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Spill Prevention, Control, and Countermeasure (SPCC) Plans and Spill Response
2019 Electric Utility Joint Superintendents’ Conference
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Jared OmernikEric Oelkers
Overview• SPCC Rule Basics• Who Needs an SPCC Plan?• SPCC Plan Requirements• Minimize Your Chances of a Spill/
Oil Handling Best Practices• How to be Prepared for a Spill• Initial Spill Response Steps
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SPCC Rule Introduction• Code of Federal Regulations, Title 40, Part 112
issued by U.S. Environmental Protection Agency (USEPA)
= 40 CFR 112= Oil Pollution Prevention regulation= SPCC Rule!
• SPCC Rule initially published in 1973• Major revisions in 2002• Additional revisions in 2008, with final rule in 2009
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SPCC Rule Basics• Goal - Protect navigable waters of the U.S.
- Protect the environment and public health- Keep oil out of our water
• How? - The SPCC Rule implements requirements for facilities that store over the threshold quantity of oil
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• The language in the SPCC Rule is intentionally broad to allow flexible implementation, but can cause confusion.
• USEPA has a 900+ page SPCC guidance document
SPCC Rule BasicsThreshold Quantity of Oil• >1,320 gallons total oil• Aboveground oil storage containers• 55-gallon container size or larger• Oil = gasoline, diesel, fuel oil, motor oil, used oil,
mineral oil, vegetable oil (FR3), and manyothers
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SPCC Rule Basics – What Do the Regulations Require?
• Develop an SPCC Plan• Provide secondary containment for oil sources• Complete regular inspections• Complete training for oil-handling personnel
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Which Facilities Need SPCC Plans?• >1,320 gallons of oil in containers 55-gallons or greater• Storage yards• Maintenance shops/garages• Substations
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Which types of containers are covered by the SPCC Plan?
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55-gallon drums Intermediate Bulk Containers (IBC/poly totes)
Oil-filled transformers and circuit breakers
Storage tanks – fuel/used oil
Bulk Storage Container vs. Oil-filled Operational Equipment
Why is this important?• Secondary containment requirements are different
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Oil-filled Operational Equipment• Oil supports the function of the
equipment
Bulk Storage Container• Used to store oil
SPCC Plan Requirements –What’s in an SPCC Plan?• Facility diagram – Figure/Drawing showing the
location of each oil storage container• Oil inventory – type of oil and storage capacity
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SPCC Plan Requirements –What’s in an SPCC Plan?• Discharge prevention measures
• What are you doing to prevent a spill?
• Discharge/drainage controls• What do you have in place to capture a spill?• Secondary containment
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SPCC Plan Requirements –What’s in an SPCC Plan?• Countermeasures for discharge discovery,
response, cleanup• What will you do when there is a spill?
• Methods of disposal of recovered materials• Getting rid of soil, rags/pads, and other oil-contaminated items
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SPCC Plan Requirements –What’s in an SPCC Plan?• Emergency contact list = Who you gonna call?
