1. SPCC Regulations: Applicability and Requirements
Timothy W. Kipp, CHMM
Senior Consultant
GZA GeoEnvironmental, Inc.
4 Free St
Portland, ME
(207)

2. Spill Prevention, Control, and Countermeasures (SPCC) Rule
Federal Rule
Clean Water Act (40 CFR Part 112)
US Environmental Protection Agency
Enforced by EPA Regional Offices
Initial SPCC Rule
Revisions issued
Compliance deadline for revised rule – November 10, 2011!

3. Applicability SPCC Plan required if you have:
Aboveground oil storage capacity greater than 1,320 gallons; or
Underground oil storage capacity greater than 42,000 gallons (not subject to 280/281 regulations); and
Potential to release oil to navigable waters of the US
Only count containers 55-gallons or greater
Includes oil-filled operational equipment

4. What Oils are Covered under the SPCC regulation?
Oils and greases
Petroleum
Fuel oil
Mineral oils
Synthetic oils
Heat transfer fluids, engine fluids, hydraulic and transmission fluids, metalworking fluids, dielectric fluids, compressor lubricants, and turbine lubricants
Animal fats and vegetable oils
Sludge
Oil refuse
Oil mixed with wastes other than dredge spoils

5. Oil-Filled Equipment – what is it?
Oil-filled operational equipment includes an oil storage container in which the oil is present to support the function of the apparatus or device.
Examples of Oil-Filled Operational Equipment
Hydraulic Systems
Gear Boxes
Machining Coolant Systems
Heat Transfer Systems
Transformers
Circuit Breakers
Electrical Switches

8. State Regulations May have similar or overlapping regulations
AST regulations
Petroleum bulk storage facilities licensing
State “SPCC” programs
However, no there are no “authorized” or equivalent state programs – you must comply with the federal requirements irrespective of any state program!

9. Navigable waters of the US - do I have the potential to discharge?
YES!

10. The SPCC Plan Format and Content PE Certification/Management Approval
Updates and Re-Certification

11. SPCC Plan Format
Emergency Action Plan
SPCC Plan Text
Tables and Figures
Appendices

13. SPCC Plan Content
Facility Information
Oil Spill Contingency Plan
Preventive Measures

14. SPCC Plan Tables and Figures
oil storage devices and oil-filled equipment
secondary containment
spill pathways
Site Locus Plan
Site Diagram
drainage/spill pathways
piping
emergency/communications equipment

15. SPCC Plan Appendices
Inspection forms
Secondary containment calculations
Tank integrity testing schedule

16. SPCC Plan Certification
Your SPCC Plan must be:
Approved by company management (corporate officer or designated representative such as EHS manager)
Certified by a licensed Professional Engineer (PE)*
Some states require that the PE be licensed in the state where the facility is located (NOT a federal requirement)
Must identify an Emergency Coordinator (EC)
Grant authority for the EC to commit company resources for spill response
*Unless your facility is a Tier I or II “Qualified Facility”

17. SPCC Plan Annual review recommended
Five-year comprehensive review and recertification required
Administrative updates (e.g., new phone numbers) do not require recertification
Plan review and recertification for technical amendments
New tanks or storage systems
New/different product storage
Changes in facility design/operation

18. SPCC Plan Implementation
Inspections
Secondary Containment
Stormwater Management
Oil Transfers and Active Measures
Tank Integrity Testing

19. INSPECTIONS
Inspections are conducted to identify malfunctions, deterioration, operator error, and deficiencies which may cause or lead to spills/releases of oil
SPCC requires periodic inspections

20. INSPECTIONS (Continued)
Oil-filled equipment, containers, and storage area are visually inspected on a weekly basis for the following:
All equipment will be examined (where applicable) for leaks from seams, rivets and bolts and gaskets and for signs of deterioration (e.g., discoloration, corrosion, cracks) of the vessel, aboveground foundation and structure supports;
All associated piping will be checked for dripping, loose joints, damage to supports, and pipe deflection;
All connections will be checked for leakage, drainage, tightness, and appropriate capping;
All pumps will be checked for evidence of leakage, proper operation, and damage;
All storage areas and containment systems will be inspected for integrity and the accumulation of stored product. If oil is observed in the containment system, the source of the oil will be determined; and
The security of the containers/areas/equipment will be checked (i.e., valves and equipment locked and secured).

21. INSPECTIONS Three potential outcomes: All OK
Non-emergency problem detected – corrective action/maintenance required
Actual spill or leak identified

23. CONTAINMENT SYSTEMS
Prevent migration of spill/release from immediate area
SPCC containment requirements
Oil storage tanks have 100 percent containment (plus adequate freeboard for precipitation for outdoor tanks)
Drum/container storage areas have containment for 10 percent of total storage capacity
Oil-filled equipment – secondary containment where practicable
For oil-filled equipment without containment, alternative measures in place including training, spill response equipment, inspections

24. Stormwater Stormwater Drainage Procedure
Dike drains must be closed and locked!
Visually inspect for oil sheen/evidence of contamination
Open valves and allow stormwater to drain
Log each stormwater drainage event

25. Oil Transfers Spills happen when/how? DURING TRANSFER OPERATIONS!
Deliveries, re-fueling, equipment maintenance etc

26. Secondary Containment for Transfer Areas
SPCC requirements
Secondary containment needs to be sized only to address the typical failure mode and quantity for the item
Passive or active measures can be utilized
Specific provisions such as drip pans, sumps, and collection systems are recommended
Overall result:
Facilities will have discretion in meeting general secondary containment requirements, consistent with good engineering practices

28. Secondary Containment – Example – Active (Temporary) Measure
Storm drain liner and dam

29. Transfer Location Checklist
Identify all transfer points?
HIGH-RISK LOCATIONS?
Included in SPCC plan?
Table and site diagram if fixed location
Most probable spill?
Spill pathways?
Containment?
Active measures?

