Transcript Hazardous Waste Management Training

ANNUAL SPILL PREVENTION
CONTROL AND COUNTERMEASURE
TRAINING (SPCC)
Presented by:
Prepared for:
Stephen F. Austin
State University
February 2, 2012
Why Are We Here?
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Liability
SPCC Regulatory Compliance
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40 CFR Part 112
Preparation of a Spill Prevention Control
and Countermeasures (SPCC) Plan
Who Regulates Whom?
SPCC
Environmental Protection Agency
Region VI
Dallas, Texas
Region 6 Serves: Arkansas, Louisiana, New
Mexico, Oklahoma, and Texas
Liability
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Penalties are in addition to clean up costs
Fines as well as prison time possible
Disclosed SPCC findings during peer audit
program
Management Responsibility and
Accountability
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Emergency Coordinator(s)
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All Oil Handling Personnel
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Responsible for emergency response and reporting
Responsible for spill prevention and response on site
Management/ Administration
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Responsible for ensuring implementation and review of
plan
It is not enough to just have an SPCC Plan, the college
must follow and implement that plan.
Ensure review of plan every 5 years or with facility
changes.
Update plan within 6 months of change.
Emergency Coordinators
Name
Office Phone
24 hour phone
Sunil Chithiri
(936) 468-6034
(734) 223-6946
Jeremy Higgins
(936) 468-4532
(936) 715-5358
Mike Griffith
(936) 468-4442
(936) 552-9384
SPCC Purpose:
Prevent Oil Discharges from Reaching
Navigable Waterways defined as lakes,
rivers, streams, wetlands and adjoining
shorelines.
 Ensure effective response to oil
discharges
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Note: Oil is any kind or in any form but not limited
to petroleum, synthetic oils, mineral oils, fuel oils,
sludge, oil refuse, and used oil.
Who Does It Impact
(SPCC)?
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Facilities with >1,320 gallons of petroleum
product storage aboveground (containers, tanks,
and machines)
Underground storage tanks greater than 42,000
gallons provided the UST is not subject to
technical requirements of 40 CFR 280 or 281
No containers smaller than 55 gallons are
counted toward the 1,320 gallon capacity
Oil Storage at SFA
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Aboveground Storage Tanks (ASTs) (6)
Kitchen Grease Receptacle (2)
Emergency Generator Belly Tank (8)
55-gallon drums of Petroleum products (5)
Elevator Reservoirs (65)
Transformers (52)
Total Oil storage at SFA = 28,421 gallons
Requirements for Storage
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Bulk Storage – Any container used to store oil.
These containers are used for purposes including,
but not limited to, the storage of oil prior to use,
while being used, or prior to further distribution
in commerce.
• Examples at SFA: Fuel ASTs, emergency
generator belly tank, 55-gallon drums, Used Oil
ASTs, kitchen grease
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Oil-filled operational equipment – Any
equipment that includes an oil storage container
(or multiple containers) in which the oil is
present solely to support the function of the
apparatus or the device.
• Examples at SFA: elevators, transformers
Requirements for “Bulk” Storage
Manage Facility and Dike Drainage
 Provide Compatible Containers
 Provide Sized Secondary Containment
 Test containers for Integrity
 Avoid Discharges During Oil Transfers
 Correct Visible Discharges
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Requirements for “Bulk” Storage
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Manage Facility and Dike Drainage
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No oil can be discharged from the facility or
from the containment areas
Units on site are protected from accumulated
rain water
As necessary, document draining activities on
monthly inspection logs
*Sections 6.0 and 7.0
of the SPCC Plan
Requirements for “Bulk” Storage
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Provide Sized Secondary
Containment
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Most tanks at SFA are contained,
maintain a double walled system,
or are within a room that would
contain a leak or spill.
Kitchen grease containers need
containment.
*Table 1B and Section 6.2 of SPCC Plan
Requirements for “Bulk” Storage
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Test containers for Integrity
Monthly Visual Inspections (Appendix D)
 Routine Integrity Testing
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• Replace at end of useful life (55 gallon
drums) or as needed for tanks < 660 gallons
• Non-destructive testing
*Section 7 and Appendix D of Plan
Requirements for “Bulk” Storage
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Avoid Discharges During Oil Transfers
Ensure trained personnel are always in
attendance during filling operations
 Engineering protections include:
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• Fuel gauges
• Automatic cut-off systems
• High level alarms
*Tables 1B, 2 and 3
Requirements for “Bulk” Storage
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Correct Visible Discharges
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SFA must promptly correct all oil leaks and/or
discharges (IF SAFE!!)
Use Spill kits and absorbent materials:
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Grounds & Transportation Building;
Agricultural Research Center/Poultry Research Center;
Elevators at HPE Complex; and
On the mobile generator trailer
Notify the Emergency Coordinator and Security
Contact outside vendors as necessary
Complete Spill Reporting Form in Appendix C
*Sections 3 and 4 of Plan
Emergency Procedures
Refer to Spill Response Flow Chart at the end of
the training packet
*Section 4 of Plan
Requirements for Oil-Filled
Operational Equipment
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No sized secondary containment required
Need active or passive containment system
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Active – spill absorbent material, drain covers,
diversion valves, etc.
Passive – berms, containment dike, etc.
*Table 1A and
Section 6.2 of Plan
Requirements for Oil-filled
Operational Equipment
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Passive and active containment provided for elevators
All elevator contractors are to be notified of who to
contact in case of an emergency
Active containment available for transformers
Respond to any spills or leaks in the same manner as
described for bulk storage containers
Photos c/o Wikimedia and KnowHow In Action Belzona® Repairs
Leaking Transformer Fins
*Table 1A and
Section 6.2 of
SPCC Plan
Record Retention and Filing
Requirements
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All records should be maintained for
at least three (3) years
Completed Logs
 Annual Training Rosters
 Corrective Action Documentation
(completed work orders)
 Spill Reports
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*Sections 7 and 10, and Appendix C and H
of the SPCC Plan
Training Requirements
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Training Required Initially and Annually
thereafter
Training to include
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SPCC Plan details and recently developed
precautionary measures
Review of known discharges or failures, or
malfunctioning Components
O&M of equipment to prevent discharges
Discharge procedure Protocols
General Facility Operations
Applicable laws, rules, and regulations
*Section 10 of the Plan
Review Known Discharges,
Failures, or Malfunctions
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Within the last year:
Any known discharges???
 Any Additional sources???
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*Section 10 of the plan
SPCC Reporting
Requirements
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After a spill of >1,000 gallons, or after two spills
>42 gallons enters US Waters within any 12
month period, report must be filed in 60 days to
US-EPA Region 6 and TCEQ
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EPA will then conduct an inspection of the facility
and complete review of the SPCC Plan
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Federal Water Pollution Control Act- Any release
of a chemical in any amount must be reported to
TCEQ
*Sections 3 and 4 of Plan
THANK YOU
Shannon Lewis
[email protected]
HRP Associates, Inc.
1-800-752-3922
www.hrpassociates.com