 gallons of oil in each of two discharges to

navigable waters or adjoining shorelines within a rolling 12navigable waters or adjoining shorelines within a rolling 12--month periodmonth period

–– ItIt’’s the amount of oil in gallons that reached the navigable s the amount of oil in gallons that reached the navigable waterswaters

•• Facility owner/operator must report to EPA within 60 daysFacility owner/operator must report to EPA within 60 days–– Detailed report content Detailed report content -- including failure analysis and corrective including failure analysis and corrective

actions taken (make sure the Plan describes the report to be filactions taken (make sure the Plan describes the report to be filed)ed)


Spill and Release ReportingSpill and Release Reporting

•• Report to the National Response Report to the National Response Center Center any amountany amount of oil discharge of oil discharge that:that:–– Violates state water quality standardsViolates state water quality standards–– Causes a film or sheen upon the waterCauses a film or sheen upon the water–– Leaves sludge or emulsion beneath the Leaves sludge or emulsion beneath the

surface surface

•• Facility owner/operator must report to NRC Facility owner/operator must report to NRC immediatelyimmediately–– Moderate report content (make sure the Moderate report content (make sure the

Plan describes the notification process, Plan describes the notification process, phone # [800phone # [800--424424--8802], etc.)8802], etc.)

–– Penalties likely to accrue if report not made Penalties likely to accrue if report not made within 15 minutes of discoverywithin 15 minutes of discovery

2.2. General to oil dischargesGeneral to oil discharges (from (from anyany facility):facility):


A simpler form A simpler form is in the is in the Template as Template as Attachment 4 Attachment 4 (Table G(Table G--20)20)


Spill and Release ReportingSpill and Release ReportingCalifornia ReportingCalifornia Reporting

Handler must, upon discovery, immediately report Handler must, upon discovery, immediately report any release any release oror threatened release of a hazardous threatened release of a hazardous materialmaterial•• Immediate reporting not be required if there is a reasonable Immediate reporting not be required if there is a reasonable

belief that the release or threatened release poses no belief that the release or threatened release poses no significant present or potential hazard to human health and significant present or potential hazard to human health and safety, property, or the environmentsafety, property, or the environment

Must also report Must also report any amountany amount of oil discharged to of oil discharged to ‘‘waters of the statewaters of the state’’Report to:Report to:•• CUPACUPA•• OES Warning CenterOES Warning Center•• 911 (if necessary)911 (if necessary)


Spill and Release ReportingSpill and Release ReportingCalifornia California Reporting under Reporting under APSAAPSA

Spill or release Spill or release of one bbl (of one bbl (>> 42 42 gallons) of gallons) of petroleum to petroleum to ‘‘waters of the waters of the statestate’’•• To OES and CUPATo OES and CUPA

The regular Calif. The regular Calif. Reporting should Reporting should suffice.suffice.

Section 9Section 9

Tools and ReferencesTools and References


Cal/EPA APSA Fact Sheets and InfoCal/EPA APSA Fact Sheets and Infowww.calepa.ca.govwww.calepa.ca.gov/CUPA/aboveground/CUPA/aboveground

mailto:[email protected]


Guidance!Guidance!

1111--05 EPA Guidance05 EPA GuidanceAmended Feb & Mar 06Amended Feb & Mar 06•• Will be updated in 2009 (?) to Will be updated in 2009 (?) to

address 11address 11--08 amendments08 amendments

A great compliance toolA great compliance tool

Includes sample SPCC Plans Includes sample SPCC Plans and Contingency Plans, etc.and Contingency Plans, etc.•• Sample plans available in WordSample plans available in Word

•• www.epa.gov/oilspillwww.epa.gov/oilspill

Includes examples and Includes examples and diagramsdiagrams

On CD and at On CD and at http://http://www.epa.govwww.epa.gov//emergencies/content/ emergencies/content/ spcc/index.htmspcc/index.htm

http://www.epa.gov/emergencies/content/spcc/index.htm


Guidance for Regional Guidance for Regional InspectorsInspectors


SPCC Plan ReminderSPCC Plan ReminderSPCC Plans are simply the SPCC Plans are simply the documentation of documentation of compliance programs and compliance programs and proceduresprocedures

ItIt’’s not just s not just whatwhat you sayyou say……itit’’s s howhow you carry it outyou carry it out

Operational personnel Operational personnel rarely read the Plan!rarely read the Plan!

SPCC Plan has force of SPCC Plan has force of federal and Calif. federal and Calif. regulationsregulationsThe SPCC Plan is a living documentThe SPCC Plan is a living document

The Plan and the SPCC program must be part of a Management The Plan and the SPCC program must be part of a Management of Change processof Change process

For the fourth year in a row, the Original Costume Contest at ESCI EnviroServices’ annual

Halloween party had no clear winner.

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