Spill Prevention, Control and Countermeasure (SPCC) Training

Goals of SPCC Training Overview of the SPCC Requirements Summary of Harvard’s SPCC Plan Spill Prevention and Response Procedures Inspection Requirements Roles and Responsibilities Information Resources

Overview of the SPCC Requirements

Summary of Harvard’s SPCC Plan

Spill Prevention and Response Procedures

Inspection Requirements

Roles and Responsibilities

Information Resources

SPCC Requirements Required by EPA if a facility can “reasonably be expected to discharge harmful amounts of oil into navigable waters of the United States or adjoining shorelines”, and stores above certain threshold Required at Harvard due to oil storage volume throughout the University and at off-site locations and because oil can reasonably be expected to enter navigable waters

Required by EPA if a facility can “reasonably be expected to discharge harmful amounts of oil into navigable waters of the United States or adjoining shorelines”, and stores above certain threshold

Required at Harvard due to oil storage volume throughout the University and at off-site locations and because oil can reasonably be expected to enter navigable waters

Oil Regulated Under SPCC All petroleum based oils Fuel oil, motor oil, distillate oil, gasoline, hydraulic fluid Oil mixed with wastes Animal fats and oils Fish and marine mammal oils Vegetable oils Oils from seeds, fruits, nuts and kernels

All petroleum based oils

Fuel oil, motor oil, distillate oil, gasoline, hydraulic fluid

Oil mixed with wastes

Animal fats and oils

Fish and marine mammal oils

Vegetable oils

Oils from seeds, fruits, nuts and kernels

Containers Regulated Under SPCC Any current oil storage container 55 gallons or greater Bulk Storage - drums, tanks and containers Operational equipment - transformers, elevator tanks, electrical switches Any empty container 55 gallons or greater capable of storing oil and not rendered unusable

Any current oil storage container 55 gallons or greater

Bulk Storage - drums, tanks and containers

Operational equipment - transformers, elevator tanks, electrical switches

Any empty container 55 gallons or greater capable of storing oil and not rendered unusable

Harvard’s SPCC Plans Harvard has five (5) SPCC Plans: Cambridge/Allston Campuses Longwood Medical Campus Southborough Campus Concord Field Station Harvard Forest Copies of the Plans are Maintained at: EH&S offices at 46 Blackstone Street in Cambridge University Operations Center Security stations at off-site locations

Harvard has five (5) SPCC Plans:

Cambridge/Allston Campuses

Longwood Medical Campus

Southborough Campus

Concord Field Station

Harvard Forest

Copies of the Plans are Maintained at:

EH&S offices at 46 Blackstone Street in Cambridge

University Operations Center

Security stations at off-site locations

Contents of SPCC Plans Identify oil storage and use locations Tanks (above and underground) Hydraulic elevator systems Emergency Generators Electrical transformers and substations Electrical switches Pumps, gear boxes, bearings Waste Oil Satellite Accumulation Areas Waste cooking oil containers Designate responsibilities for implementation Establish spill prevention and response procedures

Identify oil storage and use locations

Tanks (above and underground)

Hydraulic elevator systems

Emergency Generators

Electrical transformers and substations

Electrical switches

Pumps, gear boxes, bearings

Waste Oil Satellite Accumulation Areas

Waste cooking oil containers

Designate responsibilities for implementation

Establish spill prevention and response procedures

Roles and Responsibilities Maintain signed copy of Fuel Delivery notice Conduct follow-up Ensure contractors are aware of SPCC Reporting requirements Maintain facility-specific oil storage/use information and provide updates to EH&S Determine need for regulatory reporting Assign and monitor monthly inspections Maintain training records Assess human health and environmental hazards and impacts Cleanup spills Ensure personnel are familiar with locations of spill equipment Coordinate with EH&S on SPCC Requirements Support spill incident report and follow-up Notify the Operations Center of any spills (617-495-5560) Ensure spill equipment is stocked Conduct and document inspections Monitor SPCC regulatory changes Provide spill response equipment Ensure personnel are trained Training for Staff Provides SPCC Training and Guidance Be familiar with SPCC requirements Update inventory for accuracy Ensure resource allocation Develop SPCC Plan Contractors/ Vendors Facility Managers Environmental Safety Compliance Officers EH&S

SPCC Device Inventory Harvard facilities are required to keep an accurate and up-to-date inventory of all SPCC devices Facilities must review the devices and inventory annually EH&S maintains a web-based Facility Equipment Inventory Management System (FEIMS) http:// www.uos.harvard.edu/redir/feims.html

Harvard facilities are required to keep an accurate and up-to-date inventory of all SPCC devices

Facilities must review the devices and inventory annually

EH&S maintains a web-based Facility Equipment Inventory Management System (FEIMS)

http:// www.uos.harvard.edu/redir/feims.html

SPCC Training Required for any Harvard employee involved in: Oil handling Transfer Storage Spill response Maintenance of oil equipment Managers or supervisors who have direct reports involved in the activities listed above Fuel oil delivery company employees

