SPCC Marina Inspection Update - 2018 Oklahoma Marina Association Inspector Tom McKay
Recent Compliance Assistance Documents 40 CFR 112 Final & Most Recent Regulation (7/1/15) Latest SPCC Inspection Checklists (6/1/2014) SPCC Guidance for Regional Inspectors (8/28/13 Update Pending) SPCC & FRP Workshop for Onshore Facilities (Scheduling) in Addison, TX
SPCC Inspection Process Facility Inspection Targeting History of non-compliance Spill history of an geographic area Spill Responses ** Distance to navigable waters Proximity to sensitive ecosystems Citizen Complaints ** State/Federal referrals **
The Most Common SPCC Violations At Marinas
No SPCC Plan Common Violation Commonly found at facilities that did not know that they were regulated Small facilities Facilities that had been purchased but had not put together a plan yet. 5
No PE Certification Common Violation PE certifies that the facility s equipment, design, construction, and maintenance procedures used to implement the Plan are in accordance with good engineering practices. PE certification must be completed in accordance with law of the state in which the PE is working Generally certification includes: Name Registration number and State Date of Certification PE seal affixed to Plan 6
Qualified Facility Applicability If the facility total aboveground oil storage capacity is 10,000 gallons or less And And the facility has Then the facility is a: Within three years prior to the Plan certification date, or since becoming subject to the SPCC rule if in operation for less than three years, the facility has not had: A single discharge of oil to navigable waters or adjoining shorelines exceeding 1,000 gallons, or Two discharges of oil to navigable waters or adjoining shorelines each exceeding 42 gallons within any 12-month period. 1 No individual aboveground oil containers greater than 5,000 gallons; Any individual aboveground oil container greater than 5,000 gallons; Tier I Qualified Facility: Complete and self-certify Plan template (Appendix G to 40 CFR part 112) in lieu of a full PE-certified Plan. Tier II Qualified Facility: Prepare a self-certified Plan in accordance with all applicable requirements of 112.7 and subparts B or C of the rule, in lieu of a PEcertified Plan.
No Records Common Violation Owner/operator does not have records of inspections or tests and spill prevention training. Facility maintains very generic records that do not cover all of the requirements of the rule. Common to hear that they do inspections, but do not write them down. Lack of 5-Year Plan Review ** 8
Totes and Drums not in secondary containment Common Violation
No General Containment for Loading Areas Pump dispensers w/out general containment Load-line w/out general containment
No Secondary Containment
Secondary Containment Appears Inadequate Inadequate containment Inadequate containment
Containment Not Impervious To Contain Oil Cracks in concrete containment Cracks in cinder-block containment
Piping and Valve Issues
Lack of Tank Integrity Testing Protocols SPCC Plan Requirements Identify Standard Used STI SP001 Best Standard for Marinas API 653 Identify Inspection and Testing Protocols External inspection Shell Testing(ultrasonic) Implementation Conduct & Record external inspections per standard used Conduct & Record Nondestructive shell thickness testing; ie ultrasonic or hydrostatic.
STI SP001 Inspection Protocols An assigned knowledgeable marina employee conducts periodic inspections of all marina shop-built Above Ground Storage Containers (ASTs) Records of inspections consist of the monthly and annual inspection checklist in the Steel Tank Institute (STI) SP001 Standard
STI SPOO1 Inspection Protocols For Typical Marina Tanks
STI SP001 - Spill Control and CDRM CONTINUOUS RELEASE DETECTION METHOD (CRDM) a means of detecting a release of liquid through inherent design. Examples of CDRM: Secondary containment AST, including double-wall AST Elevated AST, with or without release prevention barrier. SPILL CONTROL - a means of preventing a release of liquid to the environment, including adjoining property and waterways. Spill control methods include : Secondary containment dike/berm Secondary containment AST Secondary containment system
Typical Marina Tank Configuration Within the SP001 Standard
Marinas With Underground Storage Tanks USTs are exempt from SPCC regulatory requirements as long as the facility follows 40 CFR 280 and/or 281. Most marinas incorporate Oklahoma UST protocols administered by the Oklahoma Corporation Commission Petroleum Storage Tank Division.
SPCC Plan Maintenance & Housekeeping * Review and Update Your SPCC Plan Most members were brought into compliance in 2009 Plans should have been updated by 11/10/2011 to incorporate new regulatory amendments. * Must document Plan review and evaluation. Sign statement at beginning or end of Plan or in a log or an appendix: I have completed review and evaluation of the SPCC Plan for (name of facility) on (date), and will (will not) amend the Plan as a result. PE must certify any technical amendment to Plan.
Continued SPCC Maintenance Keep current on overall facility inspection records. Keep current on spill prevention training for oil & fuel handling personnel. Both inspection records and training records are required to be maintained with your plan for 3 years. Follow and document tank integrity inspection & testing protocols developed for your facility.
Continued SPCC Maintenance Tier II Tank Registration with ODEQ, Local Emergency Planning Committee (LEPC), and local fire department due annually on March 1 st Maintain requisite Material Safety Data Sheets (MSDS) for hazardous materials including fuel stored at your marina
Conclusions Emphasis upon joint inspections with both State and Federal Agencies. Our goal is to increase compliance awareness and improve response performance.
Contact Information Inspector Tom McKay Office Phone: (214) 665-2180 E-Mail: mckay.tom@epa.gov