SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN Rose-Hulman Institute of Technology

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Office of Environmental Health & Safety
SPILL PREVENTION CONTROL
AND COUNTERMEASURE PLAN
Rose-Hulman Institute of Technology
Main Campus, South Campus, and Oxbridge
Prepared by: Jacob Campbell
Revised:
March 1, 2010
February 5, 2013
Office of Environmental Health & Safety
Table of Contents
SECTION
1.0
2.0
3.0
4.0
5.0
6.0
7.0
8.0
9.0
10.0
11.0
12.0
13.0
14.0
15.0
Purpose
Regulatory Reference
Scope
Responsibility
Plan Review, Certification, & Evaluation
Worker Attendance
Informed Employees
Facility Layout
Drainage Pathways and Distance to Navigable Waters
Spill Response, Emergency Procedures, and Reporting
Routine Containment Drainage
Inspections and Records
Training
Security
Management Approval and Certification
Appendices
A.
B.
C.
D.
E.
F.
G.
Emergency Contacts
Facility Layout
Emergency Generators
Above Ground Storage Tanks
Under Ground Storage Tanks
Transformers
Elevators
Prepared by: Jacob Campbell
Revised:
March 1, 2010
February 5, 2013
Office of Environmental Health & Safety
Spill Prevention, Control, and Countermeasure Plan
1.0
Purpose
The Rose-Hulman Institute of Technology Spill Prevention, Control, and Countermeasure
(SPCC) Plan is intended to provide Rose-Hulman employees a written plan which describes
the equipment, manpower, procedures, and adequate countermeasures for preventing and
controlling oil discharges.
2.0
Regulatory Reference
EPA’s 40 CFR Part 112
3.0
Scope
This plan is applicable to all operations where employees may be exposed to potential
discharge situations under normal working conditions or during an emergency situation.
4.0
Responsibility
The Manager of Environmental Health & Safety and Rose-Hulman Institute of Technology is
responsible for this plan and for ensuring the plan is available to the EPA Regional
Administrator for on-site review during normal working hours. Copies of the written plan
are located at the Office of Environmental Health & Safety in the Department of Facilities.
This plan is also available on the Office of Environmental Health & Safety website. The
Manager of Environmental Health & Safety is responsible for developing and maintaining the
plan.
The facility owner name, address, and telephone is as follows:
Rose-Hulman Institute of Technology
5500 Wabash Avenue
Terre Haute, IN 47803-3999
812-877-1511
The facility contact related to this plan is:
Jacob E. Campbell
Manager, Environmental Health & Safety
812-877-8124
812-208-2332
Additional contact related to this plan is:
Office of Public Safety
John Wolfe
Director, Public Safety
812-877-8590
Prepared by: Jacob Campbell
Revised:
March 1, 2010
February 5, 2013
Office of Environmental Health & Safety
5.0
Plan Review, Certification, and Evaluation
The plan will be reviewed and self-certified as described in accordance with Section 112.6.
Rose-Hulman Institute of Technology will amend this SPCC Plan in accordance with Section
112.7 and other applicable Section of Part 112, when there is a change in the facility design,
construction, operation, or maintenance that materially affects its potential for a discharge.
The amendment will be prepared within six months of the change. Examples of changes
that may require amendment to the plan include, but are not limited to:
•
•
•
•
Commissioning or decommissioning containers
Replacement, reconstruction, or movement of containers
Reconstruction, replacement, or installation of piping systems
Construction or demolition that might alter secondary containment structures.
Rose-Hulman Institute of Technology reviews this plan as required by the Regional
Administrator of the EPA. Amendments are then prepared within six months of the review.
Any technical amendments to our plan will be self-certified. Non-technical amendments
such as changes to names and telephone numbers are not required.
6.0
Worker Attendance
Rose-Hulman Institute of Technology is normally attended by workers at least four hours
per day.
7.0
Informed Employees
As a result of proper plan maintenance, our employees will be informed of the equipment,
manpower, procedures, and steps to prevent and control a discharge.
8.0
Facility Layout and Important Emergency Contacts
The physical layout of Rose-Hulman Institute of Technology can be found in Appendix B.
Emergency contacts in case of a discharge can be found in Appendix A.
