Triumvirate Environmental OIL SPCC Planning

Oil Spill Prevention Control & Countermeasure (SPCC) Plans


2008 Roundtable SeriesRegulations Overview

& Best Management Practices


Roundtable Agenda

•

Overview of the Oil SPCC Regulations


What do you need to know?

•

Oil SPCC Plans are required under the Clean Water Act

•

Objective: To minimize the potential for releases to “waters of the U.S.”

•

Regulations: 40 CFR Part 112•

Federal vs. State regulation

•

Applicable to most, but not all facilities


What are “waters of the U.S.”

•

Wetlands•

Rivers

•

Lakes•

Streams (including intermittent streams)

•

Ponds•

Ocean

40 CFR 112.2 Definitions


What is the applicability criteria?

Based on containers or equipment with capacity 55 gallons or greater:

•

Underground Storage Tanks (USTs) - greater or equal to 42,000 gallons

•

Aboveground Storage Tanks (ASTs) - greater or equal to 1,320 gallons

Note: Refers to aggregate amounts of oil onsite40 CFR 112.1 General Applicability


What is regulated? -Categories of Oil

•

Petroleum oils–

Crude and refined petroleum products, asphalt, gasoline, fuel oils, mineral oils, naphtha, sludge, oil refuse, oil mixed with wastes

•

Animal fats and vegetable oils–

Lard, tallow, cod liver oil, corn oil, grapeseed oil, coconut oil, palm oil, peanut oil

•

Other non-petroleum oils–

Coal tar, silicon fluids, pine oil, turpentine, tall oils

40 CFR 112.2 Definitions


What are typical uses of oil?

•

Fuel oil for heating•

Hydraulic fluids for equipment (e.g., elevators)

•

Transformers•

Waste oil

•

Cooking oil/grease•

Diesel oil for generators

•

Gasoline for motorized vehicles and equipment


How do you calculate a facility’s storage capacity?

•

Thresholds apply to the storage

capacity

of containers, tanks as well as operating equipment

40 CFR 112.1(d)(2)(ii)


What are examples of oil-filled operational equipment?

•

Hydraulic elevators•

Transformers

•

Circuit breakers and electrical switches

•

Emergency generators (gen-sets)

•

Machining coolant systems

•

Gear boxes•

Heat transfer systems


What presents the potential for releases of oil to “waters of the U.S. ? •

Proximity to:–

floor drains or sumps

–

doorways–

sewer or storm drains

–

surface waters–

soils

•

Structural integrity of the container, tank or equipment

•

Handling and storage practices


How do facilities prevent or minimize the potential for oil releases?

•

Secondary containment –

required for all aboveground tanks, containers, and operating equipment

•

Implement best management practices:–

Inspections

–

Integrity testing–

Delivery procedures

–

Storage, transfer, handling procedures–

Employee training


What are appropriate containment and diversionary structures?•

Dikes, berms, retaining walls

•

Curbing•

Culverting, gutters

•

Weirs, booms•

Spill diversion ponds

•

Retention ponds•

Sorbent materials

40 CFR 112.7(c)(1)


Other secondary containment options are…

•

Double-walled tanks•

Spill pallets for drums and smaller containers

•

Impervious (concrete floor and wall joints

•

Trenches with no outlets


What is in a “good”

spill kit?•

Absorbent materials–

Pads, booms, speedi-dri

–

Enough material to contain the largest volume•

Appropriate PPE–

Gloves, boots, safety glasses, hard hat….

•

Emergency Contact List•

First Aid Kit–

Eye wash, hand cleaner, band-aids


What are typical facility policies for oil storage? •

Containers are properly labeled and stored upright or on drum cradles

•

Containers are properly handled and transported by trained personnel

•

Containers exceeding 55 gallons must have secondary containment

•

Spill equipment is maintained at oil and loading/unloading storage areas

Best Management Practices


What are other typical facility policies for oil storage?

• Drains near storage tanks must be plugged, capped, or covered (at least during filling/transfer operations)

•

Tanks, containers, and operating equipment are inspected monthly

•

Elevator reservoirs are inspected and maintained by a contractor

Best Management Practices


What about mobile/portable storage containers?

•

Must be temporary•

Must have secondary containment–

Construction sites

–

Tank replacement/ clean-out

40 CFR 112.3(c)


How often are inspections of oil storage containers and equipment performed?

•

In accordance with the schedule set forth in the facility’s Oil SPCC Plan

•

Dependent on volume and location•

Per industry standards (ANSI, etc.)

•

PE recommendation


How are inspections performed?

•

Per good engineering standards:–

On an established, routine schedule to determine leaks, spills, other deficiencies

–

Deficiencies are documented and reported–

Corrective measures are taken asap

and

documented•

Records must be kept for 3 years

40 CFR 112.7(e)


What do train my employees on?•

Contents of the facilities Oil SPCC Plan

•

What to do in an emergency?–

Cleanup procedures

–

Who you going to call?•

Where do the outfalls go?

•

Review of the locations of oil storage•

Review of the inspection procedures

•

Review of any spills/releases during the last year


What does EPA require for security measures?

•

Fully fenced or locked/guard gates •

Security measures to ensure valves remain closed

•

Secure loading/unloading connections when not in service

•

Provide facility lighting to prevent vandalism and assist in discovery of discharges

40 CFR 112.7(g)


So what is in an Oil SPCC Plan?

•

Complete oil storage container, tank and equipment inventory

•

Site plan with locations of all tanks, container and equipment

•

Procedures for bulk deliveries or transfers

•

Oil spill emergency response procedures

•

Emergency contacts•

Spill reporting procedures

•

Inspection schedule•

Description of employee training

•

Professional Engineer Certification or Self-

Certification


What is the Professional Engineer’s role?

•

Must certify that the plan meets regulatory requirements (secondary containment) and industry standards (tank integrity testing)

•

Note: Self-Certification is allowed if total storage quantity is <10,000 gallons


Key Points

•

Oil storage thresholds•

Types of oils regulated

•

Plan must be PE certified or Self- Certified (minimum every 5 years)

•

Inspections (typically monthly)•

Training (completed annually)


Thank you!


•

BREAK!!


DEP NotificationDEP Notification

20082008 Roundtable SeriesRoundtable Series October 30, 2008October 30, 2008


What are the notification requirements?

Massachusetts Contingency Plan Notification (Subpart C)

310 CMR 40.0300


Notification to DEP•

DEP does not

need to know about small

releases which are being cleaned up

•

DEP needs

to know about and tracks significant releases

There are triggers and thresholds above which releases come into our release tracking system….via Notification


Notification Purpose and Scope

MA Contingency Plan contains requirements and procedures for notifying the DEP of releases and threats of release of Oil and Hazardous Material (OHM)

–

ID releases which require notification–

Sets time periods–

Sets procedures


Who Must Notify DEP?

•

The owner or operator of a vessel where there has been release or threat of a release of OHM*

•

any person who arranged for transport, disposal, on-site storage of OHM*

•

any person who caused or is legally responsible for a release or threat of release of OHM*

* Oil or Hazardous Materials


Role of Licensed Site Professional (LSP) in Notification

•

Use of LSP is not required for Notification

•

LSP may make notification for Responsible Party

•

LSP should state that the notification is as LSP/Agent on behalf of Responsible Party


Required Release Notifications 310 CMR 40.0310

•

2 Hour notification requirements

•

72 Hour notification requirements

•

120 day notification requirements


2 Hour Notification

ASAP not more than 2 Hours from obtaining knowledge of release

•

Sudden release to the environment•

> Reportable Quantity (RQ), occurs within 24 hours

•

Quantity Unknown•

Causes sheen on surface water

•

Release to storm drain or to the environment via sanitary sewer

•

Release could pose Imminent Hazard


Imminent Hazard (2 hour notifications)

Releases defined to pose an Imminent Hazard(310 CMR 40.0321(1))

• Vapors in buildings, etc., > 10% LEL• Release of Reactive or explosive material• Roadway releases endangering safety• Releases producing immediate or acute

adverse impacts to fish populations

Releases which “could pose” an IH (310 CMR 40.0321(2))

• Contamination in private drinking water well• Contamination in surficial soil accessible to children


72 Hour Notification •

Release indicated by oil/insoluble chemicals >

½ inch

•

> 100 ppm headspace screening during UST Closure

•

Contamination identified

within–

Zone I of Public Supply Well

–

500 feet from private supply well–

Groundwater contamination within 30 feet school or occupied residential structure and groundwater < 15 feet below grade

•

Failed tank test of UST system•

Substantial Release Migration


Substantial Release Migration?

•

Contamination that migrates >200 feet/year

•

Contamination that has or likely (within 1 year) to:–

Contaminate water supply

–

Impact Indoor air–

Necessitate remedial actions at downgradient receptors


120 Day Notification

•

Release to the Environment indicated by:–

Contamination in soil or groundwater greater than Reportable Concentrations

–

Oil/insoluble liquid measured less than ½ inch


Common Types of Reportable Releases at Hospitals/Schools

•

Leaking fuel underground/aboveground storage tank system

•

Failed electrical transformer systems•

Leaking 55-gallon drum containers

•

Hydraulic oil releases from elevator systems•

Commercial vehicle accidents resulting in fuel releases

•

Improper disposal of OHM containing equipment into dumpsters

•

Soil contamination discovered during site redevelopment/construction activities

•

PCB soil contamination from building caulking


Notifying DEP

HOW?•

2 HR + 72 HR Notifications–

Orally by Telephone

•

120 Day Notifications–

Submit Release Notification Form

24 Hour Release NotificationLocal-617-556-1133

Toll Free 888-304-1133


Immediate Response Actions After Notification

•

Minimize longer term site disruption•

Reduce the potential exposure to site receptors

•

Clean up costs are significantly lower when responsible parties clean up spills quickly


DEP Notification Facts•

1400 to 1600 reportable releases were called into MA DEP per year from 1993 through 2006–

Exception: 2,640 reportable releases in 1998

•

75% of Reportable Releases are 2 Hour or 72 Hour

•

75% of Reportable Releases closed out within the 1st

year.


Guidance Tips on Cleanup Costs

The assessment and cleanup of an oil and/or hazardous material release is a step-by-step process. The answers to clean up costs will change as more information regarding the OHM release is discovered.

Spills that had time to spread to groundwater are significantly more expensive to clean up.


Spill Scenario #1

NON-PCB Transformer Oil Spill•

<50 gallons of oil released

•

10-20 cubic yards of impacted soil excavated and disposed at off-site recycling facility

•

Oil release limited to soil only•

Submit Regulatory Closure Report to MA DEP within 60 Days of Release

Estimated Clean-up cost is < $25,000


Spill Scenario #2

NON-PCB Transformer Oil Spill•

<50 gallons of oil released

•


•

Oil release limited to soil only; however, some testing of groundwater would be needed to confirm that the OHM did not affect it

•

Submit Regulatory Closure Report to MA DEP within 120 Days of Release

Estimated Clean-up cost is $25,000 to $50,000


Spill Scenario #3•

Non-PCB Transformer Oil Spill

•

>50 gallons of oil released•


•

Soil and groundwater contamination exists •

Regulatory Closure not obtained within 120 Days of Release

Estimated Clean-up cost is > $50,000


What Happens When DEP is Not Notified of a Reportable Release?

•

6/25/08: MassDEP entered into a Consent Order with a $30,000 Penalty involving an oil delivery company.

Consent Order encompasses two releases that happened within a three-month period. Company failed to notify, and conducting Immediate Response Action without approval.

•

6/9/08: MassDEP executed a Consent Order with a $5,000 Penalty regarding chromium plating operations company. The company failed to notify the Department, as required, when it gained knowledge of a condition of Substantial Release Migration (SRM).

•

3/19/08: MassDEP executed a Consent Order with a $9,000 Penalty regarding an industrial property owner. The owner failed to notify as required after a release of metals and PCBs.


Speakers Contact Information

•

Rick Foote•

Senior Environmental Compliance Advisor

•

Cell:617-686-6184•

Email:[email protected]

•

Mike Bricher•

Senior Environmental Engineer•

Cell: 508-328-1899•

Email:[email protected]


The End!

•

Let’s go Shoot' in!!!

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Triumvirate Environmental OIL SPCC Planning