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Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
Triumvirate Environmental OIL SPCC Planning
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Triumvirate Environmental OIL SPCC Planning

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  • 1. Oil Spill Prevention Control & Countermeasure (SPCC) Plans 2008 Roundtable Series Regulations Overview & Best Management Practices Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 2. Roundtable Agenda • Overview of the Oil SPCC Regulations Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 3. 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 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 4. What are “waters of the U.S.” • Wetlands • Rivers • Lakes • Streams (including intermittent streams) • Ponds • Ocean Oil Spill Prevention Control & Countermeasure (SPCC) Plans 40 CFR 112.2 Definitions
  • 5. 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 onsite 40 CFR 112.1 General Applicability Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 6. 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 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 7. What are typical uses of oil? • Fuel oil for heating • Cooking oil/grease • Hydraulic fluids for • Diesel oil for equipment (e.g., generators elevators) • Gasoline for • Transformers motorized vehicles • Waste oil and equipment Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 8. How do you calculate a facility’s storage capacity? • Thresholds apply to the storage capacity of containers, tanks as well as operating equipment Oil Spill Prevention Control & Countermeasure (SPCC) Plans 40 CFR 112.1(d)(2)(ii)
  • 9. 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 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 10. 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 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 11. 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 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 12. What are appropriate containment and diversionary structures? • Dikes, berms, retaining walls • Curbing • Culverting, gutters • Weirs, booms • Spill diversion ponds • Retention ponds • Sorbent materials Oil Spill Prevention Control & Countermeasure (SPCC) Plans 40 CFR 112.7(c)(1)
  • 13. 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 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 14. 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 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 15. 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 Oil Spill Prevention Control & Countermeasure (SPCC) Plans Best Management Practices
  • 16. 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 Oil Spill Prevention Control Best Management Practices & Countermeasure (SPCC) Plans
  • 17. What about mobile/portable storage containers? • Must be temporary • Must have secondary containment – Construction sites – Tank replacement/ clean-out Oil Spill Prevention Control & Countermeasure (SPCC) Plans 40 CFR 112.3(c)
  • 18. 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 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 19. 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) Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 20. 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 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 21. 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 Oil Spill Prevention Control & Countermeasure (SPCC) Plans 40 CFR 112.7(g)
  • 22. So what is in an Oil SPCC Plan? • Complete oil storage • Emergency contacts container, tank and • Spill reporting equipment inventory procedures • Site plan with locations • Inspection schedule of all tanks, container • Description of and equipment employee training • Procedures for bulk • Professional Engineer deliveries or transfers Certification or Self- • Oil spill emergency Certification response procedures Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 23. 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 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 24. 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) Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 25. Thank you! Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 26. • BREAK!! Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 27. DEP Notification 2008 Roundtable Series October 30, 2008 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 28. What are the notification requirements? Massachusetts Contingency Plan Notification (Subpart C) 310 CMR 40.0300 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 29. 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 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 30. 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 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 31. 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 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 32. 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 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 33. Required Release Notifications 310 CMR 40.0310 • 2 Hour notification requirements • 72 Hour notification requirements • 120 day notification requirements Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 34. 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 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 35. 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 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 36. 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 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 37. 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 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 38. 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 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 39. 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 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 40. Notifying DEP HOW? • 2 HR + 72 HR Notifications – Orally by Telephone • 120 Day Notifications – Submit Release Notification Form 24 Hour Release Notification Local-617-556-1133 Toll Free 888-304-1133 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 41. 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 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 42. 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. Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 43. 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. Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 44. 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 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 45. Spill Scenario #2 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; 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 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 46. Spill Scenario #3 • 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 • Soil and groundwater contamination exists • Regulatory Closure not obtained within 120 Days of Release Estimated Clean-up cost is > $50,000 Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 47. 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. Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 48. Speakers Contact Information • Rick Foote • Mike Bricher • Senior Environmental • Senior Environmental Engineer Compliance Advisor • Cell: 508-328-1899 • Cell:617-686-6184 • Email:mbricher@triumvriate.com • Email:rfoote@triumvriate.com Oil Spill Prevention Control & Countermeasure (SPCC) Plans
  • 49. The End! • Let’s go Shoot' in!!! Oil Spill Prevention Control & Countermeasure (SPCC) Plans

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