Transcript SPCC Training

Beth Israel Deaconess
Medical Center
Boston, MA
Spill
Prevention
Countermeasures &
Controls
Training
Harvard
Medical
School
Today’s Outline
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What is SPCC?
Why are we in this training?
Regulatory summary of SPCC Plan
BIDMC Oil Storage
Potential Oil Spill Pathways
Discharge Prevention Measures
Contingency Plan
Harvard
Medical
School
What is SPCC?
• Spill Prevention Control and Countermeasures
• It is the oil pollution prevention regulation (40 CFR
112) promulgated under the authority of the Clean
Water Act (33 USC 1251)
• Establishes equipment, methods, and procedures to
prevent discharges of oil into or upon waters of the
United States
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Medical
School
Goals of SPCC Training
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Familiarize employees with the written SPCC Plan
Identify oil storage locations and handling procedures
Identify spill pathways
Familiarize employees with appropriate spill
response procedures and use of response
equipment
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Medical
School
SPCC Training Requirements
• Training must be provided to new hires and at least
annually to personnel involved in oil handling or
facility maintenance about proper actions to take in
the event of a spill
• Training updates must be conducted whenever a
significant change has been made to any oil
storage (e.g., new tank installation)
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Medical
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Who is subject to SPCC?
• Facilities that store, transfer, consume, or
otherwise use oil that “due to its location,
could reasonably be expected to discharge
into or upon waters of the U.S.”
• And, have aggregate above-ground storage
capacity > 1,320 gallons
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Medical
School
What is considered “oil”?
• “oil of any kind or in any form, including fats,
oils, greases of animal, vegetable, or nut
origin; and other oils and greases, including
petroleum oil, fuel oil, sludge, synthetic oils,
mineral oils, oil refuse, or oil mixed with other
waste…”
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Medical
School
What are the penalties if I fail to
comply?
• Civil administrative penalties up to $11,000
per day
• Judicial civil penalties up to $32,500 per day
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Medical
School
What are the SPCC requirements
for BIDMC?
• Must prepare a Spill Prevention
Countermeasures and Controls (SPCC) Plan
• The plan must certified by a licensed
Professional Engineer (P.E.)
• Reviewed and recertified every 5 years, or if
any technical changes are made.
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Medical
School
What is an SPCC Plan?
• The SPCC Plan is the written document that
details the equipment, personnel, procedures,
and steps to prevent and/or control
discharges of oil; and provides the
countermeasures to be implemented in the
event of a discharge
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Medical
School
Where is the Plan kept?
• A complete copy of the plan must be
maintained at the facility
– EH&S department Rose 3rd floor (RO 310)
• The plan does not need to be submitted to
EPA, but must be available for review during
business hours
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Medical
School
SPCC Plan Contents
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Facility Information
Oil Storage Summary
Potential Spill Pathways
Discharge Prevention Measures
Contingency Planning
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Medical
School
BIDMC Facility Information
• Nearest navigable water is Muddy River (1/10
mile away)
• Oil Storage Capacity – 53,359 gallons
• Worst Case Discharge – 25,000 gallons
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Medical
School
BIDMC
Emergency Response
• Code Orange Emergency Line
In-house Phone: 2-1212
Outside Phone: 617-632-1212
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Medical
School
Facility Contacts
• Rick Marini – Dir. Maint. Operations
617-667-4453
pager - #31027
• Gary Schweon – Dir. EH&S
617-667-5107 pager - #39118
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Medical
School
BIDMC Oil Storage
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Medical
School
BIDMC Oil Storage
Farr Building
6,000-gallon #2 fuel oil UST
75-gallon day tank on roof
50-gallon day tank in sub-basement
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Medical
School
BIDMC Oil Storage
Farr Building (continued)
55-gallon coolant drums (2) in sub-basement
55-gallon coolant tank on 12th floor
220-gallon coolant supply area 12th floor
95-gallon AST for elevator hyd. fluid
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Medical
School
BIDMC Oil Storage
Lowry Medical Office Building
275-gallon #2 fuel oil AST
330-gallon #2 fuel oil AST
30-gallon day tank
55-gallon coolant drums (2) in basement
55-gallon coolant drums (4) on 10th floor
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Medical
School
BIDMC Oil Storage
Clinical Center – West
8,000-gallon #2 fuel oil UST
75-gallon day tanks (2) on 8th floor
187-gallon ASTs (2) for elevator hydraulic
fluid
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Medical
School
BIDMC Oil Storage
Deaconess Building
415-gallon AST for elevator hyd. fluid
55-gallon waste oil drums (2)
21-27 Burlington Avenue
no longer leasing facilities
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Medical
School
BIDMC Oil Storage
Shapiro Building
3,000-gallon #2 fuel oil AST
100-gallon day tank on 10th floor
55-gallon waste oil drum in grounds shed
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Medical
School
BIDMC Oil Storage
Feldberg Building
145-gallon AST for elevator hyd. fluid.