The campus of Rose-Hulman Institute of Technology is located in Terre Haute, Indiana.
There are two creeks which run through campus, which collect the majority of the runoff
from campus.
Oil and petroleum products are present on the campus of Rose-Hulman in above and below
ground storage tanks, transformers, compressors, and multiple 55-gallon drums. The
following oil and petroleum products are found on campus: gasoline, diesel fuel,
transformer oil, lubricating oil, cooking oil, compressor fluid, motor oil, and hydraulic oil.
The products listed are used for emergency steam generation, electrical transformers,
hydraulic elevators, trash compactors, cooking equipment, compressors, and motor
vehicles. Rose-Hulman also owns a retail gas station located adjacent to main campus
which utilizes underground storage tanks for gasoline.
Prepared by: Jacob Campbell
Revised:
March 1, 2010
February 5, 2013
Office of Environmental Health & Safety
South Campus houses various groups. This property has a small pond which drains to a
small creek which leads to Honey Creek. Cutting tool coolant and machine oil is used and
stored on site. The used coolant and oil is stored in the building garage located on the
southwest corner of the building. There are two pad-based transformers containing
transformer oil at this location.
Emergency Generators
There are 11 emergency generators on main campus and 1 emergency generator on South
Campus (Ventures). Eight emergency generators are all supplied by natural gas lines and
therefore not subject to this plan. Three emergency generators are supplied by diesel fuel
and are subject to this plan. These three emergency generators are located behind Hatfield
Hall (55 gallons), in the basement mechanical of Hulman Memorial Student Union (300
gallons), and the Sports and Recreation Center mechanical room (230 gallons). A complete
list of all emergency generators on campus can be found in Appendix C.
Above Ground Storage Tanks
There are 3 above ground fuel tanks on campus with a total capacity of 1,250 gallons.
There are two above ground storage tanks located next to the Facilities building on the
northeast corner of the campus core. These tanks are both steel-double wall tanks with
leak detection and overfill protection and are located within a secondary containment
concrete dike which provides 100% secondary containment. The drain port for this
secondary containment is locked and any fluids are verified by the Office of Environmental
Health and Safety prior to draining. One of these tanks is a 500 gallon tank containing
automotive gasoline. The second tank is a 300 gallon containing diesel fuel. The third
above ground storage tanks is located behind the garage at the baseball fields, which is at
the southwest corner of campus. This tank is a 500 gallon propane tank used to heat the
garage at that location. There is no secondary containment for this tank. A complete list of
above ground storage tanks on campus can be found in Appendix D.
Underground Storage Tanks
As of July 1, 2010 there are no active underground storage tanks located on campus. A
20,000 gallon underground storage tank located behind the Hulman Memorial Student Union
was closed in place. This tank was filled with sand. A 2,000 gallon underground storage
tank located outside the Moench boiler room was removed in 2010.
The gas station owned by Rose-Hulman utilizes one 12,000 gallon tank and one 8,000
gallon tank to store gasoline. The tenant is responsible for all compliance with federal and
state laws, regulations, and requirements pertaining to these tanks. These tanks are
fiberglass coated plastic with overfill protection and leak detection.
A complete list of underground storage tanks on campus can be found in Appendix E.
Prepared by: Jacob Campbell
Revised:
March 1, 2010
February 5, 2013
Transformers
Office of Environmental Health & Safety
There are currently 21 non-PCB oil transformers located on concrete pads throughout the
main campus property. There are 3 non-PCB oil transformers located at our Oxbridge
property and 1 non-PCB oil transformers located at our South Campus (Ventures) property.
The estimated total volume of transformer oil on campus is approximately 6,403 gallons.
As defined in 40 CFR 112.1 (b), transformers are not considered bulk oil storage containers.
Rather, they are considered equipment which contains oil for operational purposes.
Subsequently, this equipment does not require secondary containment. A complete list of all
transformers on campus can be found in Appendix F.
Elevators
There are currently 9 hydraulic elevators on main campus and 1 on the south campus. The
estimated total volume of hydraulic elevator oil on campus is approximately 1,511 gallons.
