SPILL PREVENTION CONTROL - Saint Joseph's … 2006 FINALa 2010... · Web viewSPILL AND/OR RELEASE OF OIL Saint Joseph’s University Contacts: Howard Heim - Primary Emergency Coordinator

SPILL PREVENTION CONTROLAND COUNTERMEASURE PLAN

JULY 2006Updated January 1, 2012

Saint Joseph’s University Administrative Services SJU SPCC Plan July 2006Department of Health, Safety and Environmental Compliance Updated January 1, 2012

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TABLE OF CONTENTSSECTION PAGE

EMERGENCY PROCEDURES 4CERTIFICATION......................................................................................................... 5SPCC PLAN GENERAL INFORMATION....................................................................6SPCC PLAN REVIEW LOG........................................................................................7

1.0 INTRODUCTION...........................................................................................82.1 Facility Practices................................................................................51

2.1.1 Oil Transfer Procedures....................................................................512.1.2 Spent Spill Absorbent........................................................................522.1.3 Vehicle Traffic....................................................................................522.1.4 Drum/Tote Handling (Waste cooking oil container)...........................52

3.0 RESPONSIBILITIES, ACTIONS, NOTIFICATIONS AND REPORTING...............533.2 Emergency Notifications List.............................................................533.3 Regulatory and Response Notifications.............................................54

3.3.1 Spills Threatening Human Health......................................................543.3.2 Spills Threatening to Reach Navigable Waters.................................543.3.3 Spills.................................................................................................. 553.3.4 Commercial Clean-Up Contractors....................................................55

3.4 Reporting...........................................................................................553.4.1 PADEP Reporting..............................................................................553.4.2 US EPA Reporting.............................................................................56

5.0 INSPECTIONS.....................................................................................575.2 Inspection of Bulk Storage Containers...............................................575.3 Integrity Testing................................................................................589.1 Facility Modifications.........................................................................599.2 US EPA Requirements........................................................................609.3 5-Year Revisions................................................................................60

List of Tables

1 Potential Spill Prediction and Control........................................................................45

List of Figures

1 Site Location.............................................................................................................. 102 Site Plan............................................................................................................... 11-44


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List of Appendices

Appendix A: SPCC Rule Cross-ReferenceAppendix B: Certification for Facilities That Do Not Pose Substantial HarmAppendix C: PA DEP Notification of Reportable Release FormAppendix D: Monthly SPCC Plan Inspection Log


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EMERGENCY PROCEDURESSPILL AND/OR RELEASE OF OIL

Saint Joseph’s University

Contacts:

Howard Heim - Primary Emergency Coordinator (610) 660-3037 (O) (610) 883-0862 (C and H)

Kevin Kane - Alternate Emergency Coordinator (610) 660- 3025 (O) (610) 721-2303 (C)

Emergency Coordinator obtains the following information:1) Nature of Emergency; 2) Location of Emergency;3) Size and Extent of Emergency; and 4) If anyone is injured.

YES Anyone injured? NO

Emergency Coordinator contacts the following: Ambulance 911 Be prepared to give: Name, address, extent of emergency, possible chemicals involved and quantity.

If necessary, the Emergency Coordinator will activate internal facility alarms and/or communication systems to notify all personnel of evacua-tion.

Without jeopardizing health or safety, is the spill an incidental release that can be absorbed, neutralized, or otherwise controlled at the time of release by em-ployees in the immediate release area or by maintenance personnel utilizing equipment on-hand?

YES NO

Contain spill, clean-up spilled material, and store properly for disposal.

Emergency Coordinator contacts:

Emergency Coordinator contacts:Pennsylvania DEP: (800) 541-2050

Fire Department: 911 or (610) 525-7702 Police Dept 911 or (610) 649 1000Pennsylvania DEP: (800) 541-2050

Also see contact list in box on right. Cleanup: React EnvironmentalServices 800-326-2439Disposal Consultant Services 610-631-2150Tier Environmental Services 717-442-4400

Has spill reached or threatened navigable waters?YES NO

Emergency Coordinator contacts the following:US EPA Region 3 Response Center(24-hour emergency number) (215) 814-9016

National Response Center (800) 424-8802

Clean up spill-contaminated material and store properly.

Reporting requirements met (Section 3.4).

Saint Joseph’s University Administrative Services SJU SPCC Plan July 2006Department of Health, Safety and Environmental Compliance Revised March 2009, January 1, 2012

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Event concluded.

Saint Joseph’s University Administrative Services SJU SPCC Plan July 2006Department of Health, Safety and Environmental Compliance Revised March 2009, January 1, 2012

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Saint Joseph’s University Administrative Services SJU SPCC Plan July 2006Department of Health, Safety and Environmental Compliance REVISED MARCH 2009, January 1,, 2011

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SPCC PLAN REVIEW LOG

This SPCC Plan must be amended within six months following a change in the Saint Joseph’s University facility design, construction, operation or maintenance that materially affects the facility’s spill potential as required by 40 CFR 112.5(a).

This SPCC Plan must be reviewed and evaluated at least once every five years and amended to include more effective prevention and control technology, if such technology will significantly reduce the likelihood of a spill event and has been proven in the field as required by 40 CFR 112.5(b). Any Plan modifications require re-certification by a Professional Engineer.

Reviews and amendments must be documented in the following table and maintained as part of this Plan.

*CERTIFICATION STATEMENT“I have completed a review and evaluation of the SPCC Plan for Saint Joseph’s University and will/will not amend the Plan as a result.”


