Environmental Management for Bureau-Wide Schools. Spill Prevention, Control, and Countermeasure Plans. Ryan Eberle, P.E. Kleinfelder Tempe, AZ

Transcription

1 Environmental Management for Bureau-Wide Schools Spill Prevention, Control, and Countermeasure Plans Ryan Eberle, P.E. Kleinfelder Tempe, AZ

2 SPCC Presentation Outline Regulatory Background SPCC Rule Contents SPCC Plan Applicability SPCC Plan Contents and Examples Maintaining Compliance with SPCC Plans Summary Q&A

3 Regulatory Background Statutory Framework CWA 311(j)(1)(c) Original SPCC Rule Effective: 1/10/ Final SPCC Rule Effective: 8/16/02 Amendments: 12/06, 12/08, 12/09 Numerous compliance date extensions

4 2002 Final Rule Key Changes Changed applicability criteria Aboveground storage >1,320 gallons Containers <55 gallons exempt Required 5-year Plan review Allowed deviations Except secondary containment Allow usual and customary recordkeeping

5 2002 Final Rule Key Changes Training only for oil handlers Users of oil subject to rule New requirements for integrity testing Evaluation for field constructed ASTs Buried piping provisions Removal of spill history in plan

6 2006 Amendments Key Changes Self-certification for qualified facilities 10,000 gallons or less total storage Exemptions Mobile refuelers Motive power containers Oil-filled operational equipment

7 2008 Amendments Key Changes Exemptions Hot-mix asphalt containers Pesticide application/mixing containers Heating oil containers for residences & farms Definition of loading/unloading rack Facility definition revised

8 2008 Amendments Key Changes Facility diagram requirements Security requirements Integrity testing requirements Revised qualified facilities Tier I Tier II

9 SPCC Rule (40 CFR 112) Subpart 40 CFR Contents A All facilities and all types of oil B Petroleum oils and non-petroleum oils Except those oils covered in Subpart C. C Animal fats and oils and greases, and fish and marine mammal oils; and vegetable oils from seeds, nuts, fruits, and kernels D Response requirements

10 SPCC Rule (40 CFR 112) 40 CFR Contents General applicability Definitions Requirement to prepare & implement a SPCC plan (compliance dates) Discharge reporting to EPA SPCC plan amendment requirements SPCC plan requirements for qualified facilities General requirements for SPCC plans SPCC plan requirements for onshore (non-production) facilities

11 SPCC Plans What is the purpose of a SPCC Plan? 40 CFR 112.1(a)(1) and 112.1(e) How do I know if I need one? 40 CFR When do I need to have it? 40 CFR What is included in a SPCC Plan? 40 CFR & 112.8

12 Purpose of SPCC Plans 112.1(a)(1) to prevent the discharge of oil into or upon the navigable waters of the United States 112.1(e) To form a comprehensive Federal/State spill prevention program that minimizes the potential for discharges

13 Navigable Waters of the U.S. The term "navigable waters" of the United States means "navigable waters" as defined in section 502(7) of the Federal Water Pollution Control Act (FWPCA), and includes: (1) all navigable waters of the United States, as defined in judicial decisions prior to the passage of the 1972 Amendments of the FWPCA (Pub. L ) also known as the Clean Water Act (CWA), and tributaries of such waters as; (2) interstate waters; (3) intrastate lakes, rivers, and streams which are utilized by interstate travelers for recreational or other purposes; and (4) intrastate lakes, rivers, and streams from which fish or shellfish are taken and sold in interstate commerce.

14 What Does it Really Mean? Generally speaking, if a USGS map has a blue line, it can be a U.S. Waterway Storm drain systems typically discharge to U.S. Waters so those storm drain systems can be identified as a U.S. Waterway A dry creek bed that only flows during a rain storm can be a U.S. Waterway An irrigation ditch can be considered a U.S. Waterway, etc., etc., etc.

