1. ANNUAL SPILL PREVENTION CONTROL AND COUNTERMEASURE TRAINING (SPCC) Presented by: Prepared for: Stephen F. Austin State University February 2, 2012

2. Why Are We Here? Liability SPCC Regulatory Compliance 40 CFR Part 112 Preparation of a Spill Prevention Control and Countermeasures (SPCC) Plan

3. Who Regulates Whom? SPCC Environmental Protection Agency Region VI Dallas, Texas Region 6 Serves: Arkansas, Louisiana, New Mexico, Oklahoma, and Texas

4. Liability Penalties are in addition to clean up costs Fines as well as prison time possible Disclosed SPCC findings during peer audit program

5. Management Responsibility and Accountability Emergency Coordinator(s) Responsible for emergency response and reporting All Oil Handling Personnel Responsible for spill prevention and response on site Management/ Administration Responsible for ensuring implementation and review of plan It is not enough to just have an SPCC Plan, the college must follow and implement that plan. Ensure review of plan every 5 years or with facility changes. Update plan within 6 months of change.

6. Emergency Coordinators NameOffice Phone24 hour phone Sunil Chithiri(936) 468-6034(734) 223-6946 Jeremy Higgins(936) 468-4532(936) 715-5358 Mike Griffith(936) 468-4442(936) 552-9384

7. SPCC Purpose: Prevent Oil Discharges from Reaching Navigable Waterways defined as lakes, rivers, streams, wetlands and adjoining shorelines. Ensure effective response to oil discharges Note: Oil is any kind or in any form but not limited to petroleum, synthetic oils, mineral oils, fuel oils, sludge, oil refuse, and used oil.

8. Who Does It Impact (SPCC)? Facilities with >1,320 gallons of petroleum product storage aboveground (containers, tanks, and machines) Underground storage tanks greater than 42,000 gallons provided the UST is not subject to technical requirements of 40 CFR 280 or 281 No containers smaller than 55 gallons are counted toward the 1,320 gallon capacity

9. Oil Storage at SFA Total Oil storage at SFA = 28,421 gallons Aboveground Storage Tanks (ASTs) (6) Kitchen Grease Receptacle (2) Emergency Generator Belly Tank (8) 55-gallon drums of Petroleum products (5) Elevator Reservoirs (65) Transformers (52)

10. Requirements for Storage Bulk Storage – 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. Examples at SFA: Fuel ASTs, emergency generator belly tank, 55-gallon drums, Used Oil ASTs, kitchen grease Oil-filled operational equipment – Any equipment that includes an oil storage container (or multiple containers) in which the oil is present solely to support the function of the apparatus or the device. Examples at SFA: elevators, transformers

11. Requirements for “ Bulk ” Storage Manage Facility and Dike Drainage Provide Compatible Containers Provide Sized Secondary Containment Test containers for Integrity Avoid Discharges During Oil Transfers Correct Visible Discharges

12. Requirements for “ Bulk ” Storage Manage Facility and Dike Drainage No oil can be discharged from the facility or from the containment areas Units on site are protected from accumulated rain water As necessary, document draining activities on monthly inspection logs *Sections 6.0 and 7.0 of the SPCC Plan

13. Requirements for “ Bulk ” Storage Provide Sized Secondary Containment Most tanks at SFA are contained, maintain a double walled system, or are within a room that would contain a leak or spill. Kitchen grease containers need containment. *Table 1B and Section 6.2 of SPCC Plan

14. Requirements for “ Bulk ” Storage Test containers for Integrity Monthly Visual Inspections (Appendix D) Routine Integrity Testing Replace at end of useful life (55 gallon drums) or as needed for tanks < 660 gallons Non-destructive testing *Section 7 and Appendix D of Plan

15. Requirements for “ Bulk ” Storage Avoid Discharges During Oil Transfers Ensure trained personnel are always in attendance during filling operations Engineering protections include: Fuel gauges Automatic cut-off systems High level alarms *Tables 1B, 2 and 3

16. Requirements for “ Bulk ” Storage Correct Visible Discharges SFA must promptly correct all oil leaks and/or discharges (IF SAFE!!) Use Spill kits and absorbent materials: Grounds & Transportation Building; Agricultural Research Center/Poultry Research Center; Elevators at HPE Complex; and On the mobile generator trailer Notify the Emergency Coordinator and Security Contact outside vendors as necessary Complete Spill Reporting Form in Appendix C *Sections 3 and 4 of Plan

18. Emergency Procedures Refer to Spill Response Flow Chart at the end of the training packet *Section 4 of Plan

19. Requirements for Oil-Filled Operational Equipment No sized secondary containment required Need active or passive containment system Active – spill absorbent material, drain covers, diversion valves, etc. Passive – berms, containment dike, etc. *Table 1A and Section 6.2 of Plan

20. Requirements for Oil-filled Operational Equipment Passive and active containment provided for elevators All elevator contractors are to be notified of who to contact in case of an emergency Active containment available for transformers Respond to any spills or leaks in the same manner as described for bulk storage containers *Table 1A and Section 6.2 of SPCC Plan Photos c/o Wikimedia and Know- How In Action Belzona® Repairs Leaking Transformer Fins

21. All records should be maintained for at least three (3) years Completed Logs Annual Training Rosters Corrective Action Documentation (completed work orders) Spill Reports Record Retention and Filing Requirements *Sections 7 and 10, and Appendix C and H of the SPCC Plan

22. Training Requirements Training Required Initially and Annually thereafter Training to include SPCC Plan details and recently developed precautionary measures Review of known discharges or failures, or malfunctioning Components O&M of equipment to prevent discharges Discharge procedure Protocols General Facility Operations Applicable laws, rules, and regulations *Section 10 of the Plan

23. Review Known Discharges, Failures, or Malfunctions Within the last year: Any known discharges??? Any Additional sources??? *Section 10 of the plan

24. SPCC Reporting Requirements After a spill of >1,000 gallons, or after two spills >42 gallons enters US Waters within any 12 month period, report must be filed in 60 days to US-EPA Region 6 and TCEQ EPA will then conduct an inspection of the facility and complete review of the SPCC Plan Federal Water Pollution Control Act- Any release of a chemical in any amount must be reported to TCEQ *Sections 3 and 4 of Plan

25. THANK YOU Shannon Lewis shannon.lewis@hrpassociates.com HRP Associates, Inc. 1-800-752-3922 www.hrpassociates.com