SPCC Plans Also known as…Spill Prevention, Control, & Countermeasures Plan Required as part of 40 CFR Part 112 – Oil Pollution Prevention. The Plan: Applies to any facility that has or could discharge oil in harmful quantities 1,320 above ground storage 42,000 under ground storage Containers <55 gallons not included in storage tally

SPCC Plans Should reduce the physical and environmental hazards from storage & distribution of oil to navigable waters Should be preventative rather than reactive Should be updated every 5 years or when Plan changes Note: Includes petroleum and non-petroleum oils (i.e. animal fats)

SPCC Plans Duke has five SPCC Plans Steam Plant Transportation Medical Center Campus Marine Lab

SPCC Plans The Plan is broken down into twelve sections that detail the following: General Location Map Oil Storage Locations Appendices Checklists Review & Revision Records Training Records Cross Reference to 40 CFR 112 Spill Response Supplies & Inventory OESO Spill Response Policy

General Facility Information Names the Facility Specific facility location including longitude & latitude Describes the process of the facility Names the Spill Plan Team and where the Plan is located.

General Facility Information Plan Coordinator Personnel designated by University & Medical Center Members Duke University Spill Team E&O/FMD Trained Personnel Contractors Trained to Duke’s Plans requirements

Petroleum Storage Facilities Describes all oil storage and handling facilities covered under the Plan (including used cooking oil) Describes any modifications and implementation schedules necessary to be in compliance with the regulations

Spill Events, Containment Structures, & Spill Migration Describes the locations of the nearest navigable water Describes the predicted potential spill scenarios, spill quantities, flow rates, and spill destinations if a storage vessel described in Section 2 had a release.

Spill Prevention Measures Describes the practices and procedures in place at the facility to minimize the risk of spills and leaks of petroleum products.

Secondary Containment – Tanker Unloading

Petroleum Product Spill Containment and Cleanup Describes the types and the locations of spill response materials and appropriate response measures Includes initial notification procedures and post response activities

Notification of Spill Events Contains the information for internal and external reporting of a release. The campus police should be notified first The police shall then notify the correct people beginning with the Spill Response Team. The Plan Coordinator or the Director of Environmental Programs will notify external agencies, if necessary.

Inspections & Testing Describes required equipment inspections, frequency, and the required or recommended test method

Plan Review & Amendment Plan must be reviewed at least every 5 years by a professional engineer or whenever there is a change in facility design, construction, operation or maintenance that has the potential to impact the nature or quantity of a discharge.

Recordkeeping Details the type of records and procedures that MUST be signed, dated and kept on file at the facility for a period of 3 years. Details the records that MUST be retained for the life of the tank, piping, or ancillary system.

Training All operating and maintenance personnel involved in the storage and handling of petroleum shall receive instructions on the Plan All spill response personnel shall receive instruction to insure adequate understanding on the Plan. Training shall occur at least once a year and more frequently if a spill occurs or inspections reveal inadequacies in implementation of the plan.

Security & Lighting Describes procedures in place to ensure that access to the storage areas is controlled and storage areas are monitored at all times.

Plan Implementation Majority of fuel storage areas serve diesel emergency generators dedicated to a particular building or parking garage. Golf Course, Duke Gardens, FMD Grounds, and Duke Forest have fuel oil storage areas for equipment fueling

Plan Implementation Fuel deliveries will be scheduled by the supervisor responsible for the facility.

Plan Implementation 2. Delivery truck will back into containment area adjacent to the tanks prior to dispensing fuel (unless site has built in secondary containment).

Plan Implementation Maintenance Staff will use the SPCC Checklist to record the amount of fuel delivered.

ROUTINE EQUIPMENT CHECKS Plan Implementation INSPECTIONS & TESTING ROUTINE EQUIPMENT CHECKS Maintenance Staff familiar with the storage tanks and their operation should make the following weekly checks of oil storage areas (i.e. any area storing >55 gallons) as part of routine observations or preventive maintenance procedures: Check secondary containment for damage and integrity (will not leak); Check tanks, foundations and supports for obvious signs of leakage, distortion, or other damage; and Check piping systems, particularly at connections for obvious signs of leakage. Note: Any problems observed must be reported to the SPCC Coordinator or designee

Plan Implementation INSPECTIONS & TESTING FORMAL INSPECTIONS An SPCC inspection program has been designed to insure continued integrity of all oil storage and handling equipment. Inspections of all oil and used oil storage areas are conducted quarterly and/or annually in accordance with the schedule and requirements included in Table 2 of the plan. Records of inspections are to be signed by the inspector and maintained for at least three (3) years. Any problem detected during a formal inspection requires immediate notification of the SPCC Coordinator. Quarterly Inspections Annual Inspections

