spill prevention control & countermeasures compliance and planning
TRANSCRIPT
Spill Prevention Control & Countermeasures
Compliance and Planning
SPCC Plan
• 40 CFR 112
• Facilities subject to the rule must prepare and implement a plan to prevent any discharge of oil into or upon navigable waters of the United States or adjoining shorelines.
Who is regulated by the Rule?
• Must meet 3 Criteria1)Must be non-transportation related.2)Must have an aggregate AST capacity of
greater than 1,320 gallons or a completely buried storage capacity greater than 42,000 gallons.
3)Must be a reasonable expectation of a discharge into or upon navigable water or adjoining shorelines.
Who prepares the plan?
• The responsibility of the facility owner or operator but it MUST be certified by a licensed Professional Engineer (PE).
Professional Engineer (PE)
1) Attests to familiarity with the requirements of part 112.
2) Agent has visited and examined the facility.
3) The plan has been prepared in accordance with good engineering practices, including consideration of applicable industry standards.
4) Procedures for required inspections and testing have been established.
5) The plan is adequate for the facility.
What’s in the Plan?
1) Facility Owner, Operator, and Location2) Facility Contacts3) Facility Description which includes
operations and storage (Tank ID, Volume, and Contents)
4) Spill History5) Prevention Measures ProvidedCheck your State regulations as they may
be different from Federal regulations.
Prevention Measures Provided
• Drainage Control (Dikes, Valves, Plant Drainage Systems, Final Discharge of Drainage, and Facility Drainage Systems and equipment).
• Bulk Storage Tanks and Secondary Containment.
Testing
• AST periodic integrity testing
• Must be performed every 5 years for external inspections and every 10 years for internal inspections.
• Internal inspections only encompasses AST that hold more than 25,000 gallons of No. 2 and No. 6 Fuel Oil
Inspections
• Requirements may be different depending on the State.
• Weekly inspections shall be conducted in accordance with CFR
• Monthly inspections shall also be conducted for AST’s.
• Ensure proper training of individuals conducting inspections.
Sample Weekly Inspection
Weekly AST Inspection____ (1) Containment dike or berm in satisfactory condition.____ (2) Containment area free of excess standing water or oil.____ (3) Gate valves used for emptying containment areas secured.____ (4) Containment area/base of tank free of high grass, weeds, and debris.____ (5) Tank shell surface, including any peeling areas, welds, rivets/bolts, seams, and foundation, visually inspected for areas of rust and other deterioration.____ (6) Ground surface around tanks and containment structures and transfer areas checked for signs of leakage.____ (7) Leak detection equipment in satisfactory condition.____ (8) Separator or drainage tank in satisfactory condition.____ (9) Tank water bottom drawoffs not in use are secured.____ (10) Tank fill valves not in use are secured.____ (11) Valves inspected for signs of leakage or deterioration.____ (12) Inlet and outlet piping and flanges inspected for leakage.____ (13) All tank gauges have been inspected and are operational._________________________ ____________ _______Signature of Inspector Date Time
SPCC Review
• Review your SPCC/ODCP Plans Annually!!• Stay up to speed in any and all changes made to
your requirements by Federal and State regulators.
• Make sure that you enter into your plan the following.
1)Date of review/revision2)Revisions made3)Signature of reviewer4)Up to date PE stamp certifying the SPCC
Sample SPCC Review Sheet
SPCC / ODCP Plan Annual ReviewSection Requirements Met Revisions Made1. Compliance and Review Page2. Management Approval3. Owner, Operator, and Location4. Facility Contact Information5. Facility Description
a. Facility Operations b. Facility Storage c. Drainage Pathway to navigable waters
6. Spill History a. History b. Spill Predictions
7. Prevention Measures a. Drainage Control b. Bulk Storage Tanks c. Facility Transfer Ops d. Loading/Unloading e. Inspections/Record Keeping f. Site Security g. Personnel Training h. Spill Control Equip.
8. Emergency Contacts9. Spill Contractors10. Worst Case Scenario11. Figures12. Containment Calculations
Reviewed By:________________________ Signature: Date:_________________
SPCC Maps and Figures
• Make sure copies of SPCC maps are kept with your permit and plan!
• Insure all maps are up to date, accounting for new construction or facility changes.
• Maps shall contain all requirements set forth by Federal and State regulations.
• Calculations for figures shall be double checked for accuracy.
Spills Happen!That’s why we have an SPCC!
DO YOUR INSPECTIONS!
Questions or Concerns?
• Open to any questions
• If you would like to contact me with questions regarding your SPCC compliance or any reference material within this presentation my contact info is
Daniel Noack
Environmental Manager, Smithfield Packing Complex
(757) 357-1501