Required for any Harvard employee involved in:

Oil handling

Transfer

Storage

Spill response

Maintenance of oil equipment

Managers or supervisors who have direct reports involved in the activities listed above

Fuel oil delivery company employees

Spill Prevention Routine Inspections Monthly inspections of SPCC devices Maintenance and repairs Reporting all leaks Personnel Training All personnel handling oil must be trained upon hire Retraining must occur if there are changes to the Plan Alarms/Shutoff Valves Monitor leak detection and overfill protection systems Respond immediately to all alarms Do not leave monitoring system unsupervised Perform regular tests on monitoring systems

Routine Inspections

Monthly inspections of SPCC devices

Maintenance and repairs

Reporting all leaks

Personnel Training

All personnel handling oil must be trained upon hire

Retraining must occur if there are changes to the Plan

Alarms/Shutoff Valves

Monitor leak detection and overfill protection systems

Respond immediately to all alarms

Do not leave monitoring system unsupervised

Perform regular tests on monitoring systems

Spill Prevention Continued Fuel Deliveries Facility managers should ensure that all fuel delivery vendors receive the “Notice to Fuel Delivery Vendor” Maintain signed “Notice to Fuel Delivery Vendor” Must follow Tank Truck Delivery Procedures Harvard University personnel should be present and monitor fuel deliveries Immediately report any leakage or spillage to Harvard University’s Operations Center at (617) 495-5560

Continued

Fuel Deliveries

Facility managers should ensure that all fuel delivery vendors receive the “Notice to Fuel Delivery Vendor”

Maintain signed “Notice to Fuel Delivery Vendor”

Must follow Tank Truck Delivery Procedures

Harvard University personnel should be present and monitor fuel deliveries

Immediately report any leakage or spillage to Harvard University’s Operations Center at (617) 495-5560

Spill Prevention Continued Secondary Containment Must be an impervious material and contain a means of discharge (pipe with valve) that is able to be locked Required for oil containing devices by Harvard EH&S Transformers, electrical switches and elevator tanks are exempt from this requirement of SPCC

Continued

Secondary Containment

Must be an impervious material and contain a means of discharge (pipe with valve) that is able to be locked

Required for oil containing devices by Harvard EH&S

Transformers, electrical switches and elevator tanks are exempt from this requirement of SPCC

Spill Scenarios Potential spills at Harvard include: Damage to or release from oil delivery equipment during the loading/unloading of oil at fill stations Aboveground or underground tank failure Leaking or failure of drums or containers Overfill at a fill port Spillage during transfer from drums or tanks Leaking and/or failure of piping and pumps Leaking transformer

Potential spills at Harvard include:

Damage to or release from oil delivery equipment during the loading/unloading of oil at fill stations

Aboveground or underground tank failure

Leaking or failure of drums or containers

Overfill at a fill port

Spillage during transfer from drums or tanks

Leaking and/or failure of piping and pumps

Leaking transformer

Incidental Spills Definition: Spills of known materials that do not pose potential safety or health hazards (fire, explosion or chemical exposure) Spills that can be controlled and cleaned up at the time of release by employees in the immediate area or by maintenance personnel Spills that do NOT impact the environment Management Do not endanger yourself or others Use proper personal protective equipment (gloves, goggles, etc.) while cleaning up the spill Dispose of the waste properly and in accordance with Harvard’s Hazardous Waste procedures

Definition:

Spills of known materials that do not pose potential safety or health hazards (fire, explosion or chemical exposure)

Spills that can be controlled and cleaned up at the time of release by employees in the immediate area or by maintenance personnel

Spills that do NOT impact the environment

Management

Do not endanger yourself or others

Use proper personal protective equipment (gloves, goggles, etc.) while cleaning up the spill

Dispose of the waste properly and in accordance with Harvard’s Hazardous Waste procedures

Non-Incidental Spills Definition: A spill that causes material to reach the environment through a floor drain, storm drain, or the ground surface A major spill or release Quantity greater than 10 gallons of oil or a product that cannot be readily absorbed, neutralized, or otherwise controlled at the time of release Any quantity of spilled or released material which is unknown to personnel or the potential or actual health and safety hazards are unknown An actual or suspected injury has occurred as a result of the spill or release Immediately report Non-Incidental Spills to the University Operations Center at (617) 495-5560

Definition:

A spill that causes material to reach the environment through a floor drain, storm drain, or the ground surface

A major spill or release

Quantity greater than 10 gallons of oil or a product that cannot be readily absorbed, neutralized, or otherwise controlled at the time of release

Any quantity of spilled or released material which is unknown to personnel or the potential or actual health and safety hazards are unknown

An actual or suspected injury has occurred as a result of the spill or release

Immediately report Non-Incidental Spills to the University Operations Center at (617) 495-5560

