Triumvirate Environmental OIL SPCC Planning

Oil Spill Prevention Control &
Countermeasure (SPCC) Plans

2008 Roundtable Series
Regulations Overview
& Best Management Practices

Oil Spill Prevention Control
& Countermeasure (SPCC) Plans

Roundtable Agenda

• Overview of the Oil SPCC Regulations


What do you need to know?
• Oil SPCC Plans are required under the
Clean Water Act
• Objective: To minimize the potential for
releases to “waters of the U.S.”
• Regulations: 40 CFR Part 112
• Federal vs. State regulation
• Applicable to most, but not all facilities


What are “waters of the U.S.”

• Wetlands
• Rivers
• Lakes
• Streams (including
intermittent streams)
• Ponds
• Ocean

40 CFR 112.2 Definitions

What is the applicability criteria?
Based on containers or equipment with
capacity 55 gallons or greater:
• Underground Storage Tanks (USTs) -
greater or equal to 42,000 gallons
• Aboveground Storage Tanks (ASTs) -
greater or equal to 1,320 gallons

Note: Refers to aggregate amounts of oil onsite
40 CFR 112.1 General Applicability


What is regulated?
-Categories of Oil
• Petroleum oils
– Crude and refined petroleum products, asphalt, gasoline,
fuel oils, mineral oils, naphtha, sludge, oil refuse, oil mixed
with wastes
• Animal fats and vegetable oils
– Lard, tallow, cod liver oil, corn oil, grapeseed oil, coconut
oil, palm oil, peanut oil
• Other non-petroleum oils
– Coal tar, silicon fluids, pine oil, turpentine, tall oils

40 CFR 112.2 Definitions


What are typical uses of oil?

• Fuel oil for heating • Cooking oil/grease
• Hydraulic fluids for • Diesel oil for
equipment (e.g., generators
elevators) • Gasoline for
• Transformers motorized vehicles
• Waste oil and equipment


How do you calculate a facility’s
storage capacity?

• Thresholds apply to
the storage capacity
of containers, tanks
as well as operating
equipment

40 CFR 112.1(d)(2)(ii)

What are examples of oil-filled
operational equipment?
• Hydraulic elevators
• Transformers
• Circuit breakers and
electrical switches
• Emergency generators
(gen-sets)
• Machining coolant
systems
• Gear boxes
• Heat transfer systems


What presents the potential for
releases of oil to “waters of the U.S. ?
• Proximity to:
– floor drains or sumps
– doorways
– sewer or storm drains
– surface waters
– soils
• Structural integrity of the container,
tank or equipment
• Handling and storage practices

How do facilities prevent or minimize
the potential for oil releases?
• Secondary containment – required for all
aboveground tanks, containers, and operating
equipment
• Implement best management practices:
– Inspections
– Integrity testing
– Delivery procedures
– Storage, transfer, handling procedures
– Employee training


What are appropriate containment
and diversionary structures?
• Dikes, berms,
retaining walls
• Curbing
• Culverting, gutters
• Weirs, booms
• Spill diversion
ponds
• Retention ponds
• Sorbent materials

40 CFR 112.7(c)(1)

Other secondary containment
options are…

• Double-walled tanks
• Spill pallets for drums and smaller
containers
• Impervious (concrete floor and wall
joints
• Trenches with no outlets


What is in a “good” spill kit?
• Absorbent materials
– Pads, booms, speedi-dri
– Enough material to contain the largest volume
• Appropriate PPE
– Gloves, boots, safety glasses, hard hat….
• Emergency Contact List
• First Aid Kit
– Eye wash, hand cleaner, band-aids


What are typical facility policies
for oil storage?
• Containers are properly labeled and
stored upright or on drum cradles
• Containers are properly handled and
transported by trained personnel
• Containers exceeding 55 gallons must
have secondary containment
• Spill equipment is maintained at oil and
loading/unloading storage areas

Best Management Practices

What are other typical facility
policies for oil storage?
• Drains near storage tanks must be
plugged, capped, or covered (at least
during filling/transfer operations)
• Tanks, containers, and operating
equipment are inspected monthly
• Elevator reservoirs are inspected and
maintained by a contractor

