Harvard Medical School S pill P revention C ountermeasures & C ontrols T raining Beth Israel Deaconess Medical Center Boston, MA

Harvard Medical School Today’s Outline What is SPCC? Why are we in this training? Regulatory summary of SPCC Plan BIDMC Oil Storage Potential Oil Spill Pathways Discharge Prevention Measures Contingency Plan

Harvard Medical School What is SPCC? Spill Prevention Control and Countermeasures It is the oil pollution prevention regulation (40 CFR 112) promulgated under the authority of the Clean Water Act (33 USC 1251) Establishes equipment, methods, and procedures to prevent discharges of oil into or upon waters of the United States

Harvard Medical School Goals of SPCC Training Familiarize employees with the written SPCC Plan Identify oil storage locations and handling procedures Identify spill pathways Familiarize employees with appropriate spill response procedures and use of response equipment

Harvard Medical School SPCC Training Requirements Training must be provided to new hires and at least annually to personnel involved in oil handling or facility maintenance about proper actions to take in the event of a spill Training updates must be conducted whenever a significant change has been made to any oil storage (e.g., new tank installation)

Harvard Medical School Who is subject to SPCC? Facilities that store, transfer, consume, or otherwise use oil that “due to its location, could reasonably be expected to discharge into or upon waters of the U.S.” And, have aggregate above-ground storage capacity > 1,320 gallons

Harvard Medical School What is considered “oil”? “oil of any kind or in any form, including fats, oils, greases of animal, vegetable, or nut origin; and other oils and greases, including petroleum oil, fuel oil, sludge, synthetic oils, mineral oils, oil refuse, or oil mixed with other waste…”

Harvard Medical School What are the penalties if I fail to comply? Civil administrative penalties up to $11,000 per day Judicial civil penalties up to $32,500 per day

Harvard Medical School What are the SPCC requirements for BIDMC? Must prepare a Spill Prevention Countermeasures and Controls (SPCC) Plan The plan must certified by a licensed Professional Engineer (P.E.) Reviewed and recertified every 5 years, or if any technical changes are made.

Harvard Medical School What is an SPCC Plan? The SPCC Plan is the written document that details the equipment, personnel, procedures, and steps to prevent and/or control discharges of oil; and provides the countermeasures to be implemented in the event of a discharge

Harvard Medical School Where is the Plan kept? A complete copy of the plan must be maintained at the facility –EH&S department Rose 3 rd floor (RO 310) The plan does not need to be submitted to EPA, but must be available for review during business hours

Harvard Medical School SPCC Plan Contents Facility Information Oil Storage Summary Potential Spill Pathways Discharge Prevention Measures Contingency Planning

Harvard Medical School BIDMC Facility Information Nearest navigable water is Muddy River (1/10 mile away) Oil Storage Capacity – 53,359 gallons Worst Case Discharge – 25,000 gallons

Harvard Medical School BIDMC Emergency Response Code Orange Emergency Line In-house Phone: Outside Phone:

Harvard Medical School Facility Contacts Rick Marini – Dir. Maint. Operations pager - #31027 Gary Schweon – Dir. EH&S pager - #39118

Harvard Medical School BIDMC Oil Storage

Harvard Medical School BIDMC Oil Storage Farr Building 6,000-gallon #2 fuel oil UST 75-gallon day tank on roof 50-gallon day tank in sub-basement

Harvard Medical School BIDMC Oil Storage Farr Building (continued) 55-gallon coolant drums (2) in sub-basement 55-gallon coolant tank on 12 th floor 220-gallon coolant supply area 12 th floor 95-gallon AST for elevator hyd. fluid

Harvard Medical School BIDMC Oil Storage Lowry Medical Office Building 275-gallon #2 fuel oil AST 330-gallon #2 fuel oil AST 30-gallon day tank 55-gallon coolant drums (2) in basement 55-gallon coolant drums (4) on 10 th floor

Harvard Medical School BIDMC Oil Storage Clinical Center – West 8,000-gallon #2 fuel oil UST 75-gallon day tanks (2) on 8 th floor 187-gallon ASTs (2) for elevator hydraulic fluid

Harvard Medical School BIDMC Oil Storage Deaconess Building 415-gallon AST for elevator hyd. fluid 55-gallon waste oil drums (2) Burlington Avenue no longer leasing facilities

Harvard Medical School BIDMC Oil Storage Shapiro Building 3,000-gallon #2 fuel oil AST 100-gallon day tank on 10 th floor 55-gallon waste oil drum in grounds shed

Harvard Medical School BIDMC Oil Storage Feldberg Building 145-gallon AST for elevator hyd. fluid. Finard Building 6,000-gallon #2 fuel oil UST 205-gallon day tank in basement

Harvard Medical School BIDMC Oil Storage Stoneman Building 25,000 gallon emergency gen UST gallon ASTs with 3 emergency generators (Reisman Roof) Rose Building 55-gallon coolant drums in meter room (4) 600-gallon AST for kitchen grease in basement

Harvard Medical School BIDMC Oil Storage Research North 450-gallon #2 fuel oil AST 75-gallon day tank in penthouse 145-gallon ASTs (2) for elevator hyd. fluid. 55-gallon coolant drums (4) in penthouse

Harvard Medical School Potential Spill Pathways

Harvard Medical School Potential Spill Pathways Farr Building UST: Overfills during delivery could flow out to the riverway. Farr Building Emergency Generators: Spill on the roof could enter roof drain. Clinical Center West UST: Overfills during delivery could enter Muddy River.

Harvard Medical School Potential Spill Pathways Finard Building UST: Overfill during delivery could enter storm drains or Muddy River. Stoneman Building: Piping or day tank failure could enter catch basin (entire contents of UST could be emptied into day tank if level controls fail and go to roof drain and catch basin 25,000 gal).

Harvard Medical School Discharge Prevention Measures

Harvard Medical School Facility Drainage Control Surface drain covers used during fuel oil deliveries Floor drains discharge to sanitary sewer

Harvard Medical School Bulk Container Management Containers compatible with contents Secondary containment provided Corrosion protection for USTs Integrity testing for ASTs High-level alarms on all tanks

Harvard Medical School Facility Transfer Operations Transfer piping protected against corrosion and vehicular damage Out-of-service lines blank-flanged and locked Piping regularly inspected for leaks

Harvard Medical School Tanker Unloading Procedures All deliveries are attended Spill response kits are nearby Surface drains covered/locked Tanks have overfill protection Tanker inspected for leakage before leaving facility

Harvard Medical School Inspections and Records Tanks and piping inspected by Maintenance Tanks integrity tested every ten years Spill response equipment inspected quarterly Secondary containment inspected monthly Records kept for five years

Harvard Medical School Site Security Fencing; flow valves locked; starter controls locked; pipeline connections securely capped

Harvard Medical School Training New hires and annually as appropriate

Harvard Medical School Contingency Planning

Harvard Medical School Contingency Planning Identification of Sensitive Areas Spill Response Equipment Emergency Coordinator Duties Emergency Assessment Notifications Post-Emergency Actions

Harvard Medical School BIDMC Sensitive Areas The “Muddy River” Endangered Species Habitat Recreational Use (boating) Wetlands Resources

Harvard Medical School Spill Response Priorities Respond to injuries Protect self and others Secure the source Make required notifications Contain spilled material Protect the environment Conduct clean-up activities

Harvard Medical School Notifications - Internal Contact your supervisor Contact Code Orange Emergency whenever there is a spill, or threat of a spill, fire, or explosion involving oil (or other hazardous material)

Harvard Medical School Situation Assessment Type of situation (spill, fire, etc.) Material involved Location Potential hazard to personnel or environment Corrective action needed

Harvard Medical School Small Spill Response Small < 55 gallons Extinguish ignition sources Isolate the area Contain and absorb spilled material Transfer spent sorbent to a drum Clean the area of residue Properly dispose of spilled material

Harvard Medical School Large Spill Response Large spills > 55 gallons Extinguish ignition sources Contain spilled material to the extent practical Stop the source of the leak (if safe to do so) Summon external resources

Harvard Medical School Spill Response Equipment Absorbents, Pigs, Booms Shovels, brooms, empty steel drums PPE (gloves, goggles, boots) Cleaner and/or degreaser

Harvard Medical School Emergency Coordinator Duties Assess the situation Make notifications, external if needed Direct small spill response actions Request Contractor assistance for large spills Conduct post-emergency actions

Harvard Medical School Notifications - External for releases to soil > ten gallons for releases to water that cause a sheen The designated Emergency Coordinators will contact: MA DEP (617) US EPA (617) National Response Center (888)

Harvard Medical School Post Emergency Actions Ensure notifications have been made Identify cause of emergency Implement corrective actions to prevent recurrence Evaluate emergency response Evaluate effectiveness of SPCC Plan

Harvard Medical School Recap What is SPCC? Why are we in this training? Regulatory summary of SPCC Plan BIDMC Oil Storage Potential Oil Spill Pathways Discharge Prevention Measures Contingency Plan