The

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The
Spill Prevention Control and Countermeasure Plan
(SPCC) Pollution Incident Prevention Plan (PIPP)
Presented by
Environment, Health and Safety Department
Training Materials adopted from The University of
Michigan Dept. of Occupational Safety and
Environmental Health
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Agenda

• Overview of each specific plan
• What it is
• What regulations address it
• Effects of each plan
• Personnel involvement
• Test Questions

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Spill Prevention Control and Countermeasure Plan
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What is the SPCC Plan?

• SPCC stands for Spill Prevention Control and
  Countermeasure
• The Plan required by the United States
  Environmental Protection Agency under 40 CFR 112
• The Plan outlines measures to prevent the
  discharge of oil into navigable waters

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Definition of Oil

• The Plan covers ALL forms of oil. The definition
  of oil according to 40 CFR 112 is
• Oil of any kind or in any form, including but not
  limited to petroleum, fuel oil, sludge, oil
  refuse, kitchen grease, and oil mixed with wastes

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Who is Required to Implement the Plan?

• A facility is required to implement a SPCC Plan
  if any of the following apply
• Total underground storage capacity is greater
  than 42,000 gallons or
• An aggregate above ground storage capacity is
  greater than 1,320 gallons, and
• There is a reasonable expectation that a
  discharge could reach navigable waterways.

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What is Required Under the Regulations?

• The regulations require all affected facilities
  to have the following in place.
• A Written Plan
• Oil Storage Management/ Control
• UM Personnel Involvement
• Inspections
• Spill Prevention and Spill Control
• Record keeping

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Requirements of the Written Plan

• The Plan must incorporate the following
  information
• General Information List facility contacts and
  numbers, address
• Facility Description Describe the campus, the
  facility population, the operations of the
  facility, etc.
• Facility Drainage Describe the drainage areas
  on a map locate all storm drains and waterways
  nearby and show drainage location by using a
  flow arrow.
• Oil Storage, Distribution Use The various
  storage containers on campus are 55-gallon drums,
  underground and aboveground storage tanks,
  transformers, oil/water separators, and portable
  tanks.

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Requirements of the Written Plan

• Spill History List all spills that affected the
  navigable waterways in the past three years.
• Prevention Controls overfill protection, high
  liquid level alarms, automatic shutoff, leak
  detection, and appropriate cathodic protection.
• Loading and Unloading Ensure catchment is in
  place to hold the largest inner single
  compartment of the delivery truck.
• Spill Response Plan A plan to show how to
  respond to any emergencies OSEH and DPS have
  been trained and would be primary responders.

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Requirements of the Written Plan

• Inspections, Tests, and Records Inspections and
  tests are required to ensure there are no leaks
  from oil containers records are to be kept on
  file for three years.
• Annual Personnel Training An annual refresher
  is required to update personnel on any changes.
• Security Ensure all oil containers are secured
  so no oil is released to the environment.

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Oil Storage Management Control

• Lighting Must be adequate enough to be able to
  discover any spills
• Security Ensure containers are secured so oil
  is not released to the environment. This
  includes fences, entry gates, pad locks on the
  fill ports, and guards.
• Secondary Containment All containers must have
  secondary containment ensure all releases are
  caught before entering a waterway.
• Catchment during loading and unloading fuel
  Ensure catchment can hold the capacity of the
  largest inner single compartment of the delivery
  truck.

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Unloading and Loading Catchment Examples
Storm drain temporary cover
Portable spill containment berm
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U of M Personnel Involvement

• Personnel are responsible for the following
• Monthly or quarterly inspections
• 55-gallon drums of oil must be inspected monthly.
• All aboveground underground storage tanks must
  be inspected quarterly
• One Exception - FWT UST must be inspected
  monthly.
• Spill prevention and spill control
• Contain all releases with absorbent material if
  the scene is safe. If the scene is not safe,
  contact EHS at 766-6763 or 919-1709.
• Record keeping
• All inspection records must be complete, signed
  and kept on site for at least three years.
  Originals mailed to EHS.
• Document repairs, corrections etc.

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In Case of Spill !!

• In the event of a spill, if it is safe, attempt
  to stop and contain the spill as much as possible
  with oil dry, towels, or other absorbent
  materials.
• If the scene is not safe, contact DPS at 762-3335
  and follow up with EHS at 810-766-6763 or
  810-919-1709.
• If spilled oil enters a storm drain, contact DPS
  at 762-3335 and follow up with EHS at
  810-766-6763 or 810-919-1709.