SPILL CLEANUP SUPPLIES YES NO COMMENTS GENERAL Has there been any change in facility design, construction, operation, or maintenance since the last inspection? If yes, update the SPCC plan accordingly. Is there any new petroleum bulk storage at the DUMC? SPILL CLEANUP SUPPLIES Are the Spill Kits located in the areas identified in Section 5? Do the kits contain the items identified in Section 5 at a minimum? TANKER UNLOADING Are procedures in place to ensure a trained employee is present for the entire filling operation? Are procedures being followed to ensure adequate tank capacity such as manual tank level gauging? Is there a physical barrier available, such as a chock, to prevent premature tanker truck departure in place? Are drip pads readily available for placing beneath each connection? Any sign of tanker leaks? OIL STORAGE AREAS Is documentation on file verifying the accuracy of tank float gauges or electronic monitoring systems within the last year? Are the tanks and all associated valves and piping in good condition and free from leaks and excessive corrosion? Are all tanks without double walls stored in appropriate locations inside the containment dikes, such that any spill will be contained? Are the dikes or double walls in good condition, showing no signs of leaks, damage, or excessive wear?

Plan Implementation Quarterly Inspections Spill supplies are checked on a quarterly basis to ensure the supplies are adequate and all materials are properly stored. In addition, all oil storage and transfer areas are to be inspected on a quarterly basis to ensure the following: Containers are in good condition and are overpacked if necessary; Containers are properly labeled; Containers are stored in appropriate locations identified in the SPCC Plan; Appropriate secondary containment is provided where required; Adequate space is maintained in storage areas for maneuvering of drums, handcarts, or forklifts, as appropriate; Spill kits are adequately stocked and appropriately located;

Plan Implementation Quarterly Inspections- cont. Procedures outlined in the SPCC Plan are adhered to; Piping systems, tanks, and transfer equipment are in good condition; Repairs are made at the storage locations as required; Quarterly inspections are documented using the form in Appendix 1; and Records of such inspections and any associated repairs are kept with the master copy of the SPCC Plan by the SPCC Coordinator.

Plan Implementation Annual Inspections In addition to the quarterly inspection requirements listed above, the annual inspection includes the following general activities which are also recorded on the inspection checklist included in Appendix 1: Annual equipment inspection and maintenance requirements as described in the inspection checklist in Appendix 1; Confirm that SPCC procedures are being followed and that they are adequate for the university; Ensure that the university maintains the capability to respond to releases; and Ensure that records are being retained as described in Section 9.0.

Plan Implementation Testing In addition to regular inspections, the university will conduct tank and piping integrity testing and internal tank inspections by an inspector who is authorized to perform the relevant tests (see Table 2). A signed report and recommendations will be submitted by the testing agent following test completion and retained for the life of the tank. The test results will then be reviewed to determine subsequent testing requirements or necessary repairs.

Plan Implementation Integrity Testing The testing and the minimum testing frequency that are required for each tank or piping system to ensure continued integrity of the oil storage and handling facilities, can be found in Table 2 of the Plan. The following slide contains an excerpt from that table.

VISUAL MONITORING (Frequency) SOURCE TANK TYPE VISUAL MONITORING (Frequency) CHECK INTERSTICE FOR FUEL & WATER (Frequency) VERIFY PROPER OPERATION OF LEAK DETECTION SYSTEM (Frequency) PRESSURE TIGHTNESS TEST WITH INERT GAS (Frequency) METAL LOSS TESTING OR OTHER NDE* (Frequency) (1) Lennox–Baker Children’s Hospital – 500 gal diesel AST Single-wall; tank bottom NOT in contact with support surface and is visible YES (Quarterly) NA YES - If equipped. NOT REQUIRED (2) North Pavilion – 5,000 gal diesel AST (3) Center for Living: Aesthetics – 150 gal diesel AST Double-wall; outer shell in contact with support surface (Every 10 years) (4) Center for Living: Fitness – 150 gal diesel AST (5) – (2) 30,000 gal diesel USTs UST's (Per 40 CFR Part 280) Consult 40 CFR Part 280 for Test and Frequency. (6) OESO – 125 gal diesel AST (7) Duke South Medical Center: West Entrance – 2,000 gal diesel UST Consult 40 CFR Part 280 for Test and Frequency. Required for cathodic protection systems. Complete per 40 CFR Part 280 for cathodic protection systems.

Plan Implementation Record Keeping The following records and procedures must be signed, dated and retained for a minimum of three years: Inspections and testing procedures; Records of scheduled inspections and any corrective actions taken. Equipment maintenance records; Records of visual inspection of discharges from diked containment area; and Records of employee training and annual briefings.

Plan Implementation Training The SPCC Coordinator shall see that all operating and maintenance personnel involved in the storage and handling of petroleum receive instructions on the following: Operation and maintenance of equipment to minimize risk of equipment failure and subsequent release; Good Housekeeping Practices which ensure a clean, safe, workplace and minimize the risk of spills and leaks; Location and use of all spill control materials; Spill Prevention and Response; and Emergency notification procedures.