spcc 2015
TRANSCRIPT
Aveen Noori
(816) 513-7251
Spill Prevention, Control and Countermeasures
City of Kansas City Water Services Department Wastewater Division Blue River Wastewater Treatment Plant
Goals of SPCC Training
• Overview of SPCC (Spill Prevention Control and Countermeasure) Rule Requirements
Background, Purpose of the rule and Revisions
• Summery of Blue River Wastewater Treatment SPCC Plan
• Facility Diagram and Training
• Inspections and Testing Requirements
• Roles and Responsibilities
• Discussion of Past Spills
• Information Resources
Purpose of the rule
SPCC Purpose
1. Prevent oil discharges from reaching navigable waters in the U.S.
2. To insure effective response
to oil discharge
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 BRT, BH and LC due to
– oil storage volume at these sites
– oil can be expected to enter navigable waters.
BackgroundSPCC (Spill Prevention Control and Countermeasure) Rule
Oil spills endanger public health, impact drinking water, devastate natural resources, and disrupt the economy.
In the United States we use vast quantities of oils to heat our homes, provide fuel for automobiles, and operate various pieces of equipment. During storage, transport, or as the result of energy exploration and production activities, oil and other oil-based products are sometimes spilled onto land or into waterways.
When this occurs, human health and environmental quality are put at risk. Every effort must be made to prevent oil spills and to clean them up promptly once they occur. The costs associated with spill prevention are often much less than the costs associated with spill clean up, fines, and other civil liabilities. As the old adage states,
“an ounce of prevention is worth a pound of cure.”
SPCC Rule 40 CFR Part 112
This rule is part of the U.S. Environmental Protection Agency’s oil spill prevention program and was published under the authority of Section 311(j)(1)(C) of the Federal Water Pollution Control Act (Clean Water Act) in 1974. The rule may be found at Title 40, Code of Federal Regulations, Part 112 and can be found on the web at http://epa.gov/oilspill
MO state’s Aboveground Storage Tank Release Response 10 CSR 26-5http://www.sos.mo.gov/adrules/csr/current/10csr/10c26-5.pdf
EPA’s Discharge of Oil (Sheen Rule) 40 CFR part 110
http://epa.gov/oilspill
Part 112Oil Pollution Prevention§112.1 General applicability of the rule
§112.2 Definitions of terms used in the rule
§112.3 Requirement to prepare a SPCC Plan
§112.4 Amendment of SPCC Plan by RA
§112.5 Amendment of SPCC Plan by owner or operator
§112.7 General requirements of all facilities
§§112.8 – 112.12 Add’l specific requirements for different types of facilities + different types of oils [Bulk Storage, Production, etc...]
Purpose of SPCC (Spill Prevention Control and Countermeasure) Rule
The purpose of the Spill Prevention, Control, and Countermeasure (SPCC) rule is to help facilities prevent a discharge of oil into navigable waters or adjoining shorelines.
40 CFR part 112 Amendments in 2002, 2006, 2008, 2009, and 2011.
EPA published significant amendments to the rule in2002. The Federal SPCC rule was amended again inDecember 2006.
The amendment streamlines the requirements for theowners/operators of qualified facilities with abovegroundoil storage capacities of 10,000 gallons or less anddefines certain containers and equipment regulatedunder the rule. This final rule was amended again onNovember 20, 2008, January 14, 2009, June 19, 2009and November 9, 2009.
Implementation date for these amendments wasNovember 10, 2010
Who is covered by the SPCC Rule?
A facility is covered by the SPCC rule if it has asaggregate aboveground oil storage capacitygreater than 1,320 U.S. gallons or a completelyburied storage capacity grater than 42,000 U.S.gallons and there is a reasonable expectation ofan oil discharge into or upon navigable waters ofthe U.S. or adjoining shorelines.
Definitions 40 CFR 112.2
Bulk Storage Container
• any container used to store oil. These containers are used for purposes including but not limited to the storage of oil prior to use, while being used, or prior to further distribution in commerce.
