SPCC Compliance Update – Integrity Testing of Aboveground Storage Tanks Reply

In accordance with the US Environmental Protection Agency (US EPA) Oil Spill Prevention regulations found at 40 CFR 112.8(c) owners and operators subject to the Spill Prevention, Control, and Countermeasure (SPCC) rule are required to test or inspect each aboveground container for integrity on a regular schedule. Examples of these integrity tests include, but are not limited to: visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other systems of non-destructive testing.

The type of inspection to be performed is generally determined by the registered Professional Engineer certifying the SPCC Plan. Many SPCC plans reference the Steel Tank Institute Standard for Inspection of Aboveground Storage Tanks (SP001) as the accepted industry standard that the tanks will be inspected against. SP001 stipulates the recommended inspection frequency for various tank configurations.

While SP001 allows qualified facility personnel to perform the inspections and this is appropriate for monthly visual checks of the tank integrity, CAPACCIO recommends that tanks be inspected by a certified STI inspector at least once per year. A certified STI inspector will often uncover issues of non-compliance that are missed by facility personnel.

If you need assistance with AST integrity testing or SPCC compliance, or have general questions, please contact Jeff Briggs, certified STI inspector, at jbriggs@capaccio.com or 508-970-0033 ext.  120.

CAPACCIO provides SPCC Plans to colleges Reply

Did you know?

Having an accurate and up to date Spill Prevention, Control, and Countermeasure (SPCC) Plan will ensure that all of your oil storage locations are identified and proper safety measures or containment are in place to prevent the accidental release of oil to surface or groundwater. Having an easy to follow SPCC plan will also allow first responders to quickly identify possible receptors and take action to prevent oil from reaching them.

Recently, CAPACCIO prepared an SPCC plan for a major Boston college for oil stored at the college’s multiple campuses. CAPACCIO began by conducting a site visit to review activities regulated under the SPCC plan requirements. In particular, CAPACCIO reviewed facility operations where oil was stored, transferred, and used to assess the SPCC requirements for each activity. CAPACCIO also met with campus personnel who had knowledge of oil handling and response activities. Several storage locations required the installation of safety measures to alert personnel of a potential release of oil. For each of these locations, CAPACCIO provided recommendations for equipment and installation procedures.

Once the school completed the upgrades necessary to meet the regulatory requirements, a plan was developed that identified the oil storage locations, potential path of flow, and response measures. CAPACCIO tabularized the sources of oil storage as well as the spill prevention, control and countermeasures to be implemented in the event of a spill to streamline the management of numerous oil storage locations. In addition, a site plan was developed which identified each storage location and directly related to the tabularized information. The final SPCC Plan created by CAPACCIO was a streamlined, user-friendly document. Once feedback and buy-in was received from the school, the SPCC Plan was certified by a CAPACCIO registered professional engineer (PE).

CAPACCIO’S experience in preparing SPCC plans for educational facilities, our PE’s extensive knowledge in preparing SPCC plans, and our expertise designing containment structures and preparing practical alternative measures to secondary containment requirements was an asset to this project.

If you require assistance with your SPCC plan or need assistance with another project, please contact Bill Potochniak, PE, at 508.970.0033 ext. 134 or wpotochniak@capaccio.com.

Oh Snow, Where Art Thou? SPCC Winter Update Reply

While the local cross country ski enthusiasts and snowshoers may be a little disappointed at the lack of white stuff this year, I’ll bet the majority of us are wiping our brows in relief.  As I type, I can see the sun’s rays bouncing off the cars in the parking lot giving a glimmer of hope that spring is soon on its way.  But, being a New Englander all my life, I know that winter is likely to rear its ugly head a few times before we see the crocuses make their first appearance. 

During these winter storms, the top priority should be getting walkways and parking areas clean to ensure the safety of employees and visitors. This often puts other important areas like secondary containment for oil tanks at the back of the list, but, in accordance with the Oil Spill Prevention Control and Countermeasures (SPCC) regulations (40 CFR 112), structures used for secondary containment of oil must be kept clean and free of debris including snow and ice.  On several occasions, we have inspected secondary containment structures only to find them full of ice and snow. To prevent this from happening at your facility, secondary containment areas should be cleaned of snow before it has the chance to ice up and become a “drain freeze” during an oil spill.

For more information on SPCC Plans and SPCC compliance, contact Josh Fawson at 508-970-0033 ext. 120 or jfawson@capaccio.com.

Oil Storage and EPA Penalties – Don’t be next! Reply

On July 8, 2011, the Environmental Protection Agency (EPA) issued a “tweet” with the headline, “Companies in Vermont and Massachusetts face sanctions for failing to prevent oil spills.” It looks like the EPA has moved to social media for its regulatory updates (and warnings)! The sanctions were related to violations under Title 40, Code of Federal Regulations Part 112 (40 CFR 112) “Oil Pollution Prevention” which requires companies that store more than 1,320 gallons of oil in aboveground containers to prepare and maintain a Spill Prevention, Control, and Countermeasure (SPCC) plan. The purpose of preparing and maintaining an SPCC plan is to prevent and contain spills in order to minimize environmental damage when spills do occur. In addition, companies, through their SPCC plans, must ensure that they can adequately respond to a spill by having adequate employee training and spill response equipment.

The two New England based companies mentioned were issued significant penalties (i.e., in excess of $100K) for failing to take the required precautions to prevent and contain oil spills from their facility activities. Similar penalties are frequently issued by the EPA for a regulatory program with requirements that are relatively easy to meet. Why? Most of the time the companies that get fined don’t know about the regulation and therefore they don’t have an SPCC plan in place. In addition to paying a penalty, companies are required to come into compliance by preparing an SPCC Plan under a consent order. Don’t be the next source of EPA revenue! If you don’t have an SPCC plan, conduct an inventory of oil storage at your facility to determine if you exceed the 1,320 gallon threshold and be sure to include all animal, vegetable, mineral and synthetic oils.

If you want more information, please contact Wayne Bates at 508.970.0033 x121 or wbates@capaccio.com or check out the EPA website: http://www.epa.gov/emergencies/content/spcc/index.htm)