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SPCC PLANFOR

SAINT JOSEPH’S UNIVERSITY

1.0 INTRODUCTION

Saint Joseph’s University (SJU) is required to prepare, maintain, and follow a SPCC Plan since greater than 1,320 gallons of various oils are stored aboveground and un-derground. The discharge of oil could potentially impact SJU’s storm water system which discharges to local surface water bodies including the Schuylkill River to the East, and Cobb’s Creek, a tributary to the Schuylkill River to the South and West of SJU. The remainder of the Plan describes SJU’s procedures, which have been devel-oped to comply with the regulations codified under Federal law as published in 40 CFR 112. This Plan will be used to train personnel to ensure their awareness and under -standing of the SPCC regulations.

SJU, located in Lower Merion Township, Montgomery and Philadelphia Counties, Pennsylvania (Figure 1), is a 103-acre campus that consists of 88 buildings, recre-ational fields and stadium (Figure 2). Figure 3 shows buildings not serviced by heating oil. Detailed drawings for building numbers including 1 through 85 are shown in Figures 4 through 36. SJU is bordered by N Latches Lane to the North, Wynnefield Avenue and Overbrook Avenue to the South, 52nd Street to the East, and Cardinal Avenue to the West. SJU’s total aboveground and underground oil storage volume is over 43,000 gallons and includes the following containers with capacities at or exceeding 55-gal-lons: electrical transformers containing mineral oil, #2 fuel oil aboveground storage tanks (ASTs) for heating various buildings and to supply fuel to an emergency genera-tor, diesel fuel ASTs for maintenance equipment, a gasoline AST for maintenance equipment, and automotive virgin oil drums and cafeteria waste oil drums.

In the calculation of the 1,320-gallon threshold, only containers with an oil capacity of 55-gallons or greater are counted. Containers with an oil storage capacity of less than 55-gallons are exempt from the SPCC regulations. Oil is defined as “oil of any kind or in any form, including, but not limited to: petroleum, fuel oil, sludge, synthetic oils, min-eral oils, oil refuse, or oil mixed with wastes other than dredged spoil”. The SPCC rule can be found in Title 40 of the Code of Federal Regulations (CFR), Part 112 (Oil Pollu-tion Prevention); http://www.epa.gov/oilspill/pdfs/0703_40cfr112.pdf.

1The Oil Pollution Prevention Regulation in 40 CFR Part 112 was developed in order to (1) prevent oil discharges from reaching navigable waterways (defined to include, but not limited to: interstate waters and intrastate lakes, rivers, and streams) and adjoining shorelines, and (2) to ensure effective response to oil discharges. Required under this rule is the development of a SPCC Plan for applicable owners, users and/or operators of facilities that could possibly discharge oil in harmful quantities into navigable water-ways.

Saint Joseph’s University Administrative Services SJU SPCC Plan July 2006Department of Health, Safety and Environmental Compliance REVISED MARCH 2009, January 1, 2012

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In August 2002, the Environmental Protection Agency (EPA) amended the SPCC regu-lations to require owners or operators of facilities that “drill, produce, gather, store, use, process, refine, transfer, distribute, or consume oil and oil products” to prepare a SPCC Plan if any of the following storage practices apply:

• Greater than 1,320 gallons of oil is stored in aboveground storage containers/ tanks (ASTs), or

• Greater than 42,000 gallons of oil is stored in underground containers/tanks provided the underground storage tank (UST) is not subject to the technical requirements of the UST regulations, 40 CFR Part 280 or 281.

In December 2006, the EPA again amended the SPCC regulations to address a num-ber of issues raised by the 2002 final rule, including those pertaining to smaller oil stor-age capacities, qualified oil-filled operation equipment, motive power containers and mobile refuelers.

In December 2008, the EPA finalized amendments to the SPCC rule to provide in-creased clarity, to tailor requirements to particular industry sectors, and to streamline certain requirements for those facility owners or operators subject to the rule. On April 1, 2009, EPA delayed the effective date for the amendments to January 14, 2010 with compliance date of November 10, 2010.

A completed SPCC Plan checklist is provided in Appendix A that cross-references this Plan with the requirements of 40 CFR 112.

SJU’s records indicate that there have been no reportable spills or releases of oil at SJU within the last five years.

During the preparation of this SPCC Plan, it was determined that no Facility Response Plan is required since SJU does not meet the substantial harm criteria in 40 CFR Part 112.20. However, the Emergency Coordinator must complete the Certification of Harm Determination Form (Appendix B) and maintain the form as part of this SPCC Plan.


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Figure 1 SJU Campus Location


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Figure 2 SJU Campus Buildings


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Figure 3 Heating Systems for Buildings


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Figure 4 Mandeville Hall


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Figure 5 Hagen Arena


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Figure 6 Barry Hall


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Figure 7 ELS


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Figure 8 Post Hall


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Figure 9 Ballarmine Hall


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Figure 10 Barbelin/Lonergan Hall


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Figure 11-Drexel Library


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Figure 12 Science Center


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Figure 13 Chapel


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Figure 14 Campion


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Figure 15 Steam Plant


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Figure 16 Sourin Hall


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Figure 17 Lafarge Hall


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Figure 18 Morris Quad


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Figure 19 Moore Hall


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Figure 20 Ashwood Hall


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Figure 21 Merion Gardens


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Figure 22 McShain Hall


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Figure 23 St. Mary’s Hall


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Figure 24 Claver House


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Figure 25 St Thomas Hall


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Figure 26 Hogan Hall


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Figure 27 Sullivan Hall


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Figure 28 University Press


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Figure 29 Lannon Hall


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Figure 30 Rashford Hall


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Figure 31 Hawks Landing


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Figure 32 Gabriel Hall


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Figure 33-O’Pake Recreation Center


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Figure 34 Windram Hal


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Figure 35Building 82 Fine Arts East/Merion Hall


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Figure 36-Fine Arts West/Connelly Hall

POTENTIAL SPILL PREDICTION


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Potential oil spill locations and a description of existing measures for the avoidance and/or containment of the release of oils from the facility are presented in this section. Specific facility recommendations for improved containment measures are presented in Section 10.0.