A tank is a bulk storage container Containers smaller than55 gallon are not regulated
Definitions 40 CFR 112.2
Oil
Petroleum oil: crude oil, fuel oil, mineral oil, sludge, oil refuse, and refined product (oil mixed with wastes other than dredged spoil)
Non-petroleum oil: fats, oil, and grease of animal, fish, or marine mammal, and vegetable oils, including oils from seeds, nuts, fruits, and kernels
Definitions 40 CFR 112.2
Permanently Closed
means a container or facility for which:
• All liquid and sludge has been removed from each container and connecting line; and
• All connecting lines and piping have been disconnected from the container and blanked off,
• all valves (except for ventilation valves) have been closed and locked, and
• conspicuous signs have been posted on each container stating that it is a permanently closed container and noting the date of closure.
General SPCC requirements
1. Prevent oil spills:
• Using containers suitable for the oil stored.
• Providing overfill prevention for your oil storage containers.
• Providing sized secondary containment for bulk storage containers, suchas a dike or a remote impoundment.
• Providing general secondary containment to catch the most likely oilspill where you transfer oil to and from containers and for mobile refuelsand tanker trucks. For example, you may use sorbent materials, drippans or curbing for these areas; and
• Periodically inspecting and testing pipes and containers.
2. Prepare and implement an SPCC Plan:
The owner or operator of the facility must develop and implement anSPCC Plan that describes oil handling operations, spill preventionpractices, discharge or drainage controls, and the personnel, equipmentand resources at the facility that are used to prevent oil spills fromreaching navigable waters or adjoining shorelines. Every Plan Shouldincluding:
Operating procedures at the facility to prevent oil spills
Control measures (such as secondary containment) installed to prevent oil spills from entering navigable waters or adjoining shorelines; and
Countermeasures to contain, cleanup, and mitigate the effects of an oil spill that has impacted navigable waters or adjoining shorelines.
The Quiz
A spill of only one gallon of Oil can contaminate------- gallons of water
a. One million
b. Two million
c. 750,000
d. 10,000
NASA Images show Oil's Invasion Along Louisiana Coast
Blue River Wastewater Treatment Plant’s SPCC Plan
The latest revision to Blue River WWTP’s SPCC plan was done on April, 2012. The plan covers these following major areas:
Type of oil in each container and its storage capacity
Discharge prevention measures including procedures for routine handling of products
Discharge or drainage controls
Countermeasures for discharge discovery, response, and cleanup
Methods of disposal of recovered materials
Contact list and phone numbers (including NRC) Appendix C
Inspections
Facility Diagram
Training
PE Certification40 CFR §112.3(d)
• A licensed PE must review and certify a Plan and technical amendments
• The certification does not relieve the owner/operator of his duty to prepare and fully implement a Plan
Plan Location40 CFR §112.3(d)
• Maintain a complete copy of the Plan:
– At the facility if it is attended at least 4 hours/day
– At the nearest field office if the facility is attended for less than 4 hours/day
• Have the Plan available to the RA for on-site review during normal working hours
• A non-substantial harm facility is required to maintain at the facility a copy of a form certifying that the facility does not meet the criteria for a substantial harm facility. This form may be kept with the SPCC Plan; it must be maintained at the facility
Amendment of SPCC Plan40 CFR §112.5
For changes in facility design, construction, operation, or maintenance that materially affect the potential for a discharge as described in §112.1(b)
– Commissioning and decommissioning containers
– Replacement, reconstruction, or movement of containers
– Reconstruction, replacement, or installation of piping systems
– Construction or demolition that might alter secondary containment structures
– Changes in product or service
– Revision of operating or maintenance procedures
Amend within 6 months; implement ASAP, but no later than 6 months after amendment
Facility Diagram40 CFR §112.7(a)(3)
• Supplements facility description, which may include facility location, type, size, and proximity to navigable waters, etc.
• Includes completely buried tanks that are otherwise exempted from the rule
• Provides enough detail to undertake prevention activities, perform inspections, and take response measures
• Includes intra-facility gathering lines that are otherwise exempted from the rule
Facility Diagram40 CFR §112.7(a)(3)
Required Elements
• The location and contents of oil containers greater than 55 gallons
• Completely buried tanks unless exempt
• Connecting piping
• Transfer stations
Facility Diagram40 CFR §112.7(a)(3)
Recommended Elements
• Secondary containment
• Storm drain inlets and surface waters
• Direction of flow in the event of a discharge
• Legend – scale and symbols
• Location of response kits and firefighting equipment
• Location of valves or drainage system controls
• Compass direction
• Topographical information and area maps
Facility Diagram40 CFR §112.7(a)(3)
• Revision clarified in the 2002 final rule states that the facility diagram must include all fixed containers
i.e., not mobile or portable
• For mobile or portable containers, the diagram must:
– Identify a storage area on the facility diagram
e.g., a drum storage area
– Include a separate description of the containers in the storage area, or reference facility inventories that can be updated by facility personnel.
