Oil Spill Prevention Control and Countermeasure Training Prepared for Middle Georgia State University Eastman Campus

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.

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.

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. These are more of an Informal Briefing, and can be conduct more like a tailgate meeting. They serve as a refresher to employees about the plan, any changes to the facility since the plan was implemented, any equipment that may need more attention or maintenance, and a discussion of any spills that occurred during the year. These must be documented, and kept for 3 years.

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 Oil SPCC Implementation Training

Regulatory Overview

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.) MGC stores oil, and a discharge may enter into a storm drain, or reach navigable waters in some other way. It is important to note that the EPA’s definition of navigable water is extremely broad, and covers just about every conceivable water source. For example, the definition includes all water subject to the “ebb and flow of the tide”.

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 The EPA definition of oil is equally broad and covers more than just the traditional types of oil we tend to think of when we here the word. The EPA includes anything that behaves like an oil in water.

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.

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.

What is an Oil SPCC Plan? Detailed plan that describes a facility’s: 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

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).

MGA Eastman Campus Oil SPCC Plan

Eastman 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 Hanger.

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.

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.

Oil Transfer and Delivery Procedures Oil Transfer and Delivery Procedures are described in Section 3.5 of the Plan. Bulk transfers include: Jet A Fuel 100 Octane Aviation Fuel Gasoline Waste Fuel/Oil

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;

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.

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.

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.

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.

Monthly AST Inspections

Tank Integrity Testing MGA 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.

Preventative Maintenance Program MGA 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.

Release Response and Notification

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.

Response to Spills or Releases Immediately notify the Oil SPCC Coordinator at 478-934-3054 If not available contact the Alternate Oil SPCC Coordinator at 478-374-6707. If not available after hours, contact campus police at 478-374-6403. Follow the steps on the Spill Response Flow Chart.

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.

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.

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.

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.

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.

Questions Updated 8/2015