Best Management Practices & Countermeasure (SPCC) Plans

What about mobile/portable
storage containers?
• Must be temporary
• Must have
secondary
containment
– Construction sites
– Tank replacement/
clean-out

40 CFR 112.3(c)

How often are inspections of oil storage
containers and equipment performed?
• In accordance with the schedule set forth in
the facility’s Oil SPCC Plan
• Dependent on volume and location
• Per industry standards (ANSI, etc.)
• PE recommendation


How are inspections performed?
• Per good engineering standards:
– On an established, routine schedule to
determine leaks, spills, other deficiencies
– Deficiencies are documented and reported
– Corrective measures are taken asap and
documented
• Records must be kept for 3 years

40 CFR 112.7(e)


What do train my employees on?
• Contents of the facilities Oil SPCC Plan
• What to do in an emergency?
– Cleanup procedures
– Who you going to call?
• Where do the outfalls go?
• Review of the locations of oil storage
• Review of the inspection procedures
• Review of any spills/releases during the last
year


What does EPA require for
security measures?

• Fully fenced or locked/guard gates
• Security measures to ensure valves remain
closed
• Secure loading/unloading connections when
not in service
• Provide facility lighting to prevent vandalism
and assist in discovery of discharges

40 CFR 112.7(g)

So what is in an Oil SPCC Plan?
• Complete oil storage • Emergency contacts
container, tank and • Spill reporting
equipment inventory procedures
• Site plan with locations • Inspection schedule
of all tanks, container • Description of
and equipment employee training
• Procedures for bulk • Professional Engineer
deliveries or transfers Certification or Self-
• Oil spill emergency Certification
response procedures


What is the Professional
Engineer’s role?

• Must certify that the plan meets
regulatory requirements (secondary
containment) and industry standards
(tank integrity testing)
• Note: Self-Certification is allowed if
total storage quantity is <10,000 gallons


Key Points
• Oil storage thresholds
• Types of oils regulated
• Plan must be PE certified or Self-
Certified (minimum every 5 years)
• Inspections (typically monthly)
• Training (completed annually)


Thank you!


• BREAK!!


DEP Notification

2008 Roundtable Series
October 30, 2008


What are the notification
requirements?

Massachusetts Contingency Plan
Notification (Subpart C)
310 CMR 40.0300


Notification to DEP
• DEP does not need to know about small
releases which are being cleaned up

• DEP needs to know about and tracks
significant releases

There are triggers and thresholds above
which releases come into our release
tracking system….via Notification


Notification
Purpose and Scope

MA Contingency Plan contains
requirements and procedures for
notifying the DEP of releases and
threats of release of Oil and Hazardous
Material (OHM)
– ID releases which require notification
– Sets time periods
– Sets procedures


Who Must Notify DEP?

• The owner or operator of a vessel where there
has been release or threat of a release of OHM*
• any person who arranged for transport,
disposal, on-site storage of OHM*
• any person who caused or is legally responsible
for a release or threat of release of OHM*
* Oil or Hazardous Materials


Role of Licensed Site Professional (LSP)
in Notification
• Use of LSP is not required for
Notification
• LSP may make notification for
Responsible Party
• LSP should state that the notification
is as LSP/Agent on behalf of
Responsible Party


Required Release Notifications
310 CMR 40.0310

• 2 Hour notification requirements

• 72 Hour notification requirements

• 120 day notification requirements


2 Hour Notification

ASAP not more than 2 Hours from obtaining
knowledge of release
• Sudden release to the environment
• > Reportable Quantity (RQ), occurs within 24 hours
• Quantity Unknown
• Causes sheen on surface water
• Release to storm drain or to the environment via
sanitary sewer
• Release could pose Imminent Hazard


Imminent Hazard
(2 hour notifications)

Releases defined to pose an Imminent Hazard
(310 CMR 40.0321(1))

• Vapors in buildings, etc., > 10% LEL
• Release of Reactive or explosive material
• Roadway releases endangering safety
• Releases producing immediate or acute
adverse impacts to fish populations

Releases which “could pose” an IH (310 CMR 40.0321(2))
• Contamination in private drinking water well
• Contamination in surficial soil accessible to children


