spcc inspection process · sti sp001 inspection protocols • an assigned knowledgeable marina...
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SPCC Marina Inspection
Update - 2018
Oklahoma Marina Association
Inspector Tom McKay
Recent Compliance Assistance Documents
• 40 CFR 112 – Final & Most Recent Regulation (7/1/15)
• Latest SPCC Inspection Checklists (6/1/2014)
• SPCC Guidance for Regional Inspectors (8/28/13 –
Update Pending)
• SPCC & FRP Workshop for Onshore Facilities
(Scheduling) in Addison, TX
SPCC Inspection Process
• Facility Inspection Targeting
– History of non-compliance
– Spill history of an geographic area
– Spill Responses **
– Distance to navigable waters
– Proximity to sensitive ecosystems
– Citizen Complaints **
– State/Federal referrals **
The Most Common
SPCC Violations At
Marinas
5
No SPCC Plan
• Commonly found at facilities that did not
know that they were regulated
– Small facilities
– Facilities that had been purchased but
had not put together a plan yet.
Common Violation
6
No PE Certification
• PE certifies that the facility’s equipment, design, construction, and maintenance procedures used to implement the Plan are in accordance with good engineering practices.
• PE certification must be completed in accordance with law of the state in which the PE is working
• Generally certification includes:
– Name
– Registration number and State
– Date of Certification
– PE seal affixed to Plan
Common Violation
Qualified Facility ApplicabilityIf the facility total aboveground oil storage capacity is 10,000 gallons or less …
And… And the facility has… Then the facility is a:
Within three years prior to the
Plan certification date, or since
becoming subject to the SPCC
rule if in operation for less than
three years, the facility has not
had:
• A single discharge of oil to
navigable waters or
adjoining shorelines
exceeding 1,000 gallons, or
• Two discharges of oil to
navigable waters or
adjoining shorelines each
exceeding 42 gallons within
any 12-month period.1
No individual aboveground
oil containers greater than
5,000 gallons;
Tier I Qualified Facility:
Complete and self-certify
Plan template (Appendix G
to 40 CFR part 112) in lieu of
a full PE-certified Plan.
Any individual aboveground
oil container greater than
5,000 gallons;
Tier II Qualified Facility:
Prepare a self-certified Plan
in accordance with all
applicable requirements of
§112.7 and subparts B or C
of the rule, in lieu of a PE-
certified Plan.
8
No Records
• Owner/operator does not have records of inspections or
tests and spill prevention training.
• Facility maintains very generic records that do not cover
all of the requirements of the rule.
• Common to hear that they do inspections, but do not
write them down.
• Lack of 5-Year Plan Review **
Common Violation
Totes and Drums not in
secondary containment
Common Violation
No General Containment for Loading Areas
Pump dispensers w/out
general containment
Load-line w/out general
containment
No Secondary Containment
Secondary Containment Appears
Inadequate
Inadequate containment Inadequate containment
Containment Not Impervious To Contain Oil
Cracks in concrete
containment
Cracks in cinder-block
containment
Piping and Valve Issues
Lack of Tank Integrity Testing Protocols
SPCC Plan Requirements
Identify Standard Used
STI SP001
Best Standard for Marinas
API 653
Identify Inspection and
Testing Protocols
External inspection
Shell Testing(ultrasonic)
Implementation
Conduct & Record
external inspections per
standard used
Conduct & Record Non-
destructive shell
thickness testing; ie
ultrasonic or hydrostatic.
STI SP001 Inspection Protocols
• An assigned knowledgeable marina employee conducts periodic
inspections of all marina shop-built Above Ground Storage
Containers (ASTs)
• Records of inspections consist of the monthly and annual inspection
checklist in the Steel Tank Institute (STI) SP001 Standard
STI SPOO1 Inspection Protocols For Typical Marina Tanks
STI SP001 - Spill Control and CDRM
CONTINUOUS RELEASE DETECTION METHOD (CRDM) – a means
of detecting a release of liquid through inherent design.
Examples of CDRM:
Secondary containment AST, including double-wall AST
Elevated AST, with or without release prevention barrier.
SPILL CONTROL - a means of preventing a release of liquid to the
environment, including adjoining property and waterways. Spill control
methods include :
Secondary containment dike/berm
Secondary containment AST
Secondary containment system
Typical Marina Tank Configuration Within the SP001
Standard
Marinas With Underground Storage Tanks
• USTs are exempt from SPCC regulatory requirements as long as
the facility follows 40 CFR 280 and/or 281.
• Most marinas incorporate Oklahoma UST protocols administered by
the Oklahoma Corporation Commission – Petroleum Storage Tank
Division.
SPCC Plan Maintenance & Housekeeping
* Review and Update Your SPCC Plan – Most members were
brought into compliance in 2009 – Plans should have been
updated by 11/10/2011 to incorporate new regulatory
amendments.
* Must document Plan review and evaluation.
Sign statement at beginning or end of Plan or in a log or
an appendix:
“I have completed review and evaluation of the SPCC Plan
for (name of facility) on (date), and will (will not) amend the
Plan as a result.”
PE must certify any “technical” amendment to Plan.
Continued SPCC Maintenance
• Keep current on overall facility inspection records.
• Keep current on spill prevention training for oil & fuel handling
personnel.
• Both inspection records and training records are required to be
maintained with your plan for 3 years.
• Follow and document tank integrity inspection & testing
protocols developed for your facility.
Continued SPCC Maintenance
• Tier II Tank Registration with ODEQ, Local Emergency Planning
Committee (LEPC), and local fire department due annually on
March 1st
• Maintain requisite Material Safety Data Sheets (MSDS) for
hazardous materials including fuel stored at your marina
Conclusions
• Emphasis upon joint inspections with both
State and Federal Agencies.
• Our goal is to increase compliance
awareness and improve response
performance.
Contact Information
• Inspector Tom McKay
• Office Phone: (214) 665-2180
• E-Mail: [email protected]