30. Integrity Inspections for Aboveground Storage Tanks

31. Category 1 Tanks
Category 1 tanks as defined by Steel Tank Institute (STI) are:
Aboveground tanks
< 5,000-gallon capacity
Steel construction
Not in direct contact with the ground surface
On legs or cradles
Tank bottom not in contact with soil or concrete/asphalt base
Has a continuous release detection method (CRDM)
What does this mean?
Passive system, not requiring sensors or power to operate, that allows inspector to visually detect a release. Examples include secondary containment including vaults, dikes and double-walled tanks.

32. Steel Tank Institute (STI) SP001 Inspection Standard
Category 1 tanks < 5,000-gallon capacity are recommended only for periodic visual inspection
Inspections are to be performed in accordance with STI SP001 standard:
Monthly inspections
Annual inspections (more detailed)
Owner’s inspector must meet the requirements of the standard
STI SP001 provides detailed program including:
Inspector qualifications (paragraph 4.1)
Inspection instructions (Section 6)
Monthly and annual inspection checklists (Appendix C)
Recordkeeping
Immediate action items and corrective action recommendations

33. 12 Steps to Compliance – SPCC Facility Inspection and AST Integrity Inspection/Testing Program
STEP 1: Establish routine periodic (weekly or monthly) visual inspection program
STEP 2: Get a copy of STI SP001 standard for your facility
STEP 3: Ensure that your SPCC monthly checklist includes all required items
STEP 4: Provide hands-on training to facility personnel involved in inspections
STEP 5: Do your monthly inspections!
STEP 6: Maintain signed inspection records on file for at least three years
STEP 7: Perform annual comprehensive tank condition inspection using STI checklist and protocol
STEP 8: Utilize facility manager/engineer or someone with technical training to perform the annual inspection if available
STEP 9: Maintain signed annual inspection forms on file for at least three years
STEP 10: Be proactive about tank housekeeping and preventive maintenance
STEP 11: Keep good records of repairs and preventive maintenance
STEP 12: Relax and feel good that you are in compliance!!!

34. Inspections and Testing/ SPCC Recordkeeping
Keep written procedures and records of the inspections and tests for at least 3 years.
Inspection forms and training records must be signed by the inspector or supervisor.
Records and forms include:
Daily/weekly/monthly visual inspections
Containment area drainage logs/stormwater discharge forms
Tank construction records
Tank testing records
Tank repair/alteration history
Training records

35. Personnel Training
Oil-handling personnel must be adequately trained in:
The operation and maintenance of equipment to prevent discharges;
Discharge procedure protocols;
Applicable pollution control laws, rules, and regulations;
General facility operations;
Contents of the facility SPCC Plan; and
Spill briefings (lessons learned, malfunctions at your and other facilities, and precautionary measures).
Initial and annual refresher training for all personnel involved in oil-handling
Discharge prevention meetings held at least once per year

36. Personnel Training – Practical Considerations
Training should include practical, facility-specific information on what do in case of a spill:
Who is the EC and who are the alternates
Where is the spill response equipment located
Who is your spill response contractor
Who needs to be notified, and who makes the notifications
AND MOST IMPORTANTLY, SAFETY CONSIDERATIONS:
what size spill is too big to address with training levels of personnel and available materials/equipment
evacuation – how to decide, how to evacuate, where to muster
when to call 911 and get out!
If you have not established procedures and provided training for facility personnel, the odds of a successful spill response are very poor!

37. Personnel Training – Practical Considerations
If facility personnel are expected to provide anything beyond initial response (identification, closing valves/shutting off controls, and evacuating the area), they need additional spill response training:
Industry standard is OSHA 24-hour emergency response training
Personnel expected to operate in protective clothing such as SCBAs may need additional training (e.g., OSHA 40-hour HAZWOPER)
8-hour annual refresher required for these qualifications
Facilities subject to FRP requirements have additional requirements for annual spill response drills and exercises
Personnel expected to be involved in longer-term responses should have Incident Command System (ICS) training

38. SPCC Resources EPA SPCC Website
EPA Guidance for Regional Inspectors
This has not been updated to reflect the latest amendments but is still a great resource OR
Tim Kipp, CHMM
GZA GeoEnvironmental, Inc.
4 Free St
Portland, ME
(207)

39. SPCC Resources EPA SPCC Website
EPA Guidance for Regional Inspectors
This has not been updated to reflect the latest amendments but is still a great resource
Steel Tank Institute
STI Standard SP001 for inspection of shop-fabricated tanks
Includes inspection requirements/forms for periodic visual inspection of Category 1 tanks by owner’s representative