Streamlining the SPCC Process

Transcription

1 Streamlining the SPCC Process Presented by Mike Shoemaker, P.E., Wenck, Roswell, GA Scott Christensen, Delta Air Lines, Atlanta, GA

2 Agenda Introductions Wenck/Delta Overviews SPCC Overview SPCC Amendment Requirements Facilities Requiring Multiple Amendments Typical SPCC Plan Outline Streamlined SPCC Outline Benefits Summary 2

3 Wenck Enterprises Wenck Associates, Inc. is a leading engineering & consulting firm, dedicated to providing innovative solutions through our strategic engineering, environmental, and consulting services. 3

4 Delta Air Lines, Inc. Corporate Overview Headquartered in Atlanta, GA Operates over 5,400 flights/day Safety, Health, & Environment (SHE) Manages SHE compliance worldwide Environment consists of: Air Quality; Remediation; Hazardous Waste; EMS; and Water & Spill Response AST & UST Compliance Spill Response Water & Spill Response Responsible for ~ 35 SPCC Plans & 2 Facility Response Plans (FRP) throughout the US Oil storage quantities change often 4

5 SPCC Overview General Requirements Underground buried storage capacity of greater than 42,000 gallons in single or multiple tanks, not regulated under 40 CFR 280; and/or An aboveground cumulative storage capacity of greater than 1,320 gallons in containers greater than or equal to 55 gallons Containers that can frequently change oil storage quantity at a location Mobile Units Support Equipment Vehicles containing a non-motive source of fuel (e.g. deicing vehicles) 5

6 SPCC Amendment Requirements Commissioning/Decommissioning Containers Replacement, Reconstruction, or Movement of Containers Reconstruction, Replacement, or Installation of Piping Construction or Demolition that Might Alter Secondary Containment Changes of Product or Service Revision of a Standard Operating Procedure 6

7 Facilities Requiring Multiple Amendments Aviation Industry Airlines Airport Support Industries Multi-Site Industries Oil & Gas Operators Railroads Textile Industry Automotive and Automotive Industry 7

8 Cross-Reference with SPCC Rule Introduction Management Approval Professional Engineer Certification Plan Review Typical SPCC Plan Outline Location of SPCC Plan Certification of Substantial Harm Determination Part I - General Facility Information 1.1 Company Information 1.2 Contact Information 1.3 Facility Layout Diagram 1.4 Facility Location and Operations 1.5 Oil Storage and Handling 1.6 Proximity to Navigable Waters 1.7 Conformance with Applicable State and Local Requirements Part II - Spill Response and Reporting 2.1 Discharge Discovery and Reporting 2.2 Spill Response Materials 2.3 Spill Mitigation Procedures 2.4 Disposal Plan Part III - Spill Prevention, Control, and Countermeasure Provisions 3.1 Potential Discharge Volume and Direction of Flow 3.2 Containment and Diversionary Structures 3.3 Other Spill Prevention Measures 3.4 Inspections, Tests, and Records 3.5 Personnel, Training, and Discharge Prevention Procedures 8

9 Streamlined SPCC Plan Outline APPENDICES Only General Site Layout and Drainage Information is Provided in Text Specific Tank Information/Site Diagrams are contained in Appendices Appendix A General Figures Figure 1 Site Loca?on Map Figure 2 Site Plan Map Appendix B GSE Shop Detail Figure 3 GSE Shop Site Detail Table 1 GSE Shop - Storage Tanks Table 2 GSE Shop - Transfer Areas & Detail Table 3 GSE Shop Spill Poten?al Appendix C Terminal C Detail Figure 4 Terminal C Site Detail Table 4 Terminal C - Storage Tanks Table 5 Terminal C - Transfer Areas & Detail Table 6 Terminal C Spill Poten?al 9

10 Streamlined SPCC Plan Benefits Simplifies effort required to update the Plan Standard plan would require text revisions for amendments Entire plan would be reissued Only appendix affected by qualifying change must be revised Easy to send replacement pages Reduces costs significantly Plans can cost $3K-$10K depending on size of facility Streamlined revisions can be completed for 1/3 (or less) of the cost. 10

11 Streamlined SPCC Plan Site Examples 11

12 Summary Facilities that require SPCC Plans must maintain and revise plans as necessary Industries that use mobile storage units tend to have more need for amendments Designing the SPCC Plan to easily accommodate operational changes will save industries time and money. 12

13 Contacts: Mike Shoemaker, Wenck Associates Scott Christensen, Delta Air Lines, Inc