As with transformers hydraulic elevator reservoirs are not considered bulk oil storage
containers because their contents are “in use”. Therefore, these hydraulic reservoirs are
exempt from secondary containment requirements. There are currently no drains located
within the elevator rooms on campus. A complete list of all elevators on campus can be
found in Appendix G.
Grease Dumpsters
Dining Services utilizes a 1,000 gallon grease pit to temporarily store waste oil associated
with cooking processes. This pit is located on the north side of Hulman Memorial Student
Union and is connected to the Dining Services grease traps. There is also a 250 gallon
double-walled grease dumpster located at the loading dock which routinely emptied by an
outside vendor.
Trash Compactors and Cardboard Balers
There are 3 hydraulic cardboard balers and 1 hydraulic trash compactor on campus. The
cardboard balers are located at the Hulman Memorial Student Union loading dock (1) and
the Recycling Building (2). The one trash compactor is located at the Recycling Building as
well.
Drums
There are various locations on campus where 55 gallon drums containing oil or petroleum
products are stored. There are 8 drums sitting on secondary containment pallets in the
Facilities buildings. These contain used oil, hydraulic fluid, and oil used in various
equipment maintained by Facilities.
9.0
Drainage Pathways and Distance to Navigable Waters
Lost Creek is the main water body which could be impacted by a spill on the campus of
Rose-Hulman Institute of Technology. Lost Creek flows westerly through campus and
continues through the city of Terre Haute, eventually flowing into the Wabash River. The
gasoline and diesel fuel storage is located 130 feet from Lost Creek. A release on campus
Prepared by: Jacob Campbell
Revised:
March 1, 2010
February 5, 2013
Office of Environmental Health & Safety
also has the potential to reach this creek via the network of storm sewer catch basins.
Honey Creek, in southern Vigo County, may be affected by a potential release at South
Campus as may the wetlands located adjacent to these properties.
10.0
Spill Response, Emergency Procedures, and Reporting
The goal of this plan is to eliminate the potential for oil spills to reach affected waterways,
minimize human exposure, and environmental impacts in the unlikely event of a spill.
Responsibility for spill cleanup depends upon whether a spill in incidental or non-incidental.
Incidental and Non-incidental spills will be determined on a case-by-cases basis.
Incidental spills are limited in quantity, exposure potential, and toxicity. Incidental spills
present minor safety or health hazards to employees in the immediate work area or those
assigned to respond. Responses to incidental spills of hazardous substances are to be
performed when the substance can be absorbed, neutralized, or otherwise safely controlled
at the time of release by the employee in the immediate area at the time of release.
Incidental spill response does not require HAZWOPER training.
Non-Incidental spills pose a significant safety or health hazard to employees working in the
immediate vicinity or to the employee cleaning up the released hazardous substance. This
type of release also has the potential to become an emergency in a short amount of time.
Responders to non-incidental spills must be trained according to the OHSA 29 CFR
1910.1200 Hazard Communication standard or the OSHA 29 CFR 1910.1450 Lab Standard.
Non-incidental spills require full HAZWOPER training.
In the event of a spill on campus, the following procedures will be followed:
1. Remove all sources of ignition. If the ignition source cannot be removed, divert
spilled substance away from the ignition source.
2. Identify the release substance and consult the appropriate Material Safety Data
Sheet.
3. Report the spill immediately to the Office of Environmental Health & Safety.
4. If the amount of spilled substance is minimal, absorb and containerize. Contact
EH&S for proper disposal methods.
5. If the amount of spilled substance is large, contain it as much as possible.
Contact EH&S and monitor area until trained response personnel arrive.
6. The EH&S Manager will determine if a reportable spill occurred. If so, notification
to the appropriate government agencies will be made followed by a written
report. Indiana Department of Environmental Management requires all spills
over 1,000 gallons be reported.
7. Spills in confined spaces must follow the procedures outlined in the Rose-Hulman
Office of Environmental Health & Safety Confined Space procedure.
8. For more information regarding spill cleanup see Appendix G of the Rose-Hulman
Institute of Technology Emergency Response Plan.
In the event of a discharge of oil to navigable waters the following information will be
provided to the National Response Center (NRC) immediately following identification of a
Prepared by: Jacob Campbell
Revised:
March 1, 2010
February 5, 2013
Office of Environmental Health & Safety
discharge to navigable waters. The Discharge Notification Form can be found in Appendix
H.
