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SPCC: What You and Your Employees Should Know ARIPPA Pottsville, PA February 27, 2007

SPCC: What You and Your Employees Should Know ARIPPA Pottsville, PA February 27, 2007. Presented by Jenna Glahn and Carole Hamner. About Trinity Consultants. Trinity Consultants is an environmental consulting company headquartered in Dallas, Texas

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SPCC: What You and Your Employees Should Know ARIPPA Pottsville, PA February 27, 2007

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  1. SPCC: What You and Your Employees Should Know ARIPPA Pottsville, PA February 27, 2007 Presented by Jenna Glahn and Carole Hamner

  2. About Trinity Consultants • Trinity Consultants is an environmental consulting company headquartered in Dallas, Texas • Offer environmental consulting, environmental data management, BREEZE environmental modeling software, professional education services • 250+ employees at 20 offices across major markets of U.S.

  3. www.trinityconsultants.com

  4. SPCC CompliancePresentation Topics

  5. Presentation Topics • Spill Prevention Requirements • Federal SPCC Requirements • SPCC Plan Requirements • PADEP Spill Requirements • SPR Plan Requirements • Storage tank requirements • PADEP PPC Requirements

  6. SPCC Compliance In Pennsylvania Jenna Glahn February 27, 2007 trinityconsultants.com

  7. What is SPCC? • Spill Prevention, Countermeasure, and Control (SPCC) Rule found under 40 CFR 112 • Prevent environmental contamination • Specifically, of navigable waters of the United States or adjoining shorelines • Define actions taken to stop or control leaks • Describe clean up after leaks and steps to prevent reoccurrence

  8. Who is Subject? • SPCC Plans required for facilities with: • Aboveground storage capacity of oil > 1,320 gallons (count 55 gallons drums and bigger) • Non-transportation related • Reasonable expectation of discharge into navigable waters or shorelines • Streams, ponds, ditches, sewers, wetlands, etc.

  9. Federal SPCC Requirements

  10. Spill Prevention Control and Countermeasures (SPCC) • Oil Pollution Prevention (Jan. 1974) • Oil Pollution Act of 1990 (OPA 90) • EPA proposed revisions in 1992, 1997, and 2002

  11. AST > 660 gallons in single tank, 1,320 gallons total UST > 42,000 gallons Ambiguous concerning “use” and ‘facility’ AST > 1,320 gallons (containers > 55 gallons) Don’t count USTs complying with 40 CFR 280-281 Includes “use”, defines “facility” Summary of Changes Previous Rule Revised Rule

  12. Current and new facilities: 6 mo prep, 6 mo to implement P.E. certifies GEP, all plan amendments New facilities: prepare/implement prior to operations PE certifies plan meets 112, technical amendments only (<10K gal may self-certify) Summary of Changes (cont’d) Previous Rule Revised Rule

  13. Revise with a 1,000 spill or 2 reportable spills in 12 mos. Review every 3 years Plan must follow sequence in 112.7 Inspection records part of plan 2 Spills > 42 gallons Review every 5 years Deviations allowed Operations log okay Summary of Changes (cont’d) Previous Rule Revised Rule

  14. Visual inspection of tank sufficient for integrity testing No testing after field repairs Cathodic protection for buried piping required if warranted by soil conditions Must use visual plus another technique (hydrostatic, radiographic) Mandates testing after field repairs Buried piping replaced after August 6, 2002 must have cathodic protection Summary of Changes (cont’d) Previous Rule Revised Rule

  15. Required personnel training Required records of storm water bypass For petroleum and petroleum products only Mandates training for oil-handling employees NPDES records okay Adds Animal Fats, Vegetable Oils Summary of Changes (cont’d) Previous Rule Revised Rule

  16. SPCC Plan Requirements • Facility description and diagram showing storage locations/content • Predict direction, flow and quantity discharged • Follow rule sequence or provide cross-reference • Spill history • Tank and drum inventory • Containment/diversionary structures • List emergency equipment

  17. SPCC Plan Requirements • Contact list and phone numbers • Facility Response Coordinator, National Response Center (1-800-424-8802), Cleanup Contractors, and all appropriate Federal, State, and local agencies • Provide a contingency plan to enable a person to properly stop and contain a spill and/or report a discharge

  18. SPCC Plan Requirements • Facility operating and loading/unloading procedures • Inspection plans • Site security (fencing, lights, locks) • Training and recordkeeping procedures • Management approval • P.E. certification • Substantial Harm certification

  19. Containment / Training • Provide containment adequate to contain oil for cleanup • Dikes, berms, curbs, culverts, retention ponds, diversion ponds, sorbent materials • Annual discharge prevention training for all oil handling personnel • Operation and maintenance of equipment to prevent discharges; discharge procedure protocols; applicable pollution control laws, and the content of the facility’s SPCC Plan

  20. PE Certification • PE Must Attest That: 1) Familiar with SPCC requirements 2) He or his agent visited and examined the facility 3) Plan prepared in accordance with GEP 4) Procedures for inspections and testing have been established 5) Plan is adequate for facility

  21. Substantial Harm Certification • Reasonably expected to cause substantial harm to the environment • Transfer oil over water to/from vessels with total storage capacity > 42,000 gal. • Total oil storage capacity > 1 million gal. • Meet either criteria, prepare and submit a Facility Response Plan (FRP) or include certification of non-applicability in SPCC Plan

  22. Oil Spill Notifications (40 CFR 112.4) • Discharge > 1,000 gal. in a single event or > 42 U.S. gallons of oil in 2 events • Notice to PADEP and EPA w/in 60 days • Name, location, and description of facility • Max. storage capacity of facility • Corrective actions and countermeasures • Cause of discharge

  23. Other Notifications • Immediately contact NRC if harmful quantities of oil are released • Violate water standards, • Cause a film, sheen, or discoloration of water surface, or • Cause a sludge or emulsion to be deposited beneath water surface

  24. Current Status • Facilities now have until October 31, 2007 to update and implement their plans in accordance with the new rules (2/17/06 Federal Register Notice, 71 FR 8462) • Proposal to delay until July 1, 2009 • New facilities must have plans before operations

  25. Pennsylvania Spill Requirements

  26. PA Storage Tank and Spill Prevention Act (1989) • Developed and implemented • Tank regulations • Tank registration/annual fees • Certification of tank handling • Inspections • Procedures for reporting of releases and corrective action by tank owners • Established technical and operational standards for tank systems

  27. PADEP Rules • Pennsylvania’s Storage Tank and Spill Prevention Program (Title 25, Chapter 245) • Regulated substances include: petroleum AND hazardous substances (defined in CERCLA or EPCRA) • Register and pay annual fees for ASTs > 250 gallons (some exceptions)

  28. PA Specific Requirements (1 of 4) • Facility with total aboveground storage capacity > 21,000 gallons subject to Spill Prevention Response (SPR) • Requires annual downstream notifications (20 miles), input by emergency planning committee, and approval by the PADEP • Chapter 245, Subchapter F describes technical standards for ASTs • Chapter 245, Subchapter G describes a simplified program for small ASTs (<21K gal)

  29. PA Specific Requirements (2 of 4) • Visual inspection every 72 hours • No potential hazardous environmental conditions exist • Containment area for water accumulation • Monthly maintenance inspection • Inspection of the tank system exterior surfaces for deterioration and maintenance deficiencies • Keep monthly inspection report for 1 yr • In-Service inspection • Frequency – w/in ¼ of the corrosion rate life or 5 yrs from the previous inspection or installation

  30. PA Specific Requirements (3 of 4) • Provide secondary containment under the tank bottom and around underground piping • Permeability < 1x10-7 cm/sec at anticipated hydrostatic head, verified at the time of installation • Provide ASTs emergency containment • Permeability < 1 x 10-6 cm/sec at anticipated hydrostatic head, sufficient thickness to prevent released substance from penetrating containment structure for 72 hours • Contain 110% of the capacity of the largest tank

  31. PA Specific Requirements (4 of 4) • Transfers may not exceed the volume available in the receiving tank • Transfers must be monitored by designated personnel • Gauge or monitoring device with high level alarm • Labels consistent with industry standards • Written operations and maintenance plan • Preventative maintenance and housekeeping program

  32. Simplified Program for Small Tanks • Tanks < 21,000 gallons • Monthly maintenance and operations inspections (inc. method of leak detection) • Upgraded with secondary containment by 10/11/2007 (emergency containment by 2000) • Tanks > 5,000 gal or >1,100 gal storing highly hazardous substance • In-service inspections – every 10 yrs or at ¼ of the corrosion rate life

  33. Recordkeeping • Permanent records maintain for operational life of tank (+ 1 yr after removal) • Original tank system installation and modification records and design specs (+ manufacturer docs) • Permits issued • Notices of reportable releases • Third-party inspection reports • Temporary records (12 months) • Current registration certificates • Leak detection and routine maintenance records • In-service inspections

  34. Spill or Leak Response Chapter 245, Subchapter D • Complete an investigation of suspected releases as soon as possible; no later than 7 days after an indication of a release • If a release is detected: • Immediately contact a supervisor • Take action to stop and contain the spill • Immediately contact the Oil Spill Coordinator • Immediately initiate interim remedial actions necessary to prevent or address an immediate threat to human health or the environment

  35. Reportable Release (1 of 2) • Quantity or unknown quantity of regulated substance released to or posing an immediate threat to surface water, groundwater, bedrock, soil, or sediment • Does not include: 1) release to interstitial space of a double walled tank, or 2) petroleum release to an aboveground surface < 25 gal • Must be completely contained and recovered/removed within 24 hours

  36. Reportable Release (2 of 2) • Immediately report to NRC and state or local emergency planning committee, if hazardous substance or EHS released in quantities greater than or equal to its RQ • Also, immediately report to PADEP if: • > 10 gallons (or less if RQ is less): Hazardous waste liquids or liquids that become hazardous waste when spilled or discharged • > 500 pounds (or less if RQ is less): Solid hazardous waste or solids that become hazardous wastes when spilled or discharged • Any discharge (regardless of size) or spill of hazardous waste into waters of PA • Immediately notify DEP at (800) 541-2050

  37. Reporting Requirements • Provide written notice w/in 15 days to PADEP and each affected municipality • Prepare and submit two copies of site characterization report to PADEP w/in 180 days of reporting release • If remedial actions have not remediated the site, prepare and submit remedial action plan w/in 45 days of submitting site characterization

  38. Pennsylvania PPC Requirements

  39. PPC Plan • Develop/implement a Preparedness, Prevention, and Contingency (PPC) Plan (25 Pa Code 91.34) • Specifically requested as a condition of renewed NPDES permits • Identify potential sources of pollution expected to affect stormwater quality • See “Guidelines for the Development and Implementation of Environmental Emergency Response Plans” • Consider combining plans

  40. Speaker Contact Information Jenna Glahn Senior Consultant jglahn@trinityconsultants.com Phone: (215) 230-3519

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