Marty' spcc plan power point

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Marty' spcc plan power point

  1. 1. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCSpill Prevention ControlCountermeasure Regulation40 CFR 112Presented by Martin Bonnell, PEJanuary 15, 2013
  2. 2. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCPRESENTATION OVERVIEW• Introductions• Who needs a SPCC Plan & what is covered?• State and Federal Regulations• How is a SPCC Plan used and maintained?• What to do in the event of a product spill• Questions & Discussion
  3. 3. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCWho Needs a SPCC PlanOwners or operators of petroleum facilities that havedischarged or, due to their location, could reasonably beexpected to discharge oil in harmful quantities into or uponthe navigable waters of the United States or adjoiningshorelines to prepare, in writing, an SPCC Plan.
  4. 4. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCSPCC REQUIREMENTS• If the facility total aboveground storage in tanks orcontainers is > 1,320 gallons and/or > 42K galunderground storage (not 280/281 exempt)• It’s a non-transportation related facility (see 40 CFR Part112 Appendices A & B)• And there is a reasonable chance of a discharge towaters of the U.S. or adjoining shorelines
  5. 5. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCDEFINITIONS• Oil– Includes oil of any kind or in any form including, but not limitedto:• Petroleum and fuel oils (gasoline, diesel, lube oils, aviation gasoline,naphtha, mineral spirits, etc.)• Sludge• Synthetic oils– Created by chemical synthesis
  6. 6. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCDEFINITIONS• Oil (cont’d)– Oil refuse– Oil mixed with wastes other than dredged spoil– Animal fats, oils & greases– Vegetable oils– Mineral oils
  7. 7. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCDENATURED ETHANOL• Denatured ethanol tanks are considered oil storagecontainers if the denaturant is an oil such as refinedgasoline or natural gasoline• Shell capacity of tank used as storage capacity• These facilities may be subject to the SPCC & FRPrequirements
  8. 8. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCNON-TRANSPORTATION-RELATED FACILITIES• Industrial, commercial, agricultural, or public facilitieswhich use, store, drill for, produce, gather, process,refine or consumer oil or oil products• Waste treatment facilities or part thereof• Pipeline systems, highway vehicles & railroad cars usedto transport oil exclusively within a facility
  9. 9. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCEPA Regulates:• Railroad cars after the transportation process ends andwhen they are operated as non-transportation-relatedstorage at an SPCC regulated facilityDOT Regulates:• Railroad cars from the time the oil is offered fortransportation to a carrier until the time it reaches itsdestination and is accepted by the consignee
  10. 10. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLC“REASONAL EXPECTATION” OF DISCHARGE• The determination must be based solely uponconsideration of the geographical & locational aspects ofthe facility• Exclude manmade features such as dikes, equipment orother features which would restrain, hinder, contain orotherwise prevent a discharge as described in 112.1(b)
  11. 11. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLC“REASONAL EXPECTATION” (CONT.)• Factors to consider:– Whether a past discharge of oil reached a navigable water oradjoining shoreline;– Whether the facility is adjacent to navigable waters or adjoiningshoreline;– On-site conduits, such as sewer lines, storm sewers, certainunderground features (e.g., power or cable lines, orgroundwater);
  12. 12. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLC“REASONAL EXPECTATION” (CONT.)• Factors to consider:– Unique geological or geographic features;– Whether the facility is near a watercourse & intervening naturaldrainage;– Whether precipitation runoff could transport oil into navigablewaters;– The quantity & nature of oil stored
  13. 13. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCSTORAGE CAPACITY THRESHOLDS• IF it meets the other applicable criteria set forth in112.1, the SPCC rule applies to a facility with:– > 1,320 gallons of aggregate aboveground oil storage capacity,or– > 42,000 gallons of completely buried oil storage capacity
  14. 14. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCSTORAGE CAPACITYIncluded in storage capacity• Capacity of containers (e.g., bulkstorage containers, oil-filled equipment,mobile/portable containers, etc.) with acapacity of 55 gallons or greaterExcluded from storage capacity• Capacity of completely buried tanks& associated underground piping,ancillary equipment & containmentsystems that are subject to alltechnical requirements of 40 CFRpart 280 or 281• Capacity of tanks used exclusively forwastewater treatment• Capacity of containers that arepermanently closed• Motive power containers
  15. 15. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCDEFINITION OF STORAGE CAPACITY• “Storage capacity” is defined in 112.2 as the shellcapacity of a container• Generally, the shell capacity is the rated design capacityrather than the working/operational capacity
  16. 16. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCDEFINITION OF “PERMANENTLY CLOSED”• For a tank to be “permanently closed”, the facility mustdo the following:– Remove all liquid & sludge from each container & connectingline– Disconnect & blank off all connecting lines & piping– Close & lock all valves (except ventilation valves)– Pose a conspicuous sign on each container stating it ispermanently closed with the date of closing• Tanks can remain on site, but they are not included inthe total storage capacity
  17. 17. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCSPCC Plan Basics
  18. 18. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCSECONDARY CONTAINMENT REQUIREMENTS• Tank secondary containment requires 110 percent of the volume ofthe largest tank contained within the dike with the displacementvolumes of the tanks accounted for.• Secondary containment needs to allows for additional freeboard forcontainment of precipitation in the containment dikes.