•
•
•
•
•
•
•
•
•
•
•
•
The exact address or location and phone number of the facility
Date and time of discharge
Type of material discharged
Estimate of the total quantity discharged
Estimate of the quantity discharged to navigable waters
Source of the discharge
Description of all affected media
Cause of the discharge
Any damages or injuries caused by the discharge
Actions being used to stop, remove, and mitigate the effects of the discharge
Whether an evacuation may be needed
Names of individuals and/or organizations who have been contacted
Information regarding spills will be submitted to the EPA Region Administrator (Region V)
and the Indiana Department of Environmental Management (IDEM)within sixty days of a
single discharge more than 1,000 U.S. gallons of oil to navigable water or two discharges to
navigable waters each more than 42 U.S. gallons of oil occurring within any twelve month
period. The following information must be submitted to the EPA RA and IDEM:
•
•
•
•
•
•
•
•
•
11.0
Name of the facility
Your name
Location of Facility
Maximum storage or handling capacity of the facility and normal daily throughput
Corrective action and countermeasures taken, including a description of equipment
repairs and replacements
An adequate description of the facility, including maps, flow diagrams, and
topographical maps, as necessary.
The cause of the reportable discharge, including a failure analysis of the system or
subsystem in which the failure occurred
Additional preventive measures you have taken or contemplated to minimize the
possibility of recurrence
Other information as the EPA Regional Administrator may reasonably require
pertinent to the plan or discharge
Routine Containment Drainage
The secondary containment dike containing the 500 gallon and 300 gallon fuel storage tanks
can collect rainwater and must be routinely drained. The Office of Environmental Health &
Safety is responsible for this task. Collected water must be inspected for oil sheens. If no
sheens are present, rainwater may be drained. If any sheen is found, cleanup should be
completed using the appropriate absorbents and booms. All cleanup materials must be
disposed of properly.
Prepared by: Jacob Campbell
Revised:
March 1, 2010
February 5, 2013
12.0
Inspections and Records
Office of Environmental Health & Safety
Visual inspections of the tanks and secondary containment will be conducted monthly by the
Office of Environmental Health & Safety. All inspections are documented and the records
maintained in the Office of Environmental Health & Safety. These inspections will include a
visual check for signs of leaking and tank deterioration, the containment area, and any
associated piping. In addition, internal testing will be conducted every 20 years if the tank is
not replaced at the end of their life expectancy as determined by the manufacturer.
Inspections of the transformers on campus will be conducted biennially and copies of these
inspections are kept in the Department of Buildings and Systems as well as the Office of
Environmental Health & Safety.
Elevators are serviced monthly by an outside contractor and inspected on an annual basis
by the same outside contractor.
13.0
Training
All employees involved with oil stores on campus are to be trained in the safe operation and
maintenance of oil-related equipment to eliminate the potential for spills. All training
records will be maintained in the Office of Environmental Health & Safety.
14.0
Security
Rose-Hulman Institute of Technology maintains an Office of Public Safety which coordinates
all activities related to the local emergency response agencies. Public Safety maintains
regular security patrols and the campus is sufficiently lit to allow for the discovery of any
spills during evening hours. The Office of Environmental Health & Safety can be contacted
after hours through the Office of Public Safety. The Department of Facilities has personnel
on call in the event of any issues related to the operation of campus. The fuel storage tanks
are padlocked when not in use and only Facilities staff have keys to these pumps.
Prepared by: Jacob Campbell
Revised:
March 1, 2010
February 5, 2013
Office of Environmental Health & Safety
Certification
I hereby attest that I have completed my review and evaluation of the SPCC Plan for RoseHulman Institute of Technology:
Name: _______________________
Signature: ______________________
Date: _____________________
Review and evaluation will amend plan as a result? ______
Management Approval
We are committed to the prevention of discharges of oil to navigable waters and the
environment. This plan has the full approval of management at a level of authority to
commit the necessary resources to fully implement it.