Response Procedures In the event of a spill: Isolate area to protect people Identify the source of the spill Note the material and quantity spilled Identify potential hazards Protect potential receptors (storm drains, sumps, floor drains and soil) Clean up incidental spills Ask facility operations for location of nearest spill kit Call for help if you are unable to clean the spill

In the event of a spill:

Isolate area to protect people

Identify the source of the spill

Note the material and quantity spilled

Identify potential hazards

Protect potential receptors (storm drains, sumps, floor drains and soil)

Clean up incidental spills

Ask facility operations for location of nearest spill kit

Call for help if you are unable to clean the spill

Spill Response Supplies Speedi-dry Sorbent booms and socks Oil absorption pads Spill mats for covering storm drains/floor drains Protective gloves, suits, safety glasses or goggles Caution tape Shovels/collection drums

Speedi-dry

Sorbent booms and socks

Oil absorption pads

Spill mats for covering storm drains/floor drains

Protective gloves, suits, safety glasses or goggles

Caution tape

Shovels/collection drums

Inspections Monthly documented inspections are required for: Aboveground Storage Tanks Bulk Storage Containers Drums – 55 gallons or greater, including kitchen grease drums. Underground Storage Tanks which are used for heating on site Conduct Best Management Practice inspections on: Transformers Hydraulic Elevator Systems and Lifts Electrical Switches Grease traps Oil/Water separators Records must be kept on site for 3 years

Monthly documented inspections are required for:

Aboveground Storage Tanks

Bulk Storage Containers

Drums – 55 gallons or greater, including kitchen grease drums.

Underground Storage Tanks which are used for heating on site

Conduct Best Management Practice inspections on:

Transformers

Hydraulic Elevator Systems and Lifts

Electrical Switches

Grease traps

Oil/Water separators

Records must be kept on site for 3 years

Tank Testing Formal inspections by qualified inspectors and leak testing are required every 10 years for tanks greater than 1,100 gallons Integrity testing must be conducted under the following conditions: Regular schedule or when repairs are made to a tank On an interval not greater than 10 years Testing will be in accordance with general industry guidelines and by a qualified tank inspector Records of all testing must be maintained by the tank owner

Formal inspections by qualified inspectors and leak testing are required every 10 years for tanks greater than 1,100 gallons

Integrity testing must be conducted under the following conditions:

Regular schedule or when repairs are made to a tank

On an interval not greater than 10 years

Testing will be in accordance with general industry guidelines and by a qualified tank inspector

Records of all testing must be maintained by the tank owner

Security Containers must be located in areas that are accessible only to authorized personnel Lighting must be sufficient to enable the discovery of spills during hours of darkness and to prevent spills occurring through acts of vandalism

Containers must be located in areas that are accessible only to authorized personnel

Lighting must be sufficient to enable the discovery of spills during hours of darkness and to prevent spills occurring through acts of vandalism

Common SPCC Violations Untrained personnel Failure to report a spill to the environment Lack of an adequate SPCC Plan Inadequate secondary containment Lack of procedures and control measures to prevent a spill from reaching the environment

Untrained personnel

Failure to report a spill to the environment

Lack of an adequate SPCC Plan

Inadequate secondary containment

Lack of procedures and control measures to prevent a spill from reaching the environment

Communications Internal: EH&S will communicate regulatory changes through the SPCC Management Coordinators Emergencies: Immediately contact the University Operations Center (617) 495-5560 Go to the next slide for more SPCC resources

Internal:

EH&S will communicate regulatory changes through the SPCC Management Coordinators

Emergencies:

Immediately contact the University Operations Center (617) 495-5560

Go to the next slide for more SPCC resources

Information Resources EH&S web-based Facility Equipment Inventory Management System (FEIMS) http:// www.uos.harvard.edu/redir/feims.html Technical Assistance on SPCC Plan http:// www.uos.harvard.edu/ehs/environmental/spcc.shtml Hazardous Waste Procedures http://www.uos.harvard.edu/ehs/environmental/hazardous_waste.shtml Harvard Environmental Health and Safety Department Cambridge (617) 495-2060, Longwood (617) 432-1720

EH&S web-based Facility Equipment Inventory Management System (FEIMS)

http:// www.uos.harvard.edu/redir/feims.html

Technical Assistance on SPCC Plan

http:// www.uos.harvard.edu/ehs/environmental/spcc.shtml

Hazardous Waste Procedures

http://www.uos.harvard.edu/ehs/environmental/hazardous_waste.shtml

Harvard Environmental Health and Safety Department Cambridge (617) 495-2060, Longwood (617) 432-1720

Congratulations You have now completed the presentation portion of the SPCC Training In order to finish the training take the course quiz Then print out your certificate of completion

You have now completed the presentation portion of the SPCC Training

In order to finish the training take the course quiz

Then print out your certificate of completion