SPCC Marina Inspection Update 2018 Oklahoma Marina Association

SPCC Marina Inspection Update - 2018 Oklahoma Marina Association Inspector Tom Mc. Kay

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: – – 6 Name Registration number and State Date of Certification PE seal affixed to Plan

Qualified Facility Applicability If the facility total aboveground oil storage capacity is 10, 000 gallons or less … And the facility has… Then the facility is a: Tier I Qualified Facility: No individual aboveground Complete and self-certify oil containers greater than Plan template (Appendix G Within three years prior to the 5, 000 gallons; to 40 CFR part 112) in lieu of Plan certification date, or since a full PE-certified Plan. 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 Tier II Qualified Facility: navigable waters or adjoining Prepare a self-certified Plan shorelines exceeding 1, 000 Any individual aboveground in accordance with all gallons, or oil container greater than applicable requirements of Two discharges of oil to 5, 000 gallons; § 112. 7 and subparts B or C navigable waters or adjoining of the rule, in lieu of a PEshorelines each exceeding 42 certified Plan. gallons within any 12 -month period. 1

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

Co Totes and Drums not in secondary containment m Common m Vi on ol Violation at io n

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 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 Implementation Identify Standard Used STI SP 001 Conduct & Record external inspections per standard used Best Standard for Marinas API 653 Identify Inspection and Testing Protocols External inspection Shell Testing(ultrasonic) Conduct & Record Nondestructive shell thickness testing; ie ultrasonic or hydrostatic.

STI SP 001 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) SP 001 Standard

STI SPOO 1 Inspection Protocols For Typical Marina Tanks

STI SP 001 - 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 SP 001 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 Mc. Kay • Office Phone: (214) 665 -2180 • E-Mail: mckay. tom@epa. gov