Welcome to Harvard’s online Spill Prevention Control and Countermeasures Training. This is referred to as the SPCC training program. This training is based on a detailed written SPCC Plan that is maintained by Environmental, Health, Safety and Emergency Management (EHSEM) Department at Harvard University.
This training will provide an overview of the regulations, Harvard’s SPCC Plan procedures for spill prevention and response, and inspection requirements. As a person who may handle oil at Harvard University this training will discuss your role and responsibility with regards to the SPCC. Additional resource information will be provided for future use. So let’s get started.
An SPCC Plan is required by the United States Environmental Protection Agency, the USEPA, if the facility stores oil or oil products above a certain threshold of and it can reasonably be expected, if spilled, to reach a waterway. The Charles River is an example of a nearby waterway that may be impacted by releases from storm drains, runoff from the land surface or other means. Harvard is required to have an SPCC Plan because of the volume of oil stored throughout the University. If spilled or released, oil could potentially reach a waterway, contaminate property or cause harm to people or the environment. While your building or group of buildings may not trigger the volume specific threshold, the University must group several buildings together as defined by the regulations. This grouping results in several campuses exceeding the threshold thereby resulting in your building(s) inclusion in the Plan. Safe management of oil is not that difficult and requires both common sense and attention to good operating practices outlined in this presentation.
Many types of oil are included in Harvard’s SPCC program. These include motor oil, fuel oil, lubricating oil or hydraulic fluids, which may be used in equipment such as elevators. Also included are animal fats and oils, and even vegetable oils used in cooking. Oil mixed with other wastes is also regulated.
Not every container of oil is regulated as part of the SPCC program. Regulated containers include any oil storage container 55 gallons or greater, including storage drums. Fuel and other bulk storage tanks and equipment such as transformers and elevators are part of the program, as are empty 55 gallon or greater containers that are capable of storing oil. .
Harvard currently has 5 locations that require specific SPCC Plans. They are Cambridge/Allston, Harvard Longwood Campus, Southborough Campus, the Arsenal in Watertown and the Harvard Forest. Copies of the SPCC Plans can be found at the Environmental Health Safety and Emergency Management offices at 46 Blackstone Street in Cambridge, at the University Operations Center and on the EHSEM website
There are several key elements to each of the SPCC Plans. These include oil storage and use locations and containment structures to capture released oil which vary from facility to facility. Other sections of the Plan include designation of responsibilities for implementation, establishing spill prevention controls and procedures and response actions to be take in the event of a spill.
One of the key elements to implementation of the SPCC program is understanding your role. This table provides a summary of roles and responsibilities, based on your job duties. Please take a moment to familiarize yourself with this information. Additional details can found in your SPCC Plan. The Environmental Health Safety and Emergency Management Department is available to provide additional information about the SPCC program should you have any questions.
Be sure to notify Environmental Health Safety and Emergency Management if your facility obtains a new oil storage tank or container. EHSEM will review specific requirements with you, update the oil device inventory, and answer any questions you may have. Each school or department is required to update their SPCC inventory on an annual basis, using the EHSEM webpage.
Training is required for any Harvard employee involved in oil handling, transfer of oil or oil products, storage of oil or oil products, spill response, or maintenance of oil containing equipment. In addition any manager whose employees are involved in these activities is required to take this SPCC training.
A critical section of the SPCC Plan is Spill Prevention. There are many aspects to spill prevention including, but not limited to, proper storage device design, conducting monthly inspections of all devices, ensuring that all devices are properly maintained and in good repair (including all alarms and shutoff valves), ensuring that all employees receive appropriate training, and monitoring fuel deliveries.
Fuel delivery companies have a role in spill prevention as well. To ensure their awareness of SPCC requirements, these vendors must sign and return a copy of the “Notice to Fuel Delivery Vendors.” Note that all fuel deliveries must be monitored by Harvard personnel. All employees from the fuel oil delivery company need to take SPCC training as well and need to be informed of any specific requirements for your facility. These are outlined in your Plan.
Secondary containment is another aspect of spill prevention. Containment must be an impervious material and contain a means of discharge that is able to be locked in the closed position. Containment may include dikes, berms, double-walled tanks or other devices. With few exceptions, secondary containment is required for all oil containing devices. Contact EHSEM for details.
Despite your best efforts, spills can happen. Being aware of the potential situations that can cause a spill or release can assist in spill prevention. Potential spill scenarios at Harvard include: damage to fuel delivery equipment during the transfer of product; tank failure; an overfill at a fill port; leaking from pipes, pumps or a transformer and spillage during transfer from container to container. Where possible, the need to transfer from one container to another should be minimized in order to reduce the risk of spills, or should be done in an area designed to accommodate these transfers.
