Transcript SPCC Plans - Duke University

SPCC Plans
– Also known as…Spill Prevention, Control, &
Countermeasures Plan
• Required as part of 40 CFR Part 112 – Oil
Pollution Prevention. The Plan:
– Applies to any facility that has or could discharge oil in
harmful quantities
• 1,320 above ground storage
• 42,000 under ground storage
• Containers <55 gallons not included in storage tally
SPCC Plans
– Should reduce the physical and environmental hazards
from storage & distribution of oil to navigable waters
– Should be preventative rather than reactive
– Should be updated every 5 years or when Plan changes
Note: Includes petroleum and non-petroleum oils (i.e.
animal fats)
SPCC Plans
• Duke has five SPCC Plans
•
•
•
•
•
Steam Plant
Transportation
Medical Center
Campus
Marine Lab
SPCC Plans
• The Plan is broken down into twelve
sections that detail the following:
– General Location Map
– Oil Storage Locations
– Appendices
–
–
–
–
–
–
Checklists
Review & Revision Records
Training Records
Cross Reference to 40 CFR 112
Spill Response Supplies & Inventory
OESO Spill Response Policy
General Facility Information
• Names the Facility
• Specific facility location including
longitude & latitude
• Describes the process of the facility
• Names the Spill Plan Team and where the
Plan is located.
General Facility Information
• Plan Coordinator
• Personnel designated by University & Medical
Center
• Members
• Duke University Spill Team
• E&O/FMD Trained Personnel
• Contractors Trained to Duke’s Plans requirements
Petroleum Storage Facilities
• Describes all oil storage and handling
facilities covered under the Plan (including
used cooking oil)
• Describes any modifications and
implementation schedules necessary to be in
compliance with the regulations
Spill Events, Containment
Structures, & Spill Migration
• Describes the locations of the nearest
navigable water
• Describes the predicted potential spill
scenarios, spill quantities, flow rates, and
spill destinations if a storage vessel
described in Section 2 had a release.
Spill Prevention Measures
• Describes the practices and procedures in
place at the facility to minimize the risk of
spills and leaks of petroleum products.
Secondary Containment – Tanker
Unloading
Petroleum Product Spill
Containment and Cleanup
• Describes the types and the locations of
spill response materials and appropriate
response measures
• Includes initial notification procedures and post
response activities
Notification of Spill Events
• Contains the information for internal and
external reporting of a release.
• The campus police should be notified first
• The police shall then notify the correct people
beginning with the Spill Response Team.
– The Plan Coordinator or the Director of
Environmental Programs will notify external
agencies, if necessary.
Inspections & Testing
• Describes required equipment inspections,
frequency, and the required or
recommended test method
Plan Review & Amendment
• Plan must be reviewed at least every 5 years
by a professional engineer or whenever
there is a change in facility design,
construction, operation or maintenance that
has the potential to impact the nature or
quantity of a discharge.
Recordkeeping
• Details the type of records and procedures
that MUST be signed, dated and kept on file
at the facility for a period of 3 years.
• Details the records that MUST be retained
for the life of the tank, piping, or ancillary
system.
Training
• All operating and maintenance personnel involved
in the storage and handling of petroleum shall
receive instructions on the Plan
• All spill response personnel shall receive
instruction to insure adequate understanding on
the Plan.
• Training shall occur at least once a year and more
frequently if a spill occurs or inspections reveal
inadequacies in implementation of the plan.
Security & Lighting
• Describes procedures in place to ensure that
access to the storage areas is controlled and
storage areas are monitored at all times.
Plan Implementation
• Majority of fuel storage areas serve diesel
emergency generators dedicated to a
particular building or parking garage.
• Golf Course, Duke Gardens, FMD Grounds,
and Duke Forest have fuel oil storage areas
for equipment fueling
Plan Implementation
• Fuel deliveries
1. will be scheduled by the
supervisor responsible for the
facility.
Plan Implementation
2. Delivery truck will back into
containment area adjacent to the tanks
prior to dispensing fuel (unless site has
built in secondary containment).
Plan Implementation
3. Maintenance Staff will use the
SPCC Checklist to record the
amount of fuel delivered.
Plan Implementation
INSPECTIONS & TESTING
ROUTINE EQUIPMENT CHECKS
•
•
Maintenance Staff familiar with the storage tanks and their operation should
make the following weekly checks of oil storage areas (i.e. any area storing
>55 gallons) as part of routine observations or preventive maintenance
procedures:
–
Check secondary containment for damage and integrity (will not leak);
–
Check tanks, foundations and supports for obvious signs of leakage, distortion, or other damage; and
–
Check piping systems, particularly at connections for obvious signs of leakage.
Note: Any problems observed must be reported to the SPCC Coordinator or designee
Plan Implementation
INSPECTIONS & TESTING
FORMAL INSPECTIONS
•
An SPCC inspection program has been designed to insure continued integrity of all oil
storage and handling equipment. Inspections of all oil and used oil storage areas are
conducted quarterly and/or annually in accordance with the schedule and requirements
included in Table 2 of the plan. Records of inspections are to be signed by the inspector
and maintained for at least three (3) years. Any problem detected during a formal
inspection requires immediate notification of the SPCC Coordinator.
1.
2.
Quarterly Inspections
Annual Inspections
YES
GENERAL
Has there been any change in facility design, construction, operation, or maintenance since
the last inspection? If yes, update the SPCC plan accordingly.
Is there any new petroleum bulk storage at the DUMC?
SPILL CLEANUP SUPPLIES
Are the Spill Kits located in the areas identified in Section 5?
Do the kits contain the items identified in Section 5 at a minimum?
TANKER UNLOADING
Are procedures in place to ensure a trained employee is present for the entire filling
operation?
Are procedures being followed to ensure adequate tank capacity such as manual tank level
gauging?
Is there a physical barrier available, such as a chock, to prevent premature tanker truck
departure in place?
Are drip pads readily available for placing beneath each connection?
Any sign of tanker leaks?
OIL STORAGE AREAS
Is documentation on file verifying the accuracy of tank float gauges or electronic
monitoring systems within the last year?
Are the tanks and all associated valves and piping in good condition and free from leaks and
excessive corrosion?
Are all tanks without double walls stored in appropriate locations inside the containment
dikes, such that any spill will be contained?
Are the dikes or double walls in good condition, showing no signs of leaks, damage, or
excessive wear?
NO
COMMENTS
Plan Implementation
• Quarterly Inspections
• Spill supplies are checked on a quarterly basis to ensure the supplies
are adequate and all materials are properly stored.
• In addition, all oil storage and transfer areas are to be inspected on a
quarterly basis to ensure the following:
–
–
–
–
–
–
Containers are in good condition and are overpacked if necessary;
Containers are properly labeled;
Containers are stored in appropriate locations identified in the SPCC Plan;
Appropriate secondary containment is provided where required;
Adequate space is maintained in storage areas for maneuvering of drums, handcarts, or forklifts, as
appropriate;
Spill kits are adequately stocked and appropriately located;
Plan Implementation
• Quarterly Inspections- cont.
–
–
–
–
–
Procedures outlined in the SPCC Plan are adhered to;
Piping systems, tanks, and transfer equipment are in good condition;
Repairs are made at the storage locations as required;
Quarterly inspections are documented using the form in Appendix 1; and
Records of such inspections and any associated repairs are kept with the master copy of the SPCC Plan
by the SPCC Coordinator.
Plan Implementation
• Annual Inspections
• In addition to the quarterly inspection requirements listed above, the
annual inspection includes the following general activities which are
also recorded on the inspection checklist included in Appendix 1:
–
–
–
–
Annual equipment inspection and maintenance requirements as described in the inspection checklist in
Appendix 1;
Confirm that SPCC procedures are being followed and that they are adequate for the university;
Ensure that the university maintains the capability to respond to releases; and
Ensure that records are being retained as described in Section 9.0.
Plan Implementation
• Testing
• In addition to regular inspections, the university will conduct tank and
piping integrity testing and internal tank inspections by an inspector
who is authorized to perform the relevant tests (see Table 2).
• A signed report and recommendations will be submitted by the testing
agent following test completion and retained for the life of the tank.
• The test results will then be reviewed to determine subsequent testing
requirements or necessary repairs.
Plan Implementation
• Integrity Testing
• The testing and the minimum testing frequency that are required for
each tank or piping system to ensure continued integrity of the oil
storage and handling facilities, can be found in Table 2 of the Plan.
The following slide contains an excerpt from that table.
SOURCE
TANK TYPE
VISUAL
MONITORING
(Frequency)
CHECK INTERSTICE
FOR FUEL & WATER
(Frequency)
VERIFY PROPER
OPERATION OF LEAK
DETECTION SYSTEM
(Frequency)
YES - If equipped.
(Quarterly)
PRESSURE
TIGHTNESS TEST
WITH INERT GAS
(Frequency)
NOT REQUIRED
METAL LOSS
TESTING OR OTHER
NDE*
(Frequency)
NOT REQUIRED
(1)
Lennox–Baker
Children’s
Hospital – 500
gal diesel AST
Single-wall; tank
bottom NOT in
contact with support
surface and is visible
YES
(Quarterly)
NA
(2)
North Pavilion
– 5,000 gal
diesel AST
Single-wall; tank
bottom NOT in
contact with support
surface and is visible
YES
(Quarterly)
NA
YES - If equipped.
(Quarterly)
NOT REQUIRED
NOT REQUIRED
(3)
Center for
Living:
Aesthetics –
150 gal diesel
AST
Double-wall; outer
shell in contact with
support surface
YES
(Quarterly)
YES
(Quarterly)
YES - If equipped.
(Quarterly)
YES
(Every 10 years)
NOT REQUIRED
(4)
Center for
Living: Fitness
– 150 gal
diesel AST
Double-wall; outer
shell in contact with
support surface
YES
(Quarterly)
YES
(Quarterly)
YES - If equipped.
(Quarterly)
YES
(Every 10 years)
NOT REQUIRED
(5)
– (2) 30,000
gal diesel
USTs
UST's
NA
YES
(Per 40 CFR Part 280)
YES
(Per 40 CFR Part 280)
Consult 40 CFR Part 280
for Test and Frequency.
NA
(6)
OESO – 125
gal diesel AST
Double-wall; outer
shell in contact with
support surface
YES
(Quarterly)
YES
(Quarterly)
YES - If equipped.
(Quarterly)
YES
(Every 10 years)
NOT REQUIRED
(7)
Duke South
Medical
Center: West
Entrance –
2,000 gal
diesel UST
UST's
NA
YES
(Per 40 CFR Part 280)
YES
(Per 40 CFR Part 280)
Consult 40 CFR Part 280
for Test and Frequency.
Required for cathodic
protection systems.
Complete per 40 CFR Part
280 for cathodic
protection systems.
Plan Implementation
• Record Keeping
• The following records and procedures must be signed, dated and
retained for a minimum of three years:
–
–
–
–
–
Inspections and testing procedures;
Records of scheduled inspections and any corrective actions taken.
Equipment maintenance records;
Records of visual inspection of discharges from diked containment area; and
Records of employee training and annual briefings.
Plan Implementation
• Training
• The SPCC Coordinator shall see that all operating and maintenance
personnel involved in the storage and handling of petroleum receive
instructions on the following:
– Operation and maintenance of equipment to minimize risk of equipment
failure and subsequent release;
– Good Housekeeping Practices which ensure a clean, safe, workplace and
minimize the risk of spills and leaks;
– Location and use of all spill control materials;
– Spill Prevention and Response; and
– Emergency notification procedures.