Finard Building
6,000-gallon #2 fuel oil UST
205-gallon day tank in basement
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Medical
School
BIDMC Oil Storage
Stoneman Building
25,000 gallon emergency gen UST
3-200 gallon ASTs with 3 emergency generators
(Reisman Roof)
Rose Building
55-gallon coolant drums in meter room (4)
600-gallon AST for kitchen grease in basement
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Medical
School
BIDMC Oil Storage
Research North
450-gallon #2 fuel oil AST
75-gallon day tank in penthouse
145-gallon ASTs (2) for elevator hyd. fluid.
55-gallon coolant drums (4) in penthouse
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Medical
School
Potential Spill Pathways
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Medical
School
Potential Spill Pathways
Farr Building UST: Overfills during delivery
could flow out to the riverway.
Farr Building Emergency Generators: Spill on
the roof could enter roof drain.
Clinical Center West UST: Overfills during
delivery could enter Muddy River.
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Medical
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Potential Spill Pathways
Finard Building UST: Overfill during delivery
could enter storm drains or Muddy River.
Stoneman Building: Piping or day tank failure
could enter catch basin (entire contents of
UST could be emptied into day tank if level
controls fail and go to roof drain and catch
basin 25,000 gal).
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Medical
School
Discharge Prevention Measures
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Facility Drainage Control
• Surface drain covers used during fuel oil
deliveries
• Floor drains discharge to sanitary sewer
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Medical
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Bulk Container Management
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Containers compatible with contents
Secondary containment provided
Corrosion protection for USTs
Integrity testing for ASTs
High-level alarms on all tanks
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Medical
School
Facility Transfer Operations
• Transfer piping protected against corrosion
and vehicular damage
• Out-of-service lines blank-flanged and locked
• Piping regularly inspected for leaks
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Medical
School
Tanker Unloading Procedures
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All deliveries are attended
Spill response kits are nearby
Surface drains covered/locked
Tanks have overfill protection
Tanker inspected for leakage before leaving
facility
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Medical
School
Inspections and Records
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Tanks and piping inspected by Maintenance
Tanks integrity tested every ten years
Spill response equipment inspected quarterly
Secondary containment inspected monthly
Records kept for five years
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Medical
School
Site Security
• Fencing; flow valves locked; starter controls
locked; pipeline connections securely capped
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Medical
School
Training
• New hires and annually as appropriate
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Medical
School
Contingency Planning
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Contingency Planning
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Identification of Sensitive Areas
Spill Response Equipment
Emergency Coordinator Duties
Emergency Assessment
Notifications
Post-Emergency Actions
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Medical
School
BIDMC Sensitive Areas
• The “Muddy River”
Endangered Species Habitat
Recreational Use (boating)
Wetlands Resources
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Medical
School
Spill Response Priorities
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Respond to injuries
Protect self and others
Secure the source
Make required notifications
Contain spilled material
Protect the environment
Conduct clean-up activities
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Medical
School
Notifications - Internal
• Contact your supervisor
• Contact Code Orange Emergency Line
@ 2-1212
whenever there is a spill, or threat of a spill,
fire, or explosion involving oil (or other
hazardous material)
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Medical
School
Situation Assessment
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Type of situation (spill, fire, etc.)
Material involved
Location
Potential hazard to personnel or environment
Corrective action needed
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Medical
School
Small Spill Response
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Small < 55 gallons
Extinguish ignition sources
Isolate the area
Contain and absorb spilled material
Transfer spent sorbent to a drum
Clean the area of residue
Properly dispose of spilled material
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Medical
School
Large Spill Response
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Large spills > 55 gallons
Extinguish ignition sources
Contain spilled material to the extent practical
Stop the source of the leak (if safe to do so)
Summon external resources
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Medical
School
Spill Response Equipment
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Absorbents, Pigs, Booms
Shovels, brooms, empty steel drums
PPE (gloves, goggles, boots)
Cleaner and/or degreaser
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Medical
School
Emergency Coordinator Duties
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Assess the situation
Make notifications, external if needed
Direct small spill response actions
Request Contractor assistance for large spills
Conduct post-emergency actions
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Medical
School
Notifications - External
• for releases to soil > ten gallons
• for releases to water that cause a sheen
The designated Emergency Coordinators will
contact:
MA DEP (617)556-1133
US EPA (617)223-7265
National Response Center (888)304-1133
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Medical
School
Post Emergency Actions
• Ensure notifications have been made
• Identify cause of emergency
• Implement corrective actions to prevent
recurrence
• Evaluate emergency response
• Evaluate effectiveness of SPCC Plan
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Medical
School
Recap
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What is SPCC?
Why are we in this training?
Regulatory summary of SPCC Plan
BIDMC Oil Storage
Potential Oil Spill Pathways
Discharge Prevention Measures
Contingency Plan
Harvard
Medical
School