Area/Source Total Volume(Gal.)/Source

Potential Typeof Failure

PotentialSpill Volume

(gal.)Flow Direction* Secondary

Containment

TRANSFORMERS#1

ELS Building Owned by PECO**

255Mineral Oil

Transformer failure 255 On concrete pad, west to-ward City Ave. None

Spill during oil transfer 25

#2 Mandeville Hall

Owned by PECO**

460Mineral Oil

Transformer failure 460 Onto concrete pad and ground. None


#3Ashwood Hall

Owned by PECO**

255Mineral Oil



#4Moore Hall

210Mineral Oil



#5 Quad T.H.

319Mineral Oil



#6Boiler Room #134

Power Plant

150Mineral Oil

Transformer failure 150On concrete pad, east to-

ward retaining wall. NoneSpill during oil transfer 15

#7Boiler Room #131

Power Plant

150Mineral Oil

Transformer failure 150 On concrete pad, east to-ward retaining wall. None


#8Gest Lawn

201Mineral Oil



#9Post Hall 1

237Mineral Oil



#10Post Hall 2

237Mineral Oil



#11Xavier Hall

264Mineral Oil

Transformer failure 264 On concrete pad, east to-ward Lapsley Lane. None


#125200 City Avenue Rash-

ford Hall

253Mineral Oil

Transformer failure 253Catch Basin None


#135320 City Avenue Lannon

Hall

253Mineral Oil



#14 ,#15Maguire Fine Arts

40Mineral Oil

Transformer failure 40

Catch Basin

NoneSpill during oil transfer 4



#16Maguire Quinn Hall

125Mineral Oil




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Containment

# 17Paris Dining Hall

170Mineral Oil



#18 Merion Gardens-sec-ond floor inside Three GE 40 Transformer failure 40 Concrete floor none

#19 Merion Gardens-sec-ond floor inside

Three Westing-house 60 Transformer failure 60 Concrete floor none

# 20 Hawks Landing Peco 255 Transformer failure255/20

Onto concrete pad and ground. none

*Rate of flow would be instantaneous**The transformers listed as owned by PECO are not the responsibility of Saint Joseph’s University and are not included in the oil storage cal -culations.Secondary Containment LegendA To be contained by Speedi-Dry or other absorbent material.B Spill contained by impervious nature of building's floor and/or walls.C Secondary containment.

ABOVEGROUND STORAGE TANKS

#1Claver House

320#2 Fuel Oil

Tank failure 320Contained in room. A, B

Spill during transfer 32

#2 & #3Hogan Hall

(2) 275#2 Fuel Oil

Tank failure 275 Out to recreational room, contained in building B


#4Merion Gardens

1000#2 Fuel Oil

Tank failure 1000Double wall containment? C


#5 & #6St. Thomas Hall

(2) 275#2 Fuel Oil

Tank failure 275Contained in room. B


#7 & #8Sullivan Hall

(2) 275#2 Fuel Oil

Tank failure 275Towards floor drain. A


#9Ashwood Hall

For fire pump generator

132Diesel

Tank failure 132Towards ? Area A,B


#10Maguire-Gabriel Garage

275#2 Fuel Oil

Tank failure 275 Outside of building A


#11 & #12Maguire – Windrim Hall

(2) 275#2 Fuel Oil

Tank failureSpill during transfer

27528 Contained in building B


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Containment

#13Maguire – Fine Arts East

500#2 Fuel Oil

Tank failureSpill during transfer

50050 Outside of building A

#14, #15Merion maintenance

garage(2) 275

Diesel /#2 Fuel

Tank failure275

Contained in Building, concrete floor

A,BSpill during transfer 28

#16, 17 St. Mary’s Hall (2) 275Tank Failure 275

Above Ground CSpill During Transfer 28

UNDERGROUND STORAGE TANKS

#1Moore Hall

7,000#2 Fuel Oil

Tank failure 7,000 Double wall containment, leak detection, overflow protection, alarm sys-

tem...

CSpill during transfer 700

#2Moore Hall

1000Diesel

Tank failureSpill during transfer 1000

Double wall containment, leak detection, overflow protection, alarm system

c

#3Power Plant

10,000#2 Fuel Oil

Tank failure 10,000 Double wall containment, leak detection, overflow

protection, alarm system.C

Spill during transfer 1,000

#4Maguire – O’Pake

Upper/Lower Sports

10,000#2 Fuel Oil

Tank Failure 10,000 leak detection, overflowprotection, alarm system. C

Spill during transfer 1,000

#5Maguire – Merion Hall

4,000#2 Fuel Oil

Tank Failure 4,000 leak detection, overflowprotection, alarm system. C


*Rate of flow would be instantaneous

Secondary Containment LegendA To be contained by Speedi-Dry or other absorbent material.B Spill contained by impervious nature of building's floor and/or walls.C Secondary containment.

Generators

Barbelin/LonerganGenerator

150Diesel

Tank failure 150 Toward access road to the North or grass to the

Northwest.none


LaFargeGenerator

80Diesel

Tank failure 80Double wall containment. C



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Containment

5320 City AvenueGenerator-Lannon Hall

450Diesel

Tank failure 450

Double wall containment CSpill during transfer 45

Fieldhouse Generator 150Diesel

Spill during transfer15

Toward asphalt to the East. C

Container failure 150

Moore Hall 25Diesel

Tank failure 25 Double wall containment,On concrete pad. C


Hawks Landing 225Diesel

Tank failure 225 Double wall containment, inside on concrete floor C


McShain Hall 420Diesel

Tank failure 420 Double wall containment, outside on concrete floor C


Science Center 370Diesel

Tank failure 370 Double wall containment, outside on concrete floor C


Campion Hall 300Diesel

Tank failure 300 Double wall containment, exterior on concrete floor C


Maguire Merion Garage DieselTank failure

Spill during transfer222

22Containment tank on gen-

erator C

Fine Arts West DieselTank failure ?

?Double wall containment, exterior on concrete floor C

Spill during transfer

Post Learning Commons Diesel

Tank failure240

25Double wall containment, exterior on concrete floor C


Villiger Hall Diesel

Tank failure54050

Double wall containment, exterior on concrete floor C


Waste Cooking Oil

Campion Hall(3) 55

Waste Cooking Oil

Tank failure 165 West towards storm drains. C


Hydraulic Elevators

Area Source Total Volume(Gal.)/Source

Potential Type of Failure

Potential Spill Vol-ume (gal)

Flow direction Secondary Contain-ment


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Rashford (2) 150 max Tank failure 150 max Down to 1st flr pit Concrete lined pitBorgia (2) 150 max Tank failure 150 max Down to 1st flr pit Concrete lined pitBellarmine 150 max Tank failure 150 max Down to 1st flr pit Concrete lined pitBoathouse 150 max Tank failure 150 max Down to 1st flr pit Concrete lined pitCampion (2) 150 max Tank failure 150 max Down to 1st flr pit Concrete lined pitELS 150 max Tank failure 150 max Down to 1st flr pit Concrete lined pitMandeville (2) 150 max Tank failure 150 max Down to 1st flr pit Concrete lined pitMcShain (2) 150 max Tank failure 150 max Down to 1st flr pit Concrete lined pitMcShainBridge 150 max Tank failure 150 max Down to 1st flr pit Concrete lined pitMoore Hall (2) 150 max Tank failure 150 max Down to 1st flr pit Concrete lined pitPost Hall 150 max Tank failure 150 max Down to 1st flr pit Concrete lined pitSourin 150 max Tank failure 150 max Down to 1st flr pit Concrete lined pitMaguire Cynwyd hl 150 max Tank failure 150 max Down to 1st flr pit Concrete lined pit


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2.1 Facility Practices

TransformersAll transformers have locks in place and are kept locked. Only authorized per-sonnel have access to the keys.

Waste Cooking Oil ContainerWaste cooking oil is stored in 55-gallon drums outside Campion Hall. There is secondary containment around the drum. The container is kept in a fenced in area that is locked when not in use and is removed for disposal as necessary.

Aboveground Storage TanksFifteen AST’s (AST Nos. 1, 2, 3, 4, 5, 6, 7, 8, 9, 11, 12, 14, 15, 16, 17) are lo -cated in locked areas of locked buildings.

Two ASTs at Maguire Campus #10 Gabriel Garage and #13 Fine Arts East are located outside. Secondary containment is recommended for these tanks.

The fill ports to for all of the AST’s are always locked. Only authorized person-nel have access to the keys. SJU personnel are notified and present when the ASTs are filled.

Underground Storage TanksUSTs #1, #2, #3 and #4 and #5 are all double wall contained and have leak de-tection and overfill protection. The USTs are monitored with a Veeder-root alarm system. SJU personnel are notified and present when the USTs are filled.

2.1.1 Oil Transfer ProceduresSJU personnel supervise the removal or addition of transformer oil.

SJU personnel use caution when adding waste cooking oil to the con-tainer. The container must be closed after transferring the waste oil. Any private disposal contractor used by SJU must clean up any spills that may occur during the transfer of waste cooking oil.

During any type of fuel oil delivery, the delivery truck's tires must be chocked. During material transfer the delivery truck driver must visually monitor the oil level in the AST via the tank gauge to prevent overfilling. SJU personnel must be present during filling to ensure that the tanks are being filled properly and no leaks or spills occur. In addition, before and after delivery, all valves on the truck and tank must be inspected to en-sure none are leaking. A delivery log must be used to record the follow-ing:

date, start and end time of delivery,

quantity in tank,

quantity delivered,


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inspection comments, and

SJU personnel present.

This log will ensure supervision of the entire fuel delivery and minimize any releases.

2.1.2 Spent Spill Absorbent SJU maintenance personnel typically use spill absorbent pads (ex: Cobra Coils) to contain any minor spills or releases. Spent absorbent must be stored in the designated drum located inside the Power Plant.

Waste absorbent pads or other absorbent material must be cleaned-up and disposed using the following procedure:

Place the spent absorbent into the dedicated 55-gallon drum as soon as a spill is absorbed, but no later than the end of the day in which the spill occurred or was discovered.

The dedicated drum must be labeled with the words “REGU-LATED WASTE” and “WASTE CHEMICAL SOLID”.