– Provide an estimate of the potential number of containers, types of oil, and anticipated capacities
Exempt Containers and Piping40 CFR §112.7(a)(3)
• Certain containers and piping, exempted from SPCC requirements in the 2008 amendments, must be identified on the facility diagram and marked as “exempt”
– USTs that meet all of the technical requirements of 40 CFR Part 280 or an approved State program under 40 CFR Part 281
SPCC Blue River WWTP site Plan
Blue River Solids Processing Building
Volume and Content of Tanks and Containers at Blue River WWTP40 CFR §112.7(a)(3)
Container Tank ContentsTotal
Capacity(gallons)
Tank LocationSecondary
Containment Type
SecondaryContainment
Capacity
300-gal tank on Freight Elevator
Hydraulic Oil 300Subfloor of elevator shaft in Solids Processing Building
(Interior)Shaft NA*
125-gal tank on
Passenger Elevator
Hydraulic Oil 125Subfloor of elevator shaft in Solids Processing Building
(Interior)Shaft NA*
150-gal on Schwing Motors
Hydraulic Oil600
Top floor of Solids Processing Building: 2-on
west wall & 2- on north wall (Interior)
Metal rim as part of equipment plus absorbent material
2-6 gal each*
Fore Bay Gates
Gear Oil150
Motor in main walkway in NEID (Interior)
4-inch metal rim as part of
equipment plus absorbent material
6 gal*
75-gal tank on
Passenger Elevator
Hydraulic Oil 75Subfloor of elevator shaft in
NEID (Interior)Shaft NA*
Transformers (Not required in Plan. However, should be indicated.)
276-gal Transformer 552 NEID (exterior) Yes NA
427-galTransformer
854Solids Processing Building
(interior)NA NA
445-gal Transformer 445Behind Administration
BuildingYes NA
Container
Tank Contents
Total Capacit
y(gallons
)
Tank LocationSecondary
Containment Type
SecondaryContainmen
tCapacity
55-gal Drum
Drums of Hydraulic Oil,Gear Oil, Motor Oil
(12 drums)660
Drum Storage Room in the Solids Processing
Building (Interior)
Polyethylene bogies, racks
or pallets; sorbent
materials
12-100 gal
DrumDrums of Hydraulic Oil,
Gear Oil, Motor Oil(5 drums)
275Engine Room in the Solids Processing Building (Interior)
Polyethylene pallets; sorbent
materials66-90 gal
330-gal IBC
IBCs of Hydraulic Oil,Gear Oil, Motor Oil
(15 IBCs)4950
Engine Room in the Solids Processing Building (Interior)
Polyethylene IBC
containment385 gal
100-gal AST
Generator engines (3) 300Engine Room in the Solids Processing Building (Interior)
Drain plugs; boom; sorbent
materialsNA
250-gal AST
Used Oil (3 ASTs) 750
Two outside Engine Room and one on third
floor in the Solids Processing Building
(Interior)
Polyethylene pallets; sorbent
materials2-30 gal
55-gal Drum
Kerosene (2 drums) 715North overhead door in the Solids Processing
Building (Interior)
Polyethylene drum racks
100 gal
55-gal Drum
Oil (2 drums) 110North overhead door in the Solids Processing
Building (Interior)
Polyethylene pallet; sorbent
materials30 gal
55-gal Drum
Drums of Hydraulic Oil or Gear Oil
(varies up to 5 drums)275
Filter Floor/ work areas in the Solids Processing
Building (Interior)
Polyethylene bogies and
pallets; sorbent material
12-30 gal
55-gal Drum
Hydraulic Oil(1 drum)
55NEID Pumping Building
(Interior)
Drum bogie on wheels; sorbent
materials
12 gal
1,000-gal AST
Diesel 1,000South of the
Administration Building (Outside)
Double Walled Tank
Meets or exceeds 110%
Continued on Next PageLow profile pallet for drums: Deep well pallet for drums: Drum rack: 100 gal sump
2-drum – 30 gal 2-drum – 66 gal Drum bogie on wheels: 12 gal
4-drum – 66 gal 4-drum – 90 gal IBC containment: 385 gal
Volume and Content of Tanks at BR WWTP and Containers Continued
Failure Analysis40 CFR §112.7(b)
• Where experience indicates reasonable potential for equipment failure
– Tank loading or unloading equipment
– Tank overflow, rupture, or leakage
– Any other equipment known to be a source of a discharge
• Predict for each type
– Direction
– Rate of flow
– Total quantity of oil which could be discharged
Recordkeeping40 CFR §112.7(e)
• Keep record of procedures and record of inspections/tests
– Signed by appropriate supervisor or inspector
– With SPCC Plan
– Period of three years
– Records of inspection/tests kept under usual and customary business practices suffice