Title: ____________________________
Signature: ___________________________
Date: ____________________
Prepared by: Jacob Campbell
Revised:
March 1, 2010
February 5, 2013
Office of Environmental Health & Safety
Appendix A
A list of emergency contacts that would be needed in the unlikely event of a major spill at
Rose-Hulman Institute of Technology include the following:
SPCC Facility Response Coordinator (Office of EH&S)
812-877-8124
Office of Public Safety (After hours & Weekends)
812-877-8590
Terre Haute Fire Department
Hazardous Materials Response Team
812-234-8653
Indiana Department of Natural Resources: Spill Line
317-233-7745
Prepared by: Jacob Campbell
Revised:
March 1, 2010
February 5, 2013
Office of Environmental Health & Safety
Appendix B
Prepared by: Jacob Campbell
Revised:
March 1, 2010
February 5, 2013
Office of Environmental Health & Safety
Appendix C
Emergency Generators
Location
Fuel Type
KW
Secondary
Containment
Install
Date
Diesel
Tank
Capacity
(gal)
47
Hatfield Hall
10
No
2001
Hulman Memorial Student Union
Diesel
250
180
No
Sports and Rec Center
Diesel
195
135
No
1997
Crapo Hall
Natural Gas
N/A
150
N/A
2006
Deming Hall
Natural Gas
N/A
7
N/A
2006
Facilities
Natural Gas
N/A
10
N/A
2006
Lakeside Hall
Natural Gas
N/A
80
N/A
2012
Moench Hall
Natural Gas
N/A
150
N/A
2006
Olin Hall
Natural Gas
N/A
10
N/A
2006
Public Safety
Natural Gas
N/A
25
N/A
2009
Scharpenberg Hall
Natural Gas
N/A
15
N/A
1999
Prepared by: Jacob Campbell
Revised:
March 1, 2010
February 5, 2013
Office of Environmental Health & Safety
Appendix D
Above Ground Storage Tanks
Tank
Location
Contents
500 Gallon Steel
Facilities
Gasoline
300 Gallon Steel
Facilities
Diesel Fuel
Prepared by: Jacob Campbell
Revised:
March 1, 2010
February 5, 2013
Office of Environmental Health & Safety
Appendix E
Underground Storage Tanks
Tank
Location
Contents
12,000 Gallon Fiberglass
Gas Station
Gasoline
8,000 Gallon Fiberglass
Gas Station
Gasoline
Prepared by: Jacob Campbell
Revised:
March 1, 2010
February 5, 2013
Office of Environmental Health & Safety
Appendix F
Transformers
Location
Serial #
Branam Innovation
Center
Capacity
(gal)
kva
Mount
Owner
PCB
135
150
Concrete Pad
Rose-Hulman
N
Crapo Hall
89J442027
190
500
Concrete Pad
Rose-Hulman
N
Deming Hall
PDH1016
135
150
Concrete Pad
Rose-Hulman
N
Facilities
1552230998
319
150
Concrete Pad
Rose-Hulman
N
Hatfield Hall
137011722
251
500
Concrete Pad
Rose-Hulman
N
Hatfield Hall
13701156
299
500
Concrete Pad
Rose-Hulman
N
HMSU
950452A1
705
2000
Concrete Pad
Rose-Hulman
N
Intramural Fields
1161880398
131
150
Concrete Pad
Rose-Hulman
N
Concrete Pad
Rose-Hulman
N
Lakeside Hall
229
Logan Library
17334684
336
500
Concrete Pad
Rose-Hulman
N
Lower Dorms
F51934
135
150
Concrete Pad
Rose-Hulman
N
Moench Hall
20141962001
336
1000
Concrete Pad
Rose-Hulman
N
Myers Hall
1512260898
392
500
Concrete Pad
Rose-Hulman
N
Myers Hall
1613531098
448
1000
Concrete Pad
Rose-Hulman
N
Apartment Res Hall
337015243
423
840
Concrete Pad
Rose-Hulman
N
Olin Hall
96900719
484
1000
Concrete Pad
Rose-Hulman
N
Oxbridge
17
25
Pole
Duke Energy
N
Oxbridge
17
25
Pole
Duke Energy
N
Oxbridge
17
25
Pole
Duke Energy
N
Concrete Pad
Rose-Hