Oil Spill Prevention Control and Countermeasure Training

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Oil Spill Prevention Control and Countermeasure
Training

• Prepared for
• Middle Georgia State College

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Introduction and Overview

• The EPA has passed Oil Pollution Prevention
  regulations to implement the requirements of the
  Clean Water Act and the Oil Pollution Prevention
  Act.
• These regulations can be found at 40 CFR Part 112
  and require certain facilities to prepare Oil
  Spill Prevention Control and Countermeasure
  (SPCC) Plans.

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Oil SPCC Training

• All facilities that operate under Oil SPCC Plans
  must provide training to all oil-handling
  employees.
• Frequency of training is not specified in the
  rule, but must be sufficient to prevent a
  discharge.
• Training must be documented and records kept with
  the Plan for at least three years.

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Discharge Prevention Briefings

• In addition to the Oil SPCC training, facilities
  must also conduct discharge prevention briefings
  for all oil-handling employees on an annual
  basis, or more frequently, where appropriate.
• Briefings should
• Remind employees of plan provisions
• Update employees on the latest prevention and
  response techniques
• Highlight and describe known discharges and
• Discuss malfunctioning components.

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Training Objectives

• Attendees should understand
• What an Oil SPCC Plan is and why it is
  needed
• Potential spill sources on campus
• Oil transfer and delivery procedures
• Inspection and testing procedures and
• How to respond to a spill

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Regulatory Overview
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Oil SPCC Planning Applicability

• Plan requirements are applicable to
• Non-transportation related facilities (fixed or
  mobile) involved in oil production, refining,
  storage or well-drilling
• That store oil of any kind above planning
  thresholds with
• A reasonable expectation that a discharge in a
  harmful quantity (causes a sheen) could get to
  navigable waters (waters of the U.S.)

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What is Oil?

• EPA defines oil as oil of any kind or in any
  form, including, but not limited to
• Fats, oils, or greases of animal, fish, or marine
  mammal origin
• Vegetable oils, including oils from seeds, nuts,
  fruits, or kernels and
• Other oils and greases, including petroleum, fuel
  oil, sludge, synthetic oils, mineral oils, oil
  refuse, or oil mixed with waste other than
  dredged spoil.
• See 40 CFR 112.2

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Oil SPCC Planning Thresholds

• Underground Storage (40 CFR 112.1(d)(2)(i))
• Facilities with a total underground storage
  capacity of 42,000 gallons or more of oil are
  subject to Oil SPCC planning requirements.
• Underground tanks that are currently subject to
  all of the technical requirements of Chapter
  391-3-16 of the Georgia DNR Rules do not need to
  be included in the calculation of underground
  storage capacity.
• Consumptive use tanks that are exempted from
  the technical requirements are subject to the Oil
  SPCC planning requirements.

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Oil SPCC Planning Thresholds

• Aboveground Storage (40 CFR 112.1(d)(2)(ii))
• Facilities with a total aboveground storage
  capacity of 1,320 gallons or more of oil are
  subject to Oil SPCC planning requirements.
• Only containers or oil containing equipment with
  a capacity of 55 gallons or greater are counted.
• Thresholds apply to storage capacity contained in
  operating equipment as well as tanks/containers.

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What is an Oil SPCC Plan?

• Detailed plan that describes a facilitys
• Oil storage containers and secondary containment.
• Oil handling and management practices.
• Designated roles and responsibilities.
• Measures taken to prevent and/or control
  an oil spill.
• Countermeasures to address a
  spill should one occur

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Plan Certification and Review

• Oil SPCC Plans must be certified by a
  Professional Engineer (P.E.).
• Plans must be reviewed at least once every five
  years and completion of the review and evaluation
  must be documented.
• If amendments are required, they must be
  completed within six months.
• Technical amendments must be certified by a P.E.
  (e.g., Changes to storage capacity,
  prevention/control technology, or inspection and
  testing procedures).

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MGSC Cochran CampusOil SPCC Plan
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Cochran Campus Oil SPCC Plan

• The overall goal is to prepare/implement plan
  that satisfies the legal requirements and allows
  quick reference in the event of a spill/release.
• Copies of the Plan can be found
• EHS Office and
• Plant Operations

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Identification of Potential Releases

• Preparation of the Plan included an evaluation of
  potential releases from each of the bulk oil
  storage containers on campus.
• Two potential release scenarios were identified

• A release due to tank or piping failure
• A release during fuel deliveries or pumping of
  the waste fuel tanks.

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Identification of Potential Releases

• In order to reduce the potential of a release
  from one of these two scenarios, the Plan
  includes
• Oil transfer and delivery procedures designed to
  prevent overfills and accidents and
• A comprehensive inspection, testing and
  preventative maintenance program to detect
  releases and ensure proper function of all tank
  systems.

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Oil Transfer and Delivery Procedures

• Oil Transfer and Delivery Procedures are
  described in Section 3.5 of the Plan.
• Bulk transfers include
• Diesel Fuel for the Generator and
• Waste Cooking Oil

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Oil Transfer and Delivery Procedures

• Prior to Unloading
• Determine the available capacity of the receiving
  tank using the tank monitoring system or level
  gauge. This information should then be
  communicated to the individual responsible for
  the transfer.
• Move spill containment equipment, such as booms
  or spill barriers, into the unloading area
• Ensure that the drip pans are placed under all
  pump hose fittings (if applicable) after the hose
  is hooked up to the tank and prior to unloading
• Ensure that the fill nozzle is placed in the
  appropriate tank appurtenance

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Oil Transfer and Delivery Procedures

• During unloading
• All oil transfers must be attended. The
  individual responsible for the transfer must
  remain with the vehicle at all times during
  loading or unloading
• Periodically check the tank monitoring system to
  ensure that the available capacity is not
  exceeded.
• Prohibit smoking, lighting matches or the use of
  cellular telephones near the tank truck during
  unloading.

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Oil Transfer and Delivery Procedures

• After fuel unloading is completed
• Prior to disconnecting and removing the flexible
  hoses, ensure that they are drained
• Pour any fuel accumulated in the drip pans into
  the appropriate waste tank
• Cap and secure the fill port and
• Inspect that area around the tank truck prior to
  departure for any leaks.

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Inspections and Testing Procedures

• The Inspection and Testing program described in
  Chapter 4.0 of the Plan consist of
• Monthly Visual Inspections of all ASTs and
  55-gallon drums performed by MGC personnel
• Tank Integrity Tests of ASTs performed, as
  needed, by a qualified contractor and
• Preventative maintenance to ensure that equipment
  remains in good working order.

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Monthly AST Inspections

• ASTs, piping, and secondary containment are
  inspected on a monthly basis and documented
  using the tank inspection forms in Appendix B.
• These inspections also include oil storage in
  55-gallon drums.

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Monthly AST Inspections
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Tank Integrity Testing

• MGSC will retain the services of a Certified Tank
  Testing Contractor to perform an integrity test
  of an AST under the following circumstances
• Whenever material repairs or alterations are made
  to the tank
• If evidence of a leak occurs
• In the event of damage to the tank or containment
  structure or
• If the results of a tank inspection reveal
  evidence of leakage or deterioration.

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Preventative Maintenance Program

• MGSC routinely inspects and replaces equipment as
  part of its preventative maintenance program.
• If an inspection shows that continuation of an
  operation or practice is likely to result in an
  imminent release, prompt action is taken.
• If there is no imminent threat to cause a
  release, visible leaks are promptly corrected.

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Release Response and Notification
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Response to Spills or Releases

• Trained personnel may respond to small leaks or
  spills that do not pose significant risks to
  health or safety.
• First Responders are trained to respond in a
  defensive fashion without actually trying to stop
  the release.
• Their function is to contain the release from a
  safe distance, keep it from spreading, and
  prevent exposure to the environment.
• Do not endanger yourself or others by attempting
  to act outside of your role.

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Response to Spills or Releases

• Immediately notify the Oil SPCC Coordinator, Gene
  Cravey.
• If Gene is not available contact Ronnie Mullis or
  Danny Posey.
• Follow the steps on the Spill Response Flow
  Chart.

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Response to Spills or Releases

• Any release into a storm sewer or a visible sheen
  on surface water is a reportable release.
• The Oil SPCC Coordinator will determine whether
  the release requires action beyond the
  capabilities of facility personnel.
• After notification, trained personnel will
  attempt to control the release at its source and
  contain the material that has already been
  released using the appropriate emergency response
  and cleanup equipment.

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Response to Spills or Releases

• Released material should be contained by placing
  absorbent booms and pads down gradient of the
  source to control and divert the flow of oil.
  When possible the oil should be contained on
  pavement or concrete.
• All nearby catch basins and manholes should be
  covered and/or bermed with absorbent materials.

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Clean-up and Disposal Procedures

• All contaminated PPE, equipment, and clean-up
  waste will be contained in labeled 55-gallon
  drums and labeled.
• A private environmental clean-up contractor will
  be retained to perform any necessary remediation
  and remove all contaminated material and clean-up
  equipment.

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Internal and External Notifications

• All spills, regardless of quantity must be
  immediately reported to the Oil SPCC Coordinator.
• The Oil SPCC Coordinator is the designated party
  accountable for spill prevention and will assess
  whether a release has exceeded any reportable
  conditions and notify the proper authorities as
  necessary.

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Oil SPCC Training Summary

• Know where the Oil SPCC Plan can be found
• Be familiar with the procedures for fuel
  deliveries and monthly inspections contained in
  the Oil SPCC Plan
• Know who the Oil SPCC Coordinators are and when
  they should be notified of a spill or release
  and
• Always remember to respond to a release in a
  defensive fashion to contain the release from a
  safe distance and keep it from spreading. Do not
  endanger yourself or others by attempting to act
  outside of your role.

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Questions