Conduct a hazardous waste determination via testing or generator knowledge. The used clean-up material must then be disposed of properly based on the outcome of the hazardous waste determi-nation.

If the material is identified as non-hazardous by analytical test-ing or by generator knowledge, it should be disposed of in ac-cordance with proper local regulations for non-hazardous waste.

If the material is identified as hazardous, it should be handled, labeled, and disposed of in accordance with applicable haz-ardous waste regulations.

SJU must maintain shipping records for waste materials that are transported off-site.

2.1.3 Vehicle TrafficAll oil storage locations, with the exception of the 5320 City Avenue gen-erator and the Field house generator, are away from any roads and ve-hicular traffic. The 5320 City Avenue generator is located in a parking area and is surrounded by bollards to prevent any damage from vehicles. The Field house generator is located in a grassy area, near a parking lot, and is protected by a locked fence.

2.1.4 Drum/Tote Handling (Waste cooking oil container)The following precautions should be taken during drum/tote handling op-erations.


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Keep drums/totes closed at all times, except when dispensing or filling; and

Use appropriate transport devices such as a dolly or a specifically designed handcart.

3.0 RESPONSIBILITIES, ACTIONS, NOTIFICATIONS AND REPORTING

3.1 Responsibilities

In the event of any emergency, release or threatened release of oil, an estab-lished hierarchy of emergency personnel will be notified immediately. SJU has designated a Primary and Alternate Emergency Coordinator.

In the event of an oil release, SJU personnel shall implement the SPCC Plan procedures under the direction of the Primary Emergency Coordinator or Alter-nate.

3.2 Emergency Notifications List

Contact information for the designated persons as follows:

Name Phone

Howard R. Heim, , Primary Emergency Coordinator

Home: (610) 883-0862 Cell: (610) 883-0862Office: (610) 660-3037

Kevin Kane, Alternate Emergency Coordinator

Home: (610) 446-5646Cell: (610) 721-2303

Office: (610) 660-3025

The Primary Emergency Coordinator and Alternate Emergency Coordinator were chosen based on the following qualifications:

Must be on-site or on call at all times;

Must be familiar with the facility layout;

Must be thoroughly familiar with emergency plans;

Must know the locations of all records; and

Must have the authority to commit facility resources in the event of an emergency


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3.3 Regulatory and Response Notifications

3.3.1 Spills Threatening Human HealthImmediately notify the local authorities if the Emergency Coordinator de-termines that a release threatens human health outside SJU and evacua-tion may be necessary.

Philadelphia Fire Department Phone: 911 or (215) 525-7702 Lower Merion Township Police Dept. Phone: 911 or (610) 649-1000Bryn Mawr Fire Company Phone: 911 or (610) 525-7702Montgomery Cnty Ofc. of Emergency Preparedness Phone: (610) 631-6350

3.3.2 Spills Threatening to Reach Navigable WatersImmediately notify the National Response Center (NRC) in Washington, DC in the event of a spill of any amount that cannot be reliably contained by absorbents or secondary containment and threatens to reach naviga-ble waters of the United States:

National Response Center (NRC) Phone: (800) 424-8802(24 hours) (202) 267-2675

SJU staff must be ready to report the following information to the NRC:

Your name, location, organization, and telephone number;

Name and address of the party responsible for the incident;

Date and time of the incident;

Location of the incident;

Source and cause of the release or spill;

Types of material(s) released or spilled;

Quantity of materials released or spilled;

Danger or threat posed by the release or spill;

Number and types of injuries (if any);

Weather conditions at the incident location;

Navigable waters of United States are defined in 40 CFR Part 110.1 to include interstate waterways or intrastate waterways in-cluding lakes, rivers and streams which may be utilized by inter-state travelers for recreational purposes. Navigable waters also include lakes, rivers and streams from which fish or shellfish are taken and sold in interstate commerce. The complete definition


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may be found in Section 502(7) of the Federal Water Pollution Control Act.

3.3.3 SpillsWithin 24 hours, the Pennsylvania Department of Environmental Protec-tion (PADEP) must be notified of any spill that poses a potential threat to human health or the environment. Any spills greater than 5 gals must be reported:

PADEP Emergency Response(24 hours) Phone: (800) 541-2050

3.3.4 Commercial Clean-Up ContractorsThe following spill response contractor is familiar with SJU and could re-spond to a spill, if needed:

React Environmental Services6901 Kingsessing AvenuePhiladelphia, PA 800-326-2439

Disposal Consultant Services536 North Trooper RoadNorristown, PA 19403 610-631-2150

Tier Environmental Services5745 Lincoln HighwayGap, PA 17527 717-442-4400

The Facilities Director or his designee will make the call to the response contractor to respond after a decision by the Primary Emergency Coordi-nator that these services are needed.

Contractors who will potentially respond to a release should visit the site beforehand to become adequately familiar with the storage areas, site layout, etc.

3.4 Reporting

3.4.1 PADEP ReportingWithin 15 days of a reportable spill or release of oil, the Emergency Coor-dinator must file a written report to the following:

PA Department of Environmental ProtectionBureau of Waste ManagementDivision of Storage TanksP.O. Box 8762Harrisburg, PA 17105-8762


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Lower Merion Township75 East Lancaster AveArdmore, PA 19003

City of Philadelphia1515 Arch StreetOne Parkway, 13th FloorPhiladelphia, PA 19102

The appropriate reporting form is attached as Appendix C.