The Plan describes two different classifications of spills incidental spills and non-incidental spills. Incidental spills are spills of known materials that do not pose a safety or health hazard and can be easily controlled or cleaned up by employees in the work area or by maintenance employees. It is important to know that once a spill enters a floor drain, storm drain or ground surface it is no longer considered incidental and the University Operations Center must be called immediately. If you are responding to an incidental spill, do not endanger yourself or others, call for help if you need it, and always wear the proper personal protective equipment for clean up, including gloves and goggles. Once the spill has been eliminated, store the waste in accordance with Harvard’s Hazardous Waste Management Procedures.
A non-incidental spill is a spill that causes material to reach the environment through a floor drain, storm drain, ground surface or underground soil. This category also includes all spills greater than 10 gallons of oil and all spills that cannot be readily absorbed or controlled at the time of the release. Additionally, any spill or release that poses a threat to human health or the hazards are unknown or the spill has caused an injury is deemed to be non-incidental. As a precaution, if you are not sure of the spill material, the quantity or if the material has reached the environment, immediately call the Operations Center. They will contact EHSEM for technical assistance. Don’t ever delay notification because you are unsure.
In the event that you notice a spill, the following steps should be taken immediately: isolate the area to protect others; identify the source of the spill in order to determine the material and note the quantity of material that was spilled; if you determine that the spill is “incidental” clean the spill up using appropriate spill clean up materials. If you cannot clean up the spill because of quantity or it presents a danger to safety or human health or has reached the environment, call the Operations Center immediately.
All locations that have an SPCC Plan are required to have spill response supplies on site. These supplies are for trained employees who respond to incidental spills and may include Speedi dry, sorbent booms and socks, oil absorbent pads, spill mats for covering drains, personal protective equipment (such as goggles and gloves), caution tape and shovels and drums for used absorbent materials. Know where your spill kits are located.
Documented, monthly inspections are one method to prevent spills and are required for aboveground storage tanks, drums that are 55-gallons or greater (including kitchen grease drums), and underground storage tanks that are used for on-site consumptive use such as heating oil. As a best management practice, Harvard also requires inspections of transformers, hydraulic elevator systems and lifts, electrical switches, grease traps, and oil water separators. All inspection records must be kept on-site for a minimum of three years. Ensure that your records are available for inspection at all times.
Periodic testing is required on certain tanks. Every 10 years all tanks greater than 1,100 gallons must be inspected by a qualified inspector along with a tank test. Integrity testing must be conducted, when there are repairs made to the tank or on an interval not greater than 10 years. Records of all tank testing must be maintained by the Harvard school or department.
Security of tanks and containers is essential in ensuring that the devices are constantly under the control of authorized personnel. Lighting in areas must be sufficient to enable the discovery of spills and to prevent spills from occurring due to vandalism.
Maintaining compliance with the requirements of the SPCC Plan is essential for the health and safety of workers and protection of the environment. The most common violations of the SPCC regulations include: inadequate training programs; failure to report a spill that reaches the environment; lack of an SPCC Plan; inadequate secondary containment and lack of spill prevention procedures. Please make sure that you do your part.
Environmental Health Safety and Emergency Management will ensure that all SPCC Management Coordinators are made aware of changes or updates to the program. If there is ever an emergency or you are unsure of your required response to a spill or release contact the University Operations Center at (617) 495-5560. EHSEM may be reached at (617) 495-2060. The Longwood EHSEM office may be reached at (617) 432-1720.
Refer to the EHSEM webpage for additional information on SPCC and other related programs and trainings.
Thank you for taking the time to perform your work safely at Harvard.
SPCC Plan Training
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
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 a certain volume 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
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
Harvard’s SPCC Plans• Harvard has five (5) SPCC Plans: – Cambridge/Allston Campuses – Longwood Medical Campus – Southborough Campus – The Arsenal at Watertown – Harvard Forest• Copies of the Plans are Maintained at: – EHSEM 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
Roles and Responsibilities Environmental Safety Facility Contractors/ EH&S Compliance Managers Vendors OfficersDevelop SPCC Plan Ensure resource allocation Update inventory for accuracy Be familiar with SPCC requirementsProvides SPCC Training and Training for Staff Ensure personnel are trained Provide spill responseGuidance equipmentMonitor SPCC regulatory Conduct and document Ensure spill equipment is Notify the Operations Centerchanges inspections stocked of any spills (617-495-5560)Support spill incident report Coordinate with EH&S on Ensure personnel are familiar Cleanup spillsand follow-up SPCC Requirements with locations of spill equipmentAssess human health and Maintain training records Assign and monitor monthlyenvironmental hazards and inspectionsimpactsDetermine need for regulatory Maintain facility-specific oil Ensure contractors are awarereporting storage/use information and of SPCC Reporting provide updates to EH&S requirementsConduct follow-up Maintain signed copy of Fuel Delivery notice
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
Information Resources• EHSEM 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_wa• Harvard Environmental Health Safety and Emergency ManagementvDepartment• 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