72 Hour Notification
• Release indicated by oil/insoluble chemicals
> ½ inch
• > 100 ppm headspace screening during UST
Closure
• Contamination identified within
– Zone I of Public Supply Well
– 500 feet from private supply well
– Groundwater contamination within 30 feet school
or occupied residential structure and groundwater
< 15 feet below grade
• Failed tank test of UST system
• Substantial Release Migration

Substantial Release Migration?
• Contamination that migrates >200
feet/year
• Contamination that has or likely (within
1 year) to:
– Contaminate water supply
– Impact Indoor air
– Necessitate remedial actions at
downgradient receptors


120 Day Notification
• Release to the Environment indicated
by:
– Contamination in soil or groundwater
greater than Reportable Concentrations
– Oil/insoluble liquid measured less than ½
inch


Common Types of Reportable Releases
at Hospitals/Schools
• Leaking fuel underground/aboveground storage
tank system
• Failed electrical transformer systems
• Leaking 55-gallon drum containers
• Hydraulic oil releases from elevator systems
• Commercial vehicle accidents resulting in fuel
releases
• Improper disposal of OHM containing equipment
into dumpsters
• Soil contamination discovered during site
redevelopment/construction activities
• PCB soil contamination from building caulking


Notifying DEP
HOW?
• 2 HR + 72 HR Notifications
– Orally by Telephone

• 120 Day Notifications
– Submit Release Notification Form

24 Hour Release Notification
Local-617-556-1133
Toll Free 888-304-1133

Immediate Response Actions After
Notification

• Minimize longer term site disruption
• Reduce the potential exposure to site
receptors
• Clean up costs are significantly lower
when responsible parties clean up spills
quickly


DEP Notification Facts
• 1400 to 1600 reportable releases were
called into MA DEP per year from 1993
through 2006
– Exception: 2,640 reportable releases in
1998
• 75% of Reportable Releases are 2 Hour
or 72 Hour
• 75% of Reportable Releases closed out
within the 1st year.


Guidance Tips on Cleanup Costs

The assessment and cleanup of an oil and/or
hazardous material release is a step-by-step
process. The answers to clean up costs will
change as more information regarding the
OHM release is discovered.

Spills that had time to spread to groundwater
are significantly more expensive to clean up.


Spill Scenario #1
NON-PCB Transformer Oil Spill
• <50 gallons of oil released
• 10-20 cubic yards of impacted soil excavated and
disposed at off-site recycling facility
• Oil release limited to soil only
• Submit Regulatory Closure Report to MA DEP
within 60 Days of Release
Estimated Clean-up cost is < $25,000


Spill Scenario #2
NON-PCB Transformer Oil Spill
• <50 gallons of oil released
• 10-20 cubic yards of impacted soil excavated and
disposed at off-site recycling facility
• Oil release limited to soil only; however, some
testing of groundwater would be needed to
confirm that the OHM did not affect it
• Submit Regulatory Closure Report to MA DEP
within 120 Days of Release
Estimated Clean-up cost is $25,000 to $50,000


Spill Scenario #3
• Non-PCB Transformer Oil Spill
• >50 gallons of oil released
• 10-20 cubic yards of impacted soil excavated
and disposed at off-site recycling facility
• Soil and groundwater contamination exists
• Regulatory Closure not obtained within 120
Days of Release
Estimated Clean-up cost is > $50,000


What Happens When DEP is Not
Notified of a Reportable Release?
• 6/25/08: MassDEP entered into a Consent Order with a $30,000
Penalty involving an oil delivery company. Consent Order
encompasses two releases that happened within a three-month
period. Company failed to notify, and conducting Immediate
Response Action without approval.
• 6/9/08: MassDEP executed a Consent Order with a $5,000 Penalty
regarding chromium plating operations company. The company
failed to notify the Department, as required, when it gained
knowledge of a condition of Substantial Release Migration (SRM).
• 3/19/08: MassDEP executed a Consent Order with a $9,000 Penalty
regarding an industrial property owner. The owner failed to notify
as required after a release of metals and PCBs.


Speakers Contact Information
• Rick Foote • Mike Bricher
• Senior Environmental • Senior Environmental Engineer
Compliance Advisor
• Cell: 508-328-1899
• Cell:617-686-6184
• Email:mbricher@triumvriate.com
• Email:rfoote@triumvriate.com


The End!

• Let’s go Shoot' in!!!


Triumvirate Environmental OIL SPCC Planning

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