15 Do I Need A SPCC Plan? 112.1(b) Applies to any owner or operator of a nontransportation-related onshore facility engaged in gathering, storing, using, or consuming oil and oil products which could reasonably be expected to discharge oil in quantities that may be harmful into or upon the navigable waters of the United States

16 Do I Use Oil? What is oil? Oil means oil of any kind or in any form, including, but not limited to: fats, oils, or greases of animal, fish, or marine mammal origin; vegetable oils, including oils from seeds, nuts, fruits, or kernels; and, other oils and greases, including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with wastes other than dredged spoil

17 A Potential To Discharge? Discharge includes, but is not limited to, any spilling, leaking, pumping, pouring, emitting, emptying, or dumping of oil 112.1(d)(1)(i) must exclude consideration of manmade features such as dikes or other structures that restrain, hinder, contain or otherwise prevent a discharge

18 What Is My Facility? Facility means any mobile or fixed, onshore building, property, parcel, lease, structure, installation, equipment used in oil storage, oil transfer, oil distribution, or in which oil is used The boundaries of a facility depend on several site-specific factors, including the ownership or operation of buildings, structures, and equipment on the same site and types of activity at the site. Contiguous or non-contiguous buildings, properties, parcels, leases, structures under the ownership or operation of the same person may be considered separate facilities.

19 Does My Facility Have Enough Capacity? 112.1(d)(2) Completely buried oil storage capacity 42,000 gallons and/or Aboveground oil storage capacity of 1,320 gallons I only have that one used oil tank and a few quarts of oil in the shop and a whole fleet of trucks parked overnight

20 Is any Equipment Exempt? 112.1(d) Containers w/ capacities <55 gallons Permanently closed containers (i.e., not in use) Motive power containers Hot-mix asphalt containers Residential heating oil containers Pesticide application equipment / mixing containers Completely buried tanks subject to UST regulations Wastewater treatment facilities

21 Example 1 Rio Grande Elementary School Adjacent to the Rio Grande 10 school buses w/ 100-gallon fuel tanks 5,000-gallon diesel UST (fueling buses) 5,000-gallon propane tank (heating) 1,500-gallon gasoline AST (fueling vehicles) Filled to 1,000 gallons Does RGE need a SPCC plan?

22 What Storage Counts? Fuel Storage School Buses 5,000-gallon diesel UST 1,500-gallon gasoline AST 5,000-gallon propane AST Does it Count? No No YES No Why? The school buses fuel tanks are considered "motive power containers" USTs are not included if regulated under 40 CFR 280 An aboveground oil tank Propane is not considered an oil Motive power container means any onboard bulk storage container used primarily to power the movement of a motor vehicle, or ancillary onboard oil-filled operational equipment (40 CFR 112.2).

23 Example 1 Does RGE need an SPCC plan because they only keep 1,000 gallons of gasoline at the site? Even though RGE only stores 1,000 gallons of gasoline, the tank has the to store 1,500 gallons, which is more than the 1,320 gallon threshold!

24 Example 2 Rio Grande Elementary School Adjacent to the Rio Grande 10 school buses w/ 100-gallon fuel tanks 5,000-gallon diesel UST (fueling buses) 5,000-gallon propane tank (heating) 1,000-gallon gasoline AST (fueling vehicles) Ten 55-gallon drums of engine & hydraulic oils & grease (bus maintenance) Does RGE need a SPCC plan?

25 What Storage Counts? Fuel Storage School Buses 5,000-gallon diesel UST 1,000-gallon gasoline AST Does it Count? No No YES Why? The school bus fuel tanks are considered "motive power containers" USTs are not included if regulated under 40 CFR 280 Still counts toward facility total even though it s only 1,000 gallons Propane Tank No Propane is not considered an oil. 55-gallon oil drums in building YES Any oil storage container 55-gallons or greater must be counted. Ten 55-gallon drums = 550 gallons

26 Example 2 Count 1,000-gallon gasoline AST and the ten 55-gallon drums. Does RGE need a SPCC plan? RGE has the to store 1,550 gallons of oil, which is more than the 1,320 gallon threshold!

27 Capacity Summary Count All oil containers 55 gallons or larger Oil storage containers in buildings Do not count: USTs (if regulated under 40 CFR 280) Motor vehicle fuel tanks Ancillary equipment tanks on vehicles e.g., hydraulic equipment tanks

28 When Do I Need A SPCC Plan? When were you in operation? Operation is not defined in the regulations, but it is generally accepted to mean the date on which the facility has the capacity to store 1,320 gallons of oil Key dates: August 16, 2002 November 10, 2010 (for now)

29 Key Dates 112.3(a) If your facility was in operation on or before August 16, 2002: Maintain your existing SPCC Plan (should be compliant with 2002 Rule) Amend it to comply with the revised regulations and implement the revised plan no later than November 10, 2010 (comply with 2006, 2008, 2009 Amendments)

30 Key Dates 112.3(a) If your facility was in operation after August 16, 2002 but on or before November 10, 2010: Prepare and implement a plan no later than November 10, (b)(1) If your facility was in operation after November 10, 2010: Prepare and implement a plan before you begin operations (i.e., before you have the capacity of 1,320 gallons)

31 Example 3 Construction of Rio Grande High School (RGHS) Located near a dry ditch that eventually drains to the Rio Grande Will have one 2,000-gallon diesel AST to fuel school buses Construction began in March 2010 and will finish by October 2010 AST will not be installed until January 2011 What are RGHS obligations regarding their SPCC Plan?

32 Does RGHS Need a SPCC Plan? Potential to discharge to U.S. Waters? Dry ditch eventually discharge to Rio Grande Capacity? One 2,000-gallon diesel tank

33 When Does RGHS Need a SPCC Plan? Beginning Operation? Tanks are being installed in 2011 Therefore, the Plan must be prepared and implemented before tanks are A. Filled B. Installed Based on

34 Example 4 Rio Grande Elementary Constructed in 2005 Need for SPCC plan already established But When do they need the Plan? When do they need to comply with the Plan?

35 SPCC Plan Certification 112.3(d) A licensed Professional Engineer (P.E.) must review and certify the SPCC Plan P.E. can be from any state OR

36 Self-Certification Qualified facilities may self-certify if: Total aboveground oil storage is 10,000 U.S. gallons or less; AND No single discharge over the past 3 years that exceeded 1,000 U.S. gallons; AND No two discharges of 42 U.S. gallons within any twelve month period over the past three years Cannot self-certify portions dealing with environmentally equivalent or impracticability determinations need P.E.

37 Self-Certification Qualified facility types Tier I No single container larger than 5,000 gallons May use SPCC plan template ( Tier II All other qualified facilities not classified as Tier I Specific requirements must be met!

38 Quick Review SPCC Rule Contents SPCC Plan Applicability Do I need a plan? When do I need a plan? P.E. and self-certification Now SPCC Plan Components

39 Overview of Key SPCC Plan Components

40 General SPCC Plan Components 112.7(a)(1) (40 CFR 112.7) Discussion of conformance with the regulation 112.7(a)(3) Describe the physical layout of the facility and include a facility diagram Type of oil stored and capacity of each container Discharge prevention measures & procedures for routine handling Discharge or drainage controls for control of a discharge (e.g., secondary containment)

41 General SPCC Plan Components 112.7(a)(3) [cont.] (40 CFR 112.7) Countermeasures for discharge discovery, response and cleanup Methods of disposal of recovered materials Contact list 112.7(a)(4) Provide procedures for reporting a discharge 112.7(b) Prediction of potential discharge

42 Facility Diagram Requirements Must show: Location & contents of oil storage containers Location & contents of each storage area e.g., multiple 55-gal. drums stored in one location Location of all exempt USTs, connecting pipes, gathering lines, etc. Should also show: Surface water flow directions Drain locations

43 Facility Diagram Example

44 Reporting Agency Reportable Quantity Reporting Deadline National Response Center Any release of oil to a navigable water unless exempted Immediately Type of Report Telephone (800) EPA Region 1. A discharge of 1,000 gallons of oil into or upon navigable waters in a single spill event, or 2. A discharge of oil more than 42 U.S. gallons into or upon navigable waters in each of two spill events occurring within any 12-month period 60 days Written

45 Reporting Reports must include: The exact address or location and phone number of the facility; The date and time of the discharge; The type of material discharged; Estimates of the total quantity discharged; Estimates of the quantity discharged as described in 40 CFR 112.1(b); The source of the discharge; (cont.)

46 Reporting Reports must include: A description of all affected media; The cause of the discharge; Any damages or injuries caused by the discharge; Actions being used to stop, remove, and mitigate the effects of the discharge; Whether an evacuation may be needed; and, The names of individuals and/or organizations who have also been contacted.

47 Example Discharge Report Part A: Discharge Information Facility Information Name: Owner: Operator (Lessee): Address: Address: Address: Telephone (Comm Center): Contact: Contact: Telephone: Telephone: Type of Oil: Discharge Date and Time: Discovery Date and Time: Quantity Released: Quantity Discharged to Waterbody: Discharge Duration: Discharge Location/Source: Actions taken to stop, remove, and mitigate impacts of the discharge: Affected Media: Air Water Soil Stormwater sewer Sanitary sewer oil/water separator Other Nature of discharges, environmental/health effects, and damages: Injuries: Yes No Describe: Evacuation Required: Yes No Describe: Part B: Notification Checklist Scenario Agency Telephone Date Time Name of person receiving call Name of person making notification: Release (any amount) Discharge to navigable water (any amount) Discharge to navigable water (>1,000 gal a single event or >42 gal in two events w/in 12-months) Facility (Internal) National Response Center (800) EPA Region IX Written N/A ADEQ Written N/A

48 Spill Prediction Storage Container Description Cause of Spill Direction of Flow - Destination Rate of Release (gal/min) Duration of Release (seconds) Quantity Released (gallons) Diesel AST (a) Tank overfill (b) Transfer hose leak SW - storm drain (a) 20 (b) 5 5 (a) 1.7 (b) 0.5 Gasoline AST (a) Tank overfill (b) Transfer hose leak SW - storm drain (a) 20 (b) 5 5 (a) 1.7 (b) 0.5 Sub-base AST for Generator (a) Tank overfill (b) Transfer hose leak S-SE - storm drain (a) 20 (b) 5 5 (a) 1.7 (b) 0.5 Sub-base AST for Generator (a) Tank overfill (b) Transfer hose leak N or S - storm drain (a) 20 (b) 5 5 (a) 1.7 (b) 0.5 Flexible aboveground fuel transfer hose (a) Tank overfill (b) Transfer hose leak SW - storm drain

49 General SPCC Plan Components 112.7(c) (40 CFR 112.7) Provide appropriate containment and/or diversionary structures to prevent a discharge 112.7(d) Impracticality determination 112.7(e) Written commitment of manpower, equipment & materials to control & prevent discharge Conduct inspections and tests

50 General SPCC Plan Components 112.7(f) (40 CFR 112.7) Training for oil-handling personnel Designation of responsible personnel 112.7(g) Security for oil handling, processing, storage areas Adequate lighting for discovery and prevention of discharges 112.7(h) Tank truck loading/unloading racks

51 Tank Loading/Unloading Provide general secondary containment for the following: When tankers unload fuel to your ASTs/USTs When your vehicles are fueling from ASTs/USTs Can use active containment measures

52 General SPCC Plan Components (40 CFR 112.7) 112.7(i) Brittle fracture evaluation for field-constructed tanks 112.7(k) Oil-filled operational equipment requirements In lieu of general secondary containment: Document inspection and monitoring program Prepare an oil spill contingency plan per 40 CFR 109 Written commitment of manpower, etc.

53 Specific SPCC Plan Components Facility Drainage 112.8(b) (40 CFR 112.8) Restrain drainage from diked areas Inspect accumulated water before draining Retain drainage from undiked areas at the facility

54 What Happens When Rain Accumulates Containment? You CAN T allow uncontaminated rainwater from the secondary containment into a storm drain or discharge to a waterway unless you: Normally keep the bypass closed Inspect the retained rainwater no oil is present Open the bypass under responsible supervision Keep adequate records May need a separate permit to release this rainwater (NPDES?)

55 What Happens When Rain Accumulates Containment?

56 Specific SPCC Plan Components (40 CFR 112.8) Bulk Storage Containers [ 112.2] Any container used to store oil.including storage prior to use, while being used, or prior to further distribution in commerce Excludes oil-filled electrical, operating or manufacturing equipment e.g., transformers, hydraulic systems, compressors Alternative requirements [ 112.7(k)]

57 Bulk Storage Containers

58 Oil-Filled Equipment

59 Specific SPCC Plan Components (40 CFR 112.8) Bulk Storage Containers 112.8(c)(1) Construction and material compatible with material stored and conditions of storage (temp. & press.) 112.8(c)(2) Provide secondary containment for the entire capacity of the largest single container + sufficient freeboard to contain precipitation ( sized ) Diked areas must be sufficiently impervious

60 Example 5 Rio Grande Elementary s 1,000-gallon gasoline tank sits in a steel catchment basin. The catchment is really just a horse trough, but the guy from Feed n Seed said it would hold 1,000 gallons of water. Q: Is the catchment basin adequate for sized secondary containment?

61 Example 5 The entire capacity of the largest single container is 1,000 gallons, so the capacity of the secondary containment must be at least 1,000 gallons AND Have sufficient freeboard to contain precipitation

62 Example 6 Ten 55-gallon drums stored in a covered maintenance shop. Q1: Do the drums need secondary containment? Q2: How many gallons does the secondary containment for the drums need to hold?

63 Specific SPCC Plan Components (40 CFR 112.8) Bulk Storage Containers 112.8(c)(7) Conduct regular tank integrity testing and inspections per industry guidance 112.8(c)(8) Install at least one of the following overfill protection devices & test regularly High liquid level alarms Direct audible or code signal High liquid level pump cutoff device Direct vision gauge (must have person present)

64 Specific SPCC Plan Components (40 CFR 112.8) Bulk Storage Containers 112.8(c)(10) Promptly correct visible discharges & remove any accumulations of oil in diked areas 112.8(c)(11) Provide sized containment for portable and mobile containers Except mobile refuelers (general containment)

65 Specific SPCC Plan Components (40 CFR 112.8) Facility Transfer Operations 112.8(d) Protective wrapping/coating and cathodic protection for buried piping Installed after August 16, 2002 Properly design pipe supports Conduct regular inspections of aboveground valves, piping, etc. Warn vehicles entering facility

66 Other SPCC Plan Requirements Use good engineering practices Management approval and commitment Organization 112 Appendix C Certification of Substantial Harm Criteria Transfer oil over water Store >1,000,000 gallons

67 Quick Review SPCC Rule Contents SPCC Plan Applicability SPCC Plan Components Next Practical steps to maintaining compliance

68 Maintaining Compliance Secondary Containment General or sized Integral (i.e., double-wall) Concrete Plastic liner Portable Sized for largest tank Compatible with tank contents

69 Tanks Maintaining Compliance Inspections Level indicator operational Leaks (bolts, rivets, seams) Corrosion (holes, pitting) Tank bottoms & supports Spill/overfill protection Electrical/grounding Emergency shut-off Signage/labels Set backs Locks

70 Piping Maintaining Compliance Inspections Supports Signage/labels Connections (seepage) Earthquake/seismic protection Weather protection (corrosion) Cracking, crumbling, deterioration Valves closed when non-operating Pump controls locked off when not in use

71 Maintaining Compliance Inspections Secondary Containment Sidewalls and floor intact? Cracks sealed? Valves/drainage controls closed and operational? Free of liquids? Cleaned-out? Tank bottom visible?

72 Maintaining Compliance Inspections Security/Vandalism Check perimeter fencing Check facility lighting Gates locked when unattended

73 Maintaining Compliance Maintenance Fix leaks in piping/tanks/valves immediately Seal/reseal cracks in secondary containment Clean-out/pump-out secondary containment Clean-up small spills immediately Easier to detect new spills

74 Maintaining Compliance Common Problems Inadequate piping support

75 Maintaining Compliance Common Problems Inadequate secondary containment

76 Maintaining Compliance Common Problems Inadequate secondary containment

77 Maintaining Compliance Common Problems Inadequate secondary containment

78 Maintaining Compliance Common Problems Inadequate maintenance of secondary containment Drain

79 SPCC Plan Challenges SPCC Plan Organization Implementation If it s not written down, you didn t do it Document! Document! Document! The burden of proof is on you! Combined plans may be open for public review Training

80 Summary Q&A Question 1 What is the purpose of the Oil Pollution Prevention regulation found in 40 CFR 112? prevent the discharge of oil into or upon the navigable waters of the United States

81 Summary Q&A Question 2 What is the total oil capacity at my site that will require me to implement a SPCC Plan? 1,320 U.S. Gallons

82 Summary Q&A Question 3 If I have two 6,000 gallon AST that contain diesel, do I need a P.E. to certify my plan? YES Total storage exceeds 10,000 gallons

83 Summary Q&A Question 4 I have a tank farm with one 10,000 gallon diesel AST and one 5,000 gallon waste oil AST. How much must my secondary containment hold? 10,000 gallons plus freeboard!

84 Summary and Conclusions Purpose of the Oil Pollution Prevention regulations Triggers for SPCC Plan implementation When a P.E. must certify the SPCC Plan Required components of the SPCC Plan Compliance with SPCC requirements

85 Thank you! Ryan Eberle, P.E. KLEINFELDER Address: 1335 W. Auto Dr. Tempe, AZ Phone Website: EPA SPCC Website: