The Federal Spill Prevention, Control, & Countermeasures Compliance Workshop

1. The FederalSpill Prevention, Control, & Countermeasures Compliance Workshop October 2008 Presented by:

2. Spill Prevention, Control, & Countermeasures Rule • Review the federal regulation • Program history • Basic rule definitions • Who must comply • SPCC Plan requirements • Emergency Response & Notification Workshop and Goals

3. Spill Prevention, Control, & Countermeasures Rule • Enforcement/Penalties • Common violations • Tips on how to comply • Compliance dates • Reference material • Highlight assistance available Workshop and Goals

4. Spill Prevention, Control, & Countermeasures Rule • The Federal Environmental Protection Agency (EPA) regulates the Oil Pollution Prevention and Response Regulation (40 CFR 112) in Vermont New England Regional I Office - Boston, MA - regulate, inspect & enforce the rule

5. Spill Prevention, Control, & Countermeasures Rule • Oil Pollution Prevention and Response Regulation • Outlines requirements for prevention, • preparedness, and response to oil discharges • Prevention requirements are called the • “SPCC rule” • Includes requirements for Facility Response • Plans (FRPs)

6. What is the purpose of a SPCC Plan? • The purpose of the SPCC rule is to prevent discharges of oil into U.S. waters.

7. It’s not Rocket Science

8. Program history • 1970: Executive Order 11548 • 1972: Clean Water Act • Develop / implement facility-specific Spill Prevention, Control and Countermeasure (SPCC) Plans

9. Program history • Multiple revisions have been made: 1991, 1993, 1997, 2002, 2006 • Changes allow for more flexibility • If your SPCC Plan is older than 6 years, it is probably not compliant

10. Definitions What is an “oil”? • Any kind, in any form, including: heating oils, motor fuels, lubricating oils, cutting oils, quenching oils, hydraulic oils, transformer oils and cooking oils.

12. Definitions • "Navigable Waters" includes, but is not limited to: harbors, lakes, rivers, brooks, ponds, streams, and wetlands. • Or any swale or ditch that could convey water.

13. Who must write a plan? • Non-transportation facilities • Facilities that store oil aboveground in containers greater than 55-gallons with an aggregate volume greater than 1,320-gallons; or

14. Who must write a plan? • Facilities that store oil below ground - “not otherwise regulated” with a total aggregate volume of 42,000 gallons; and • Facilities that could reasonably be expected to discharge oil to a "navigable water of US" or "adjoining shorelines".

15. Is the facility considered non-transportation related? yes no Is the facility gathering, storing, using, processing, consuming, drilling, transferring, or distributing oil? no yes Could the facility be expected to discharge oil that may be harmful to U.S. waters? no Not subject to SPCC yes yes no Is the total above ground capacity of oil over 1,320 gals? __________________ Do not include containers that are permanently closed, less than 55-gals, motive power, or exclusively used for wastewater treatment. no Is the total underground capacity of oil over 42,000 gals? _________________ Do not include permitted USTs. yes The facility is subject to SPCC

16. Who can write a plan? • The plan has to be certified by a registered Professional Engineer, with the exception: • 10,000 gallons or less can self-certify if: • No reportable* discharges within last 3 years * Reportable discharge = 1,000 gallons or 2 discharges exceeding 42 gallons within 12 months; and

17. Who can write a plan? • Plan cannot include any impracticability determination or deviate from any requirement of the SPCC Plan rule.* *The impracticability determination provision may be used when a facility is incapable of installing secondary containment by any reasonable method and for operational equipment. - December 2006 Amendment

19. SPCC Plan Requirements • Introduction • Facility description • Storage Tanks / Containers • Spill History • Spill Containment & Prevention • Spill Prediction & Direction • Stormwater Discharge • Deliveries & Unloading Procedures • Flood Hazard • Inspections, Testing & Records • Spill Control & Countermeasures • Emergency Response & Notification • Facility Security • Personnel Training • Plan Review & Amendment Procedures • Plan Implementation Items

20. SPCC Plan Requirements • Introduction • Emergency contact/notification list • Immediate spill response procedure • Oil Policy Statement • Applicable Regulations Rule Cross Reference – Table 1 Management approval form – Appendix A

21. Table 1

22. Appendix A

23. SPCC Plan Requirements • 2. Facility Description • General Information • Detailed facility description (operations) Include facility layout and drainage patterns • Include all AST and UST areas and add a map of your location – Figures 1 & 2

24. Figure 1

25. SPCC Plan Requirements • 3. Storage Tanks / Containers • Describe all containers, include contents and volume, note where they are located. • Add a map with their locations - Figure 2 • Tank & container descriptions - Table 2

26. Figure 2

27. Table 2

28. SPCC Plan Requirements • 4. Spill History • Describe facility spill events in this section. Include your spill documentation form – Appendix B • *note: Qualified facilities must review spill history but are no longer required to document spills under the threshold.

29. Appendix B

30. SPCC Plan Requirements • 5. Spill Containment & Prevention • Describe facility oil storage • Types of containment provided • Describe how oil is transferred • Include containment calculations – Appendix C

31. Appendix C

32. SPCC Plan Requirements • 6. Spill Prediction & Direction • A summary of potential sources, types of failures, potential volumes, flow rate, direction of flow, and discharge prevention measures. • Spill prediction & direction - Table 3

33. Table 3

34. SPCC Plan Requirements • 7. Stormwater Discharges • Describe how stormwater flows off the property and where it may infiltrate or enter waters of the state. • Discuss your policy for cleaning out containment areas including oil/water separators. Containment drainage log - Appendix D

35. Appendix D – Dike Drainage Log

36. SPCC Plan Requirements • 8. Deliveries & Unloading Procedures • Commercial haulers / contractors responsibilities. Size of vehicles delivering • We recommend the 2-man rule for deliveries • Procedures found in Appendix E

37. Appendix E – Loading/Unloading

38. SPCC Plan Requirements • 9. Flood Hazards • Describe facility flood history and potential for flooding in the future. High risk or minimal?

39. SPCC Plan Requirements • 10. Inspections, Testing, & Records • Describe how you will provide visual inspections (daily, monthly, and annual) • Must document the inspections Checklist provided in Appendix D

40. Appendix D – Monthly Inspection Checklist

41. SPCC Plan Requirements • 10.2 Bulk AST Storage Tank Testing • Describe how you will provide visual inspections (daily, monthly, and annual) • Documentation is required Checklist provided in Appendix D Bulk AST testing schedule in Table 4

42. Appendix D – Monthly AST Checklist

43. Table 4

44. SPCC Plan Requirements • 10.3 UST Tank Testing • Describe how you will provide inspections (daily, monthly, and annual) • Incorporate UST, ERP self-certification information here • Documentation is required

45. SPCC Plan Requirements • 10.4 Records • These addition records should be maintained: • all test & maintenance performed on tanks/structures holding oil • all spills/leaks that occur, the corrective action taken, and plans for prevention Spill Records in Appendix D

46. Appendix D – Equipment Checklist

47. Appendix D – Spill Notification/Internal

48. SPCC Plan Requirements • 11. Spill Control & Countermeasures • Procedures taken by facility to mitigate or prevent any discharge or prevent any release from operational activities. Follow flow chart - Appendix F Spill Response Log - Appendix D

49. Appendix D – Spill Notification Form

50. SPCC Plan Requirements • 12. Emergency Response & Notification • With the facility protected to prevent / contain spills, it is unlikely oil would reach water. Still, emergency procedures are required. Emergency procedures flow chart - Appendix F