Personnel Training40 CFR §112.7(f)
• Train oil-handling personnel
– Operation/maintenance of prevention equipment
– Discharge procedure protocols
– Applicable pollution control laws, rules, and regulations
– General facility operations
– Contents of the facility SPCC Plan
• Designate person accountable for discharge prevention and who reports to facility mgmt
• Schedule/conduct at least one briefing/year:
– Known discharges and failures, malfunctioning components, new precautionary measures
Training40 CFR §112.7(f)
1. Detailed SPCC Training 40 CFR 112.7(f)(1)
Training for new oil-handling employees and those with oil spill prevention responsibilities.
2. Annual spill prevention briefings for oil handling personnel
…to assure an adequate understanding of the SPCC Plan, the briefings must highlight and describe
• Known discharges as described in §112.1(b)
• Failures, malfunctioning components
• Any recently developed precautionary measures
Brittle Fracture40 CFR §112.7(i)
• Field-constructed aboveground container must be evaluated for risk of discharge or failure due to brittle fracture if
Not required at BR
Inspections
Description in the Plan must be consistent with practice:
• ASTs
• pipelines
• drainage
• loading/unloading areas
• security
• training
• response equipment
Forms and details must match:
components, actions, frequencies
Must now reference and/or be consistent with the relevant industry standard
listed in the Plan, e.g. AST Inspection Records included in STI-SP001 or
available with API 653, or offer an Environmentally Equivalent method.
Inspections & Testing Summary
Applicable to all SPCC regulated facilities
Examples of inspections and tests required by 40 CFR 112
• Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs 112.7(c)(6)
• Prior to filling and departure of any tank car or tank truck, closely inspect for discharges the lowermost drain and all outlets of such vehicles 112.7(h)(3)
Inspections & Testing Summary• Regularly test liquid level sensing devices (overfill
prevention) to ensure proper operation, e.g. tape gauge, clock gauge, alarm/strobe 112.7(c)(8)(v)
• Inspect the condition of the accumulation in dikes before draining, to ensure no oil will be discharged 112.8(b)(1)
• Inspect and may drain uncontaminated retained storm water 112.8(b)(2)
• Observe effluent treatment facilities frequently enough to detect possible system upsets that could cause a harmful navigable water discharge 112.8(c)(9)
• Regularly inspect all aboveground valves, piping, and appurtenances 112.8(d)(4)
Inspections & Testing Summary
The inspection and testing program and procedures must be written/described in the Plan
• The specific industry standards used must be referenced
• Plans can still include ‘‘environmentally equivalent’’ measures if determined/approved/certified by a PE and in accordance with good engineering practice
• Scope, frequency and methods of inspections or testing
• Personnel to carry out the inspections/testing and the qualifications required of them
• At a minimum, periodic visual inspections need to be conducted by a qualified inspector (as determined in the standard)
Periodic Visual Inspections & Integrity TestingIntended to prevent, predict, and detect discharges
Somewhat flexible, but must be in accordance with industry standards
So……unless an environmental equivalence determination is made ––there is a limit to this flexibility
• Type, scope & frequency of inspections depend on tank or container type, containment, configuration and the industry reference standard selected or considered
• Could range from periodic visual inspections by facility personnel to leak testing to detailed internal and external physical testing by certified/qualified outside specialists, e.g. radiographic or ultrasonic, plus tank entry
Performed on a ‘‘regular schedule’’ and whenever material repairs are made
Frequent Visual Inspections 40 CFR 112.8(c)(6)
Intended to be a routine (though sufficiently detailed) walk-around by the o/o and typically conducted by properly trained facility personnel
• Can be used to meet certain industry standard integrity testing requirements (e.g. STI-SP001)