  19. 19. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCSecondary Containment
  20. 20. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCSecondary Containment
  21. 21. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCDrum Containment
  22. 22. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCRACK SPILL PAD CONTAINMENT• If transport truck makes hard connect to tank – the tank has a“Rack” and must have spill pad containment.• Spill Pad containment must be large enough to contain the largestcompartment of the truck unloading at the petroleum facility.
  23. 23. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCSpill Pad Containment
  24. 24. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLC112.3 PREPARE & IMPLEMENT A PLAN• The facility owner/operator must prepare a SPCC Plan:– In writing– In accordance with 112.7 & any other applicable sections of 40CFR part 112
  25. 25. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLC112.3(c) MOBILE FACILITIES• Onshore & offshore mobile facilities must prepare,implement & maintain a Plan as required by the rule– Amend & implement a Plan, if necessary to ensure compliancewith the rule, on or before 11/20/09– Can be a general Plan; a new Plan is not required each time afacilities moves to a new site
  26. 26. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLC112.3(d) PE CERTIFICATION• A licensed PE must review & certify a Plan & technicalamendments• The certification does not relieve the owner/operator ofhis duty to prepare & fully implement a Plan
  27. 27. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCPE “ATTESTATION”• With certification, the PE attests that:– PE is familiar with the rule requirements– PE or his agent visited & examined the facility– The Plan has been prepared in accordance with goodengineering practice, including the consideration of applicableindustry standards, & with the requirements of 40 CFR part 112– PE allow flexibility in meeting many rules provisions by providingequivalent environmental protection or developing contingencyplans.– Procedures for required inspections & testing have beenestablished– The Plan is adequate for the facility
  28. 28. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLC112.3(e)(1) PLAN REQUIREMENTS• Maintain a complete copy of the Plan:– At the facility if it is attended at least 4 hours per day– At the nearest field office if the facility is attended for less than 4hours per day• Have the Plan available to the RA for onsite reviewduring normal working hours
  29. 29. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCPLAN REVIEW & EVALUATION• Complete once every 5 years from the date facilitybecomes subject to the rule– If a facility was in operation on or before 8/16/2002, 5 years fromthe date of your last review required by the rule• Amend Plan within 6 months to include more effectiveprevention & control technology• Implement ASAP, but no later than 6 months ofamendment
  30. 30. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCDOCUMENTING PLAN REVIEW• Must document Plan review & evaluation• Sign statement at beginning or end of Plan or in a log oran appendix– “I have completed review & evaluation of the SPCC Plan for(name of facility) on (date), and will (will not) amend the Plan asa result.”• PE must certify any technical amendment to Plan– Qualified Facilities exception
  31. 31. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCSmaller Oil Storage Facilities
  32. 32. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLC112.6 QUALIFIED FACILITY PLAN REQUIREMENTS• Smaller oil storage facility that is eligible for streamlined regulatoryrequirements– Self-certified SPCC Plan instead of one reviewed & certified by aProfessional Engineer– Streamlined integrity testing & facility security requirements• Must meet eligibility criteria to use alternative option• EPA’s recent amendment would divide this group of facilities intotiers– Requirements described here would apply to “Tier I” facilities
  33. 33. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLC112.6 QUALIFIED FACILITY PLAN REQUIREMENTS (CONT.)• EPA’s recent amendment would divide this group of facilities intotiers– Requirements described here would apply to “Tier II” facilities– Additional relief would be provided to “Tier I”
  34. 34. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCSELF-CERTIFICATION OPTIONFOR QUALIFIED FACILITIES• Allow facility owners that store <=10K oil & meet other“qualifying” criteria to self-certify their SPCC Plans, inlieu of review & certification by a PE• “Qualifying” criteria –– NO discharges for 3 years prior or since becoming subject to therequirements• Under this approach, owners may not deviate from anyrequirements under 112.7(a)(2) (can’t use EE) & maynot make impracticability determinations under 112.7(d)
  35. 35. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCREPORTABLE DISCHARGE HISTORY• A single discharge of oil to navigable water or adjoiningshorelines exceeding 1,000 gallons OR,• Two discharges to navigable water or adjoiningshorelines each exceeding 42 gallons within any 12month period• Count only the amount that reaches navigable water oradjoining shorelines
  36. 36. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCREPORTABLE DISCHARGE HISTORY (CONT.)• Oil discharges resulting from natural disasters, acts ofwar, or terrorism are not included• Sabotage & vandalism are not beyond facilities control• Self-certifying facilities do not automatically lose eligibilityif they have a reportable spill, the RA has the authority torequire a Plan amendment
  37. 37. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCSELF-CERTIFICATION• Owner/operator attests they are familiar with the rule &have visited & examined the facility• The Plan has been prepared in accordance withaccepted & sound industry practices & standards• Procedures for required inspections & testing have beenestablished• The facility meets the qualifying criteria
  38. 38. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCSELF-CERTIFICATION (CONT.)• The Plan does not deviate from rule requirements exceptas allowed & as certified by a PE• The Plan & staff responsible for implementing it have thefull approval of management & the o/o has committedthe necessary resources to fully implement the Plan• The Plan is being fully implemented
  39. 39. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCTECHNICAL AMENDMENTS• May self-certify technical amendments as long as a PEhas not certified the portion being changed• If a PE certified the affected portion of the Plan, then aPE must certify the technical amendment
  40. 40. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCDrum Containment
  41. 41. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCTank Containment
  42. 42. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCTIER I SUMMARYAnd a facility… Then the owner/operator of the facility…If a facility……has 10,000gallons or lessin aggregateabovegroundoil storagecapacity…meets the oildischarge historycriteria…may prepare a self-certified SPCC Plan instead ofone reviewed & certified by a ProfessionalEngineer (PE)…may meet tailored facility security & tankintegrity inspection requirements without PEcertification…may prepare a Plan which includes PE-certifiedenvironmentally equivalent measures orimpracticability determinations that would requirePE certifications for only the portions dealing withenvironmental equivalence & impracticabilitydeterminations. The remaining portions of thePlan could be self-certified by the facilityowner/operator
  43. 43. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCASSISTANCE, SERVICES & PRODUCTS• Brams Engineering Services– Assistance drafting SPCC plans– Inspects and Prepares SPCC Plans– Prepares Tier I SPCC Plans for Owner/Operator Self Certification– Prepares Tier II SPCC Plans for Owner/Operators– Designs Tank Containment Basins– Responses to EPA Violation Letters
  44. 44. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCU.S. EPA – Penalties & Fines
  45. 45. Martin Bonnell, PE ◊ Senior Civil Engineer ◊ 952-261-9351 ◊ martybonnell@charter.netBRAMSENGINEERINGLLCQUESTIONS & CONTACT INFOMartin Bonnell, PESenior Civil EngineerBrams Engineering, LLC172 Spruce DriveApple Valley, MN 55124952-261-9351martybonnell@charter.net

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