3.4.2 US EPA ReportingWithin 60 days after a spill or release of greater than 1,000-gallons or af-ter two spills of greater than 42-gallons within any 12-month period the Emergency Coordinator must file a written report of the event(s) to the following agency:

U.S. Environmental Protection AgencyRegion 3, Removal BranchRemoval Enforcement and Oil Section (3HS32)1650 Arch StreetPhiladelphia, Pennsylvania 19103-2029

The EPA report must include:

Name of the facility;

Your name;

Location of the facility;

Maximum storage or handling capacity of the facility and normal daily throughput;

Corrective action and countermeasures you have taken, includ-ing a description of equipment repairs and replacement;

An adequate description of the facility, including maps, flow dia-grams, and topographical maps, as necessary;

The cause of the discharge, including a failure analysis of the system orc subsystem in which the failure occurred;

Additional preventive measures you have taken or contem-plated to minimize the possibility of recurrence; and

Such other information as the Regional Administrator may rea-sonably require pertinent to the Plan or spill event.

The EPA may conduct an inspection of the site and review this Plan if 1,000-gallons or more of oil is spilled to a navigable waterway, or there are two or more reportable spills to the NRC in a calendar year. Follow-


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ing the inspection and review, the EPA may require facility modifications and/or operational changes to minimize the possibility of future spills.

4.0 EMERGENCY PROCEDURES

In the event of a spill or release, the emergency procedures outlined in the emergency procedures flow chart (page i) must be followed. A copy of the emergency procedure flow chart must be posted in or near the Primary Emergency Coordinator’s office. If any employee discovers a spill or release it should be immediately reported to the Primary Emergency Coordinator. If the Primary Emergency Coordinator or Alternate deter-mines that the spill or release cannot be handled by on-site personnel and/or may be a threat to either human health or the environment, the listed professional spill response contractor should be contacted.

The Primary Emergency Coordinator or Alternate is responsible for determining when a spill event has concluded or is under control sufficiently such that normal activities and personnel presence may be safely resumed.

5.0 INSPECTIONS

5.1 Visual Inspections

On a monthly basis, SJU personnel or a designated vendor must inspect the drum storage areas, ASTs, and transformer areas. A written record of the in-spections must be kept as required by 40 CFR Part 112.7 Section (e). A SPCC Inspection Log, (Appendix D), must be completed and signed by the inspector as part of each monthly inspection.

Containers and drums must be checked for proper labeling, and signs of deterio-ration or leakage. Any sign of rust, corrosion, or leakage constitutes an unsatis-factory condition requiring appropriate preventive maintenance. Any container or drum label deficiencies must be corrected immediately. The containment ar-eas must also be inspected for cracks or other forms of deterioration.

SJU personnel should also verify an adequate supply of spill containment and abatement materials. See Section 6.0 for a detailed list of spill abatement equip-ment and materials that should be on-site.

All inspection logs must be made part of this SPCC Plan and maintained on-site for at least three years. Any problems must be reported to the Emergency Coor-dinator and corrected as soon as possible.

5.2 Inspection of Bulk Storage Containers

The ASTs and waste oil containers are bulk storage containers regulated under 40 CFR 112.8(c). Monthly visual inspections of these containers must include:


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Inspection of tanks supports and foundation,

Inspection of the outside of the container for signs of deterioration,

Inspection for discharges, and

Accumulation of oil inside secondary containment areas.

Records of inspections must be maintained at SJU. Any signs of a loss of oil must be promptly corrected and any accumulation of oil inside the secondary containment must be removed.

5.3 Integrity Testing

The USTs maintained by SJU are subject to integrity testing and all tanks in ex-cess of 750-gallons are required to be inspected to industry standards, by a cer-tified inspector. SJU has a certified vendor perform automatic tank gauging leak detection and precision tightness testing on each UST annually. The files are maintained in the Facilities Department. Each UST has passed annually.

If a tank should ever fail, an investigation into the cause of the failure must be performed and the tank must be brought into compliance.

The frequency of integrity testing is based on the age of the tank. Regular schedules for periodic tank inspections should be implemented.

A regularly updated list of certified inspector companies could be found at the following DEP web address: http://www.dep.state.pa.us/dep/deputate/airwaste/ wm/tanks/storagetanks/UST.htm. The integrity testing may include techniques such as hydrostatic, radiographic, ultrasonic, acoustic emissions, or another sys-tem of non-destructive shell testing.

6.0 SPILL ABATEMENT EQUIPMENT AND MATERIALS

SJU must maintain spill control equipment for all of the oil storage areas on-site. The following materials must be provided:

absorbent material (i.e. Speedi-dry, pads, and booms)

shovel

broom

Spill kits should be accessible to all employees and located near all oil storage loca-tions. SJU personnel should inspect these areas monthly to ensure that they are main-tained in working order and spill abatement materials are replenished as needed.


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7.0 TRAINING

Annual training must be provided for all “oil handling” personnel to assure an under-standing of the SPCC Plan as required by 40 CFR Part 112.7(f). SJU personnel whose duties involve the management, use, inspection or maintenance of oil storage, transfer, process or equipment will be trained in the use of this SPCC Plan by the Primary Emer -gency Coordinator. This training must highlight those portions of the SPCC as they re-late to facility operations, including, but not limited to, known discharges or failures, malfunctioning components, and recently developed precautionary measures. The training must include the following:

Operation and maintenance of equipment to prevent the discharge of oil;

Accidental discharge procedure response;

Applicable pollution control laws, rules and regulations;

General facility operations; and,

Contents of this SPCC Plan.

The regulations require training briefings at least once a year.

8.0 SECURITY

For security purposes, the transformers are locked to prevent unauthorized access. SJU campus security patrols the campus 24 hours a day, seven days a week. Campus lighting provides sufficient illumination for all of the oil storage locations, with the excep-tion of the Barbelin/Lonergan generator, and ASTs #6 & #7, Hogan Hall and #13 Fine Arts East.

Applicable security measures described below are stated in 40 CFR 112.7(g) and in-clude:

Facility lighting should be commensurate with the type and location of the fa-cility. Considerations should be given to: (A) discovery of spills occurring during hours of darkness, both by operating personnel, if present, and by non-operating personnel (the general public, local police, etc.) and (B) pre-vention of spills occurring through acts of vandalism.

9.0 SPCC PLAN AMENDMENT

This Plan may require amendments under the following three conditions.

9.1 Facility Modifications

SJU must amend the Plan whenever there is a change in facility design, con-struction, operation or maintenance that materially affects the facility’s potential for a discharge of oil to navigable waters. Plan amendments must be prepared within six months and fully implemented as soon as possible, but not later than six months following the Plan’s amendment.


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Emergency response procedures should be reviewed when:

The Plan fails during an emergency.

It becomes evident that emergency contacts demonstrate they are not equipped to handle situations.

The Primary Emergency Coordinator or Alternate changes or there is a change in their contact information.

9.2 US EPA Requirements

The EPA may require amendments to the Plan whenever the facility has: 1) dis-charged more than 1,000-gallons into or upon the navigable waters in the U.S.; 2) discharged oil in quantities greater than 42-gallons, as defined in 40 CFR Part 112.1(b), into or upon the navigable waters of the U.S. in two spill events, occur -ring within any 12 month period.

9.3 5-Year Revisions

This SPCC Plan must undergo a complete review and evaluation at least once every five years. As a result of this review, the Plan must be updated within six months to include more effective prevention and control technology, if such tech-nology is identified as having the ability to significantly reduce the likelihood of spills, and has been field proven at the time of the review. All technical amend-ments to this Plan shall be certified by a Professional Engineer in accordance with 40 CFR 112.3(d). Non-technical amendments include changes to phone numbers or names.

All five-year SPCC plan reviews must be documented at their completion in the SPCC Plan Review Log at the beginning of this Plan. The person responsible for the five-year review must attest to the certification statement with their signa-ture, include the date of the review and indicate whether a revision to the Plan is necessary.

10.0 RECOMMENDATIONS

The following recommendations are made in order for Saint Joseph’s University to fully implement this Plan and meet the November 10, 2010 compliance deadline for SPCC Plan implementation.

1. Perform and record findings of the monthly visual inspections of all oil storage locations and maintain the records for at least three years.

2. Provide and maintain spill control equipment accessible to all oil storage loca-tions. Absorbent material (i.e. Speedi-dry, pads, and booms), shovels, and brooms must be provided. Maintenance personnel should ensure that the spill kits are replenished as needed.


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3. Train all oil-handling personnel at least annually on the procedures of this SPCC Plan.

4. Provide locks for all areas where oil is stored to ensure students will not van-dalize the area.

5. Provide secondary containment around AST #10 Maguire Gabriel Garage and AST #13, Fine Arts East since these tanks are located outside without containment.

6. Provide spill kits, continue routine inspections and install secondary contain-ment or berm the area around the Mandeville Transformer to divert any spills away from the sewer drain located down gradient.

7. Provide proper labeling for all aboveground tanks and waste cooking oil con-tainer. The containers must have labels stating the contents and any hazards (i.e. No Smoking).

8. Maintain good housekeeping around all oil containing areas so that monthly inspections can be performed and any signs of a release can be discovered.


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APPENDIX A

SPCC RULE CROSS-REFERENCE

Saint Joseph’s UniversityPhiladelphia, Pennsylvania

Applicable Section of SPCC Rule (40 CFR)

Description of Rule Section of SPCC Plan

112.3 (d) P.E. Certification Requirements Page 5

112.4 Amendment of Spill Prevention and Countermeasure Plan (SPCC) by Regional Administrator 9.2

112.5(a) SPCC Amendments due to changes in facility design 9.1112.5(b) 5-Year SPCC Amendments Page 7, 9.3112.5(c) P.E. Certifications to SPCC Amendments 9.3§ 112.7 General requirements for SPCC Plans for all facilities and all oil types. 1.0

§ 112.7(a)

General requirements; discussion of facility’s conformance with rule re-quirements; deviations from Plan requirements; facility characteristics

that must be described in the Plan; spill reporting information in the Plan; emergency procedures.

1.0, 2.0, 3.0, 4.0, Table 1, Site Plan

§ 112.7(b) Fault analysis 2.0§ 112.7(c) Secondary containment 2.0, 2.1§ 112.7(d) Contingency planning 5.0§ 112.7(e) Inspections, tests, and records 5.0§ 112.7(f) Employee training and discharge prevention procedures 2.1, 3.0, 7.0§ 112.7(g) Security (excluding oil production facilities) 8.0§ 112.7(h) Oil Transfer Procedures (excluding offshore facilities) 2.1.1§ 112.7(i) Brittle fracture evaluation requirements N/A§ 112.7(j) Conformance with State requirements 3.0

§ 112.8, § 112.12 Requirements for onshore facilities (excluding production facilities) 1.0§ 112.8(a), § 112.12(a) General and specific requirements 1.0§ 112.8(b), § 112.12(b) Facility drainage 2.0§ 112.8(c), § 112.12(c) Bulk storage containers 5.2§ 112.8(d), § 112.12(d) Facility transfer operations, pumping, and facility process 2.1


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APPENDIX B

CERTIFICATION FOR FACILITIES THAT DO NOT POSE SUBSTANTIAL HARM

Facility Name: Saint Joseph’s University

Facility Address: 5600 City Avenue, Philadelphia, PA

1. Does the facility have a maximum storage capacity greater than or equal to 42,000 gal-lons and do the operations include over water transfers of oil to or from vessels?

