The Environmental Protection Agency (EPA) recently fined a university $20,964 for releasing about 3,500 gallons of diesel fuel into a tributary. As part of the settlement, the university will also update their Spill Prevention Control and Countermeasures (SPCC) plan to include best management practices (BMPs) to prevent future oil discharges, establish standard operating procedures (SOPs) for fuel transfer options, implement the BMPs and SOPs named in the plan, train employees on the updates and inventory all aboveground and underground storage tanks on their campus.
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Among the containers and tanks onsite, the university has two 30,000-gallon aboveground storage tanks that store diesel fuel for the central heating plant. This fuel produces energy to heat the water that’s circulated throughout campus.
In January 2015, a return line was closed during a fuel transfer between the two aboveground tanks and overflowed the receiving tank. The fuel entered a storm drain that discharged into a tributary that leads to the Potomac River.
The university did have an SPCC plan and was prepared to respond. They immediately prevented additional fuel from entering the drain and worked quickly to prevent the discharge from getting further downstream. After containing the fuel, the university also worked with their state’s environmental department and a contractor to remediate the affected drains, ditches and soil.
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Because the university was prepared to respond to this spill, they were able to contain it quickly and prevent it from reaching the Potomac River. This type of response is a form of active containment.
In many instances, active secondary containment measures are acceptable and work well. But, someone needs to be available to deploy the containment device.
Using passive containment eliminates the need for human intervention because the secondary containment device, system, product or method is always in place and ready to go. The most common forms of passive secondary containment are containment dikes, sumps and pallets.
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Although passive secondary containment is generally preferred, it’s not always practical or possible for every area or process. Many facilities use a combination of active and passive containment to prevent and respond to spills.
Some popular BMPs and active containment methods include:
- Covering storm drains with drain covers or other devices that seal the drain before fluids are transferred to prevent anything from entering the storm drain
- Requiring an appropriate number of trained personnel to be onsite and ready to immediately respond to a spill before it can reach a drain
- Using absorbents to contain a spill so that it does not reach a drain or any other environmentally sensitive area
- Manually engaging dikes, weirs or other containment devices before liquid transfers begin or in response to a spill
The EPA requires facilities with an SPCC plan to review it whenever something onsite changes, or at least every five years. Facilities are also required to train affected employees on the SPCC plan and their roles regarding oil spill prevention, spill notification, containment and cleanup.
Reviewing plans and hosting drills regularly can help to uncover procedures that are outdated or simply aren’t effective. They can also help determine if SOPs are being followed each time oil is transferred — potentially preventing a discharge and subjecting the facility to fines and cleanup costs.
Does your facility need an SPCC plan? Download this white paper to find out.