• Must occur frequently to detect signs of deterioration, discharges, or accumulations of oil inside diked areas
• Records for integrity tests and frequent visual inspections ––usual and customary business practices will suffice
• Retain for at least 3 years
• Must be signed by inspector or supervisor
Frequent Visual Inspections 40 CFR 112.8(c)(6)
Bulk storage tanks and containers include:
• Mobile/portable tanks
• Drums
• Totes
• Containers
• Non-transportation related tanker trucks
• Piping connected to these tanks and containers
Field Conditions Consistent with Practice
More Inspection Examples
More Inspection Examples
More Inspection Examples
Tank Supports & Foundations
More Inspection Examples
More Inspection Examples
More Inspection Examples
Inspection of water inside containment prior to release
Keep a record if draining to a watercourse
More Inspection Examples
More Inspection Examples
Regularly Scheduled Integrity Testing
Applies to aboveground bulk storage tanks that are
• Large, medium or small
• Field-erected or shop-built , or a combination of
• Wherever a tank is located – on the ground, off the ground, partially in the ground (partially buried, bunkered, or vaulted tanks)
• Storing any type of oil
e.g. mobile/portable containers, drums, totes
Potentially Relevant Industry StandardsVisual inspections and/or integrity testing
• API 653
• STI-SP001
• Other industry standards and Recommended Practices
i.e. other API standards and RPs, ASME standards, etc.
New equipment
Equipment in service
ASTs and plastic tanks
Container supports and foundation
Diked area
Aboveground valves, piping and appurtenances
Underground piping
Scope of API 653
Carbon and low alloy steel tanks built to API 650 or API 12C standard
Welded or riveted, non-refrigerated, atmospheric pressure ASTs
• Covers maintenance, inspection, alteration and repair of steel field-erected storage tanks and their components
• May include brittle fracture assessment and welding requirements
• Assessment of foundation, bottom, shell, structure, roof, attached appurtenances and nozzles to the face of the first flange, first threaded joint or first welding-end connection
Scope of API 653
• Requires certified inspections based on a tank’s service history
• Certified inspection intervals of 5-20 years depending upon the tank size and configuration
• Standard for field-erected tanks
– over 50’ tall
– having a diameter greater than 30’
Monthly Inspections UnderAPI 653
• Monthly inspections are recommended, a checklist is available with the standard
• Performed by owner/operator’s inspector
• Assess the overall condition without removing the tank from service
• Inspector need not be certified, just knowledgeable
External Inspections Under API 653
• Required every 5 years, or more frequently
• Conducted by a certified inspector
• Tank can remain in service
• Review of previous periodic inspections
• Includes tank thickness testing
• Corrosion rate calculated by comparing the original shell thickness and the established current shell thickness
Internal Inspections Under API 653
• Required every 10 years, or more frequently
• Conducted by a certified inspector
• Determines suitability for continued service by assessment of internal and external conditions
Scope of STI-SP001
Aboveground storage tanks containing non-corrosive, stable, flammable and combustible liquids
• Shop-fabricated tanks
• Portable containers
• Field-erected tanks (Appendix B)
Up to 50’ in height and 30’ in diameter
With a shell thickness less than ½”
Three categories based on capacity, configuration, spill control and continuous release detection method (CRDM)
An example using STI-SP001
Category 3 ASTs
For a single-walled AST, in contact with the ground, and between 5,000-30,000 gallons…
…two options
STI-SP001Option 1
Periodic AST inspections MONTHLY (unless EE)
Performed by o/o
No need to be certified, just knowledgeable
Checklist is included with the standard
Records of inspections must be maintained
Formal external inspection EVERY 5 YEARS
Conducted by a certified inspector
Review of previous periodic inspections, FEIs and FIIs