Yes No X

2. Does the facility have a maximum storage capacity greater than or equal to one million (1,000,000) gallons and is the facility without secondary containment for each above ground storage area sufficiently large to contain the capacity of the largest above ground storage tank within the storage area?

Yes No X

3. Does the facility have a maximum storage capacity greater than or equal to one million (1,000,000) gallons and is the facility located at a distance (as calculated using the ap-propriate formula in Attachment C-III or an alternative formula1 considered acceptable by the RA) such that a discharge from the facility could cause injury to an environmentally sensitive area as defined in Appendix D?

Yes No X

4. Does the facility have a maximum storage capacity greater than or equal to one million (1,000,000) gallons and is the facility located at a distance (as calculated using the ap-propriate formula in Attachment C-III or an alternative formula1 considered acceptable by the RA) such that a discharge from the facility would shut down a public drinking water intake?

Yes No X

5. Does the facility have a maximum storage capacity greater than or equal to one million (1,000,000) gallons and within the past 5 years, has the facility experienced a reportable spill in any amount greater than or equal to 10,000 gallons?

Yes No X

1 If an alternative formula is used, documentation of the reliability and analytical soundness of the alternative formula must be attached to this form.


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APPENDIX C

PADEP Notification of Reportable Release


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APPENDIX D

INSPECTION LOGS


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MONTHLY SPCC PLAN INSPECTION LOGSAINT JOSEPH’S UNIVERSITY PHILADELPHIA, PENNSYLVANIA

Inspector’s Name

I certify that I have personally inspected the equipment described below on the date indicated. The information indicated on equipment condition is accurate to the

best of my ability and experience.

Printed Name______________________________Signature____________________________ Date_____________________

Area/Description

Good Housekeeping PreventativeMaintenance

Spill Prevention and Response Kits Problems

Identified Corrective Actions Taken & DateAccept. Unaccept. Accept. Unaccept. Accept. Unaccept.

TRANSFORMERS

#1 ELS Building

#2 Mandeville Hall

#3 Ashwood Hall

#4 Moore Hall

#5 Quad T.H.

#6 Boiler Room #134 Power Plant

#7 Boiler Room #131 Power Plant

#8 Gest Lawn

#9 Post Hall 1

#10 Post Hall 2

#11 Xavier Hall


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Inspector’s Name




Area/Description




TRANSFORMERS #12 5200 City Avenue 1-Rashford Hall

#13 5320 City Avenue 2-Lannon Hall

#14 Maguire Campus Fine Arts west

#15 Maguire Campus Fine Arts west

#16 Maguire Campus Quinn Hall

#17 Maguire Paris Dining Hall

#18 Merion Gardens 2nd flr inside (GE)

#19 Merion Gardens 2nd flr inside (westing-house)

#20 Hawks Landing


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Inspector’s Name




Area/Description




ABOVEGROUND STORAGE TANKS#1 Claver House

#2 Hogan Hall

#3 Hogan Hall

#4 Merion Gardens

#5 St. Thomas Hall

#6 St. Thomas Hall

#7 Sullivan Hall

#8 Sullivan Hall

#9 Ashwood Hall

#10 Maguire – Gabriel Garage

#11 Maguire – Windrim Hall 1

#12 Maguire – Windrim Hall 2


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Inspector’s Name




Area/Description





#2 Hogan Hall

MONTHLY SPCC PLAN INSPECTION LOG SAINT JOSEPH’S UNIVERSITY PHILADELPHIA, PENNSYLVANIA

Inspector’s Name




Area/Description




ABOVEGROUND STORAGE TANKSABOVEGROUND STORAGE TANKS


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Inspector’s Name




Area/Description





#2 Hogan Hall

#13 Maguire – Fine Arts East

#14 Maguire – Merion Maintenance Garage#15 Maguire – Merion Maintenance Garage

#16 St. Mary’s

#17 St. Mary’s


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Inspector’s Name




Area/Description




UNDERGROUND STORAGE TANKS

#1 Moore Hall-7000 gal

#2 Moore Hall-1000 gal

#3 Power Plant

#4 Maguire – O’Pake Upper/Lower Sports

#5 Maguire – Merion Hall


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Inspector’s Name




Area/Description




ABOVEGROUND STORAGE TANKS

Barbelin/Lonergan

LaFarge

5320 City Avenue-Lannon Hall

Fieldhouse

Fine Arts West

Campus Commons

Villiger

Moore Hall

Hawk Landing Garage


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Inspector’s Name




Area/Description




ABOVEGROUND STORAGE TANKSGenerators

Maguire Merion Main Garage

McShain Hall

Science Center

Campion Hall

Campion Hall - Drum


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Documents

SPILL PREVENTION CONTROL - Saint Joseph's … 2006 FINALa 2010... · Web viewSPILL AND/OR RELEASE OF OIL Saint Joseph’s University Contacts: Howard Heim - Primary Emergency Coordinator