• Facility Emergency Coordinator• National Response Center• Cleanup Contractor• State and local agencies
• Spill reporting• Notification and documentation
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SPCC Plan Requirements –What’s in an SPCC Plan?• Inspections
• Inspect in accordance with the written procedures developed by the facility
• Discharge Prevention Briefings – Training• Oil-handling personnel• At least once per year
• Security• Control unauthorized access• Prevent vandalism
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SPCC Plan Requirements Secondary Containment
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Oil-filled Operational Equipment• General secondary
containment• Most likely quantity of oil that
would be discharged
• Passive or active• Spill kit, spill response team
Bulk Storage Container• Sized secondary
containment• Contain the volume of
the container plus sufficient freeboard for rainfall
• Passive• Concrete/Steel/berm
Secondary Containment Types• Double-walled tank
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Secondary Containment Types• Concrete or steel containment unit
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Secondary Containment Types• Containment pallet
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Secondary Containment Types• Convault
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Secondary Containment Types• Hydrocarbon filter (Barrier Boom)
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Secondary Containment Types• Concrete containment pit
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Secondary Containment Types• Spill kit/drain cover (active)• Spill response team (active)
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SPCC Plan Certification• >10,000 gallons of oil
• P.E. certification required
• Flexibility:• Environmental Equivalence = deviate from certain
requirements as long as equivalent environmental protection provided
• Impracticability Determination = allows for no secondary containment if it’s impracticable
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SPCC Plan Requirements Certification (Self-certified)
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Tier II ____________________• <= 10,000 gallons oil• Meet spill history reqs• No flexibility with SPCC
Rule
Tier I __________________• <= 10,000 gallons oil• Meet spill history reqs• No flexibility with SPCC
Rule• No single container
greater than 5,000 gal• USEPA SPCC Plan
template
SPCC Plan RequirementsAmendments and Five-year Review• Amend the SPCC Plan within 6 months of changes
• If the plan is certified by a P.E., then a P.E. must certify technical changes
• Administrative updates can be made without a P.E. certification
• The SPCC Plan must be reviewed at least once every 5 years
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Minimize Your Chances of a Discharge• Inspections
• Regularly inspect oil containers• Look for signs of leakage, deterioration, damage• Identify items that require maintenance
• Training• Annual training required• Understand your facility’s oil sources• Know who to call if there is a spill
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Minimize Your Chances of a Discharge• Have standard methods for completing routine
tasks (Standard Operating Procedures (SOPs))• Oil transfer checklist
• Use best management practices (BMPs) when completing oil transfers• Use a funnel when manually transferring into a drum• Cover nearby storm drains• Confirm sufficient capacity is available before filling
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Evaluating the Risk of a Spill• Spilled Material
• Viscosity – how fast will it flow• PCBs or other hazardous material
• Surface Material• Concrete • Compacted/Loose Gravel• Grassed/vegetated area
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Evaluating the Risk of a Spill• Containment/Diversionary Structures
• Will the spill be fully/partially contained?
• Nearby pathways• Storm/sanitary inlets• Swales/ditches/culverts• Waterways – ponds/lakes/rivers
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What You Can do Now to be Prepared for an Oil Spill• Evaluate oil sources
• Maintenance needed?• Do they have secondary containment?
• Review discharge prevention and spill response steps• Do they make sense?• Would you know what to do?
• Spill kits need re-filling?
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What You Can do Now to be Prepared for an Oil Spill• Training – does your staff know what to do?
• Know the facility oil sources• Know who to call
• Review your SPCC Plan• Emergency contacts up to date? • Oil sources all listed in correct location with correct oil type/volume?
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Spill Response Steps1. Assess potential risks (fire, explosion, electric shock)2. Determine the source, approximate volume, size of
the spill, PCB presence, and direction of flow 3. Contact the Facility Emergency Coordinator (FEC)4. Under the FEC’s direction, select personal protective
equipment (PPE) and initiate actions to stop the source of the spill and place initial protection for receptors
5. Capture oil that has reached a waterway to prevent any further spreading downstream
6. Clean up oil by using absorbent materials, pumping, and removing oil-saturated earth or stone, as required
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Spill Response – Who to Call• 911 – emergency responders• Spill response contractor• Sanitary district (for spill to sanitary sewer)• Wisconsin spills hotline
• What is a reportable quantity?• 800-943-0003
• EPA/Coast Guard/ National Response Center• 800-424-8802
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Spill Response ScenarioMinor Spill on Impervious Surface
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Spill Response ScenarioMinor Spill on Impervious Surface
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• Assess potential risks – low?• Stop source of spill• Select PPE• Clean up spill• Notify FEC with material
and volume spilled
Spill Response ScenarioSubstation Regulator Failure
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Spill Response ScenarioSubstation Regulator Failure
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• Assess potential risks – major• Notify FEC/emergency
responders• Human health and safety is
priority• Block potential spill pathways
(ditch/storm inlet)
Spill Response ScenarioSubstation Regulator Failure
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• Excavation
• Staging
• Disposal
Spill Response ScenarioSpill into Water
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Spill Response ScenarioSpill into Water
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• Assess potential risks –environmental
• Notify FEC/spill response contractor
• Stop source of spill
Questions?Jared Omernik (SPCC Rule, SPCC Plans)
Eric Oelkers (Spill Response)608-216-7341
scsengineers.com
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