Includes ultrasonic thickness testing (UTT)
Must determine the corrosion rate
UTT can lead to ultrasonic testing scan (UTS)
STI-SP001Option 1
Leak Testing by owner/designee EVERY 5 YEARS
Only a point-in-time test method to determine if an AST is
liquid tight
Is not preventative, provides an indication if integrity has already been breached
Used as a measure to other inspection procedures
Formal Internal Inspection EVERY 10 YEARS
Performed by a certified inspector
STI/API trained and certified
Purpose is suitability for continued service
STI-SP001Option 2
Periodic AST inspections MONTHLY (unless EE)
Formal external inspection EVERY 5 YEARS
Leak testing EVERY YEAR
Gas pressure decay
Vacuum decay
Gas pressure soap bubble testing
Gas tracers
Soil tracers
Mass measurement
Level measurement
Hydrostatic test
OIL SPILL REPORTING REQUIREMENTS
• Internal Reporting Requirements (Oral)
• External Reporting Requirements (Oral and Written)
Internal Reporting Requirements
Appendix C.1 Notification Action Summary at Blue River WWTP
Unless noted otherwise, notifications to regulatory agencies are to be made only by the Division Manager after the emergency conditions related to the release are implemented. This restriction is necessary to prevent misinformation and to assure the notifications are properly conducted.
Then..
Appendix C.2 Oil Spill Response Immediate Actions
1) Stop the source of the spill and shut off ignition sources
2) Notify Facility personnel.
3) Initiate containment of the spill.
4) Notify the Kansas City Fire Department Hazardous Materials Response Team, if necessary.
5) Assess the characteristics of the release
6) Determine if a spill is potentially hazardous.
7) If a threat is present, initiate appropriate actions.
8) Determine if evacuation is necessary.
9) Direct the response
Reporting RequirementsAppendix C.3 Emergency Response Notification List
Agency Notification Phone Number
National Response Center (800) 424-8802
Missouri Department of Natural Resources (573) 634-2436
Mid-America Regional Council (MARC)/LEPC (816) 474-4240
Blue River WWTP
Notification
Name Phone Number
Treatment Plant
Superintendent
Hans Newsom Work: 816-513-7225
Cell: 816-806-1935
Engineer Aveen Noori Work: 816-513-7251
Cell: 816-210-3792
Treatment Plant Manager Joel Sendra Work: 816-513-7203
Cell: 816-718-3942
Assistance Manager Sherri Irving Work: 816-513-7205
Cell: 816-394-0991
Water Services Notification Name Phone Number
Environmental Compliance
Engineer
Denise Burkett Work: 816-513-0413
Cell: 816-522-7165
Safety Manager Dan Minor Work: 816-513-0390
Cell: 816-797-5762
Wastewater Utility Officer David Nelsen Work: 816-513-0541
Cell: 816-213-3409
Director Terry Leeds Work: 816-513-0529
Cell: 816-718-6914
Outside Services Phone Number
Local Fire Department
(for threat to human health)
911
Local Police Department
(for threat to human health)
911
Local Hospital (Emergency) 911
Spill Response Cleanup – Kansas City Fire Department 911
• Appendix C.4 Free Product Removal Activities Report Form
• Estimated quantity, type and thickness of free product observed or measured in wells, boreholes and excavation
• Type of free product recovery system used
• Whether any discharge will take place on-site or off-site during the recovery operation and the location of this discharge:
• Type of treatment applied to, and the effluent quality expected from, any discharge:
• Steps that have been or are being taken to obtain necessary permits for any discharge:
• Quantity and disposition of the recovered free product:
• Location and the appearance of the free product:
• Any other information pertinent to the release including Initial Release Response Measures and sample results if available:
Always refer to the SPCC rule and official agency guidance at:
http://epa.gov/oilspill
References
• http://epa.gov/oilspill
• 2002 Final SPCC Rule Text, 67 FR 47042
• SPCC Guidance for Regional Inspectors, v1.0, November 2005
• Tank Inspection, Repair, Alteration and Reconstruction, API Standard 653, 4th Edition, April 2009, includes Addendum 1 (August 2010) and Addendum 2 (January 2012)
Questions?
• The new and modified cousin Joe’s home