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SPCCTEST

• 1. The SPCC Plan regulates the following
  pollutant.
• a. Water
• b. Salt
• c. Oil
• Soil
• 2. Which of the following is a form of oil that
  is regulated by 40 CFR 112?
• a. Kitchen grease
• b. Gasoline
• c. Diesel Fuel
• All the above
• 3. How many years do the records need to be kept
  on file?
• a. 3 years
• b. 3 months
• c. forever
• 7 years
• Which containers are required to be inspected
  monthly?

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Pollution Incident Prevention Plan
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Pollution Incident Prevention Plan

• Affected facilities are required to have a Plan
  in place according to Michigan Part 5 Rules,
  Spillage of Oil and Polluting Materials.
• A PIPP is required if a facility exceeds the
  threshold management quantity, for oil, salt, or
  any polluting material listed in Table 1 (a list
  with 960 chemicals).
• Threshold management quantity is the total amount
  of chemical in one discrete area that determines
  if a facility is required to implement a PIPP and
  provide secondary containment.

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Pollution Incident Prevention Plan

• The PIPP is intended to prevent releases of
  polluting materials to surface waters or ground
  waters of the state.
• Polluting Materials
• Oil
• Salt
• Any material specified in table 1 ( 960
  chemicals)
• Any compound or product that contains 1, or
  more, by weight, of oil, salt or any material
  listed table 1.

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PIPP Content

• The Plan must incorporate the following
  information
• Identification Information
• Facility name and description
• Facility contacts and numbers
• 24 hour emergency phone number(s)
• Facility description and operations
• Spill clean-up responders
• University of Michigan OSEH
• Youngs Environmental Cleanup Inc.

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PIPP Content Contd

• The Plan must incorporate emergency notification
  procedures.
• All notifications go through OSEH 763-4568.
• OSEH will contact the necessary outside entities.

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PIPP Content contd

• The Plan must also incorporate spill control and
  cleanup procedures.
• The CPP Operational personnel working in the
  plant are trained in PPE and hazard
  communication.
• In the event of a spill and the area is safe, try
  to control the spilled material. If the area is
  unsafe call OSEH at 763-4568.
• U of M OSEH department will notify the Michigan
  Department of Environmental Quality (MDEQ) if
  necessary. A written report of the incident must
  be mailed to MDEQ within 10 days.
• Spill clean up procedures for CPP personnel
• Notify the appropriate response coordinator
• Sound the alarm and evacuate personnel
• Attempt to control the situation
• Assist the spill response personnel

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PIPP Content contd

• In the event of a spill release, the following
  steps must be implemented
• Stop the source of the release by shutting off
  pumps, closing valves, removing product from
  vessels that are suspected to be leaking
• Contain the release in diked areas, enclosures,
  with absorbent booms, etc (located near west
  door)
• Clean up the spill

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PIPP Content contd

• A chemical inventory must be incorporated in the
  Plan.
• The CEP stores the following polluting materials
  in bulk
• Sodium hydroxide, sulfuric acid, no.2 fuel oil,
  sodium chloride, turbine and transformer oil.
• Storage of all polluting materials exceeding the
  threshold management quantity and stored in
  containers 10 gallons or larger must have
  secondary containment.

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MSDS Location

• The Plan must list where material safety data
  sheets (MSDS) are located for the polluting
  materials exceeding the threshold management
  quantity.
• The CEP MSDSs are located in a binder located in
  the control room of the CEP. Additionally, EHS
  maintains copies of MSDSs provided TO EHS by
  departments.
• EHS can be contacted at 766-6763 if one needs a
  MSDS.

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Plan Updates

• The facility owner or operator shall evaluate the
  Plan every 3 years or after any release that
  requires implementation of the plan.
• EHS and Facilities Management personnel review
  the plan annually to ensure the plan is updated.
• If there are changes, the plan is revised i.e.
  new emergency contacts, new tanks, etc.

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PIPP TEST

• 1. The PIPP Plan regulates the following
  pollutant(s).
• a. Water
• b. Salt
• c. Oil
• All the above
• 2. Where are the CEPs MSDSs located?
• a. CEP Control Room
• b. Hubbard Building front office
• c. Lunch room
• Tim Bardens office
• 3. The PIPP is intended to prevent releases of
  polluting materials to surface waters or ground
  waters of the state.
• a. True
• b. False
• Which of the following is part of the CEP spill
  clean up procedures?
• Notify the appropriate response coordinator

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Questions Please contact Environment, Health and
Safety at 766-6763 or 919-1709