Implementing SPCC Requirements and Storm Water BMPS at a Large Industrial Facility
Recently, much attention has been focused on storm water pollution prevention and spill management. The U.S. Environmental Protection Agency (EPA) issued its Final Rule for Oil Pollution Prevention (40 CFR Part 112) on July 17, 2002, making major changes to the original rule issued in 1973. Facilities subject to this regulation must amend their Spill Prevention, Control, and Countermeasure (SPCC) plan and implement all requirements of the 2002 final rule by October 31, 2007.
The East Tennessee Technology Park (ETTP) in Oak Ridge, Tennessee, is a large U.S. Department of Energy (DOE) facility undergoing environmental cleanup under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), while at the same time it is being converted into a private industrial park. The site’s SPCC plan has been amended to meet all requirements of the 2002 final rule, and much progress has been made in implementing new requirements.
The SPCC plan for the ETTP includes a new facility diagram which marks the location and contents of each oil container, oil storage area, and storage tank for hazardous chemicals. Individual electrical transformers and other equipment that uses oil are marked on the diagram. The facility diagram also shows the complete storm drain system with 121 permitted outfalls and 14 oil skimmers. Arrows are included to indicate general surface flow directions.
SPCC training requirements are being satisfied at ETTP with a Web-based SPCC training module and a discharge prevention briefing that is presented annually to all oil-handling personnel. Fuel trucks are used throughout ETTP to support the CERCLA cleanup activities. Therefore, a required reading was developed that provides specific instructions on how personnel must comply with the SPCC requirements applicable to fuel truck operations.
The ETTP also makes extensive use of best management practices (BMP) plans contained in the facility’s storm water pollution prevention plan (SWPPP). Certain guidance included with the BMP plans has proven to be very effective for storm water pollution prevention at ETTP. One example is an accumulated water discharge request form that must be completed in order to discharge certain types of non-hazardous water to the environment. This form ensures that appropriate characterization is performed, release limits are not exceeded, and the discharge has minimum adverse impact on the environment.
BMP plans related to storm water pollution prevention are maintained for specific operations at the ETTP such as the wastewater treatment unit and the on-site garage. BMP plans have also been prepared for general site activities including maintenance of vegetation along waterways, herbicide application, controlling erosion and sediment during construction activities, and concrete truck washout. New BMP plans are prepared as needed and added to the SWPPP.
The new SPCC regulations related to storm water pollution prevention and spill management have major implications and present many challenges for large industrial facilities. The ETTP has met these challenges through SPCC plan implementation and effective use of site-specific storm water BMPs.
On July 17, 2002, the EPA issued its final rule (EPA 2002) amending the Oil Pollution Prevention regulation (40 CFR part 112) promulgated under the authority of the Federal Water Pollution Control Act of 1972, as amended, or Clean Water Act (CWA). The rule includes requirements for owners and operators of certain non-transportation-related facilities to prepare, amend, and implement SPCC plans, and in some cases to prepare facility response plans. Subparts A through C of 40 CFR part 112 are often referred to as the “SPCC rule.” The main focus of the SPCC rule is preventing discharges of oil to navigable waters and adjoining shorelines.
The EPA proposed revisions to the original SPCC rule of 1973 on three occasions, in 1991, 1993, and 1997. The SPCC final rule that was published on July 17, 2002 (EPA 2002) incorporated many of the proposed revisions and added many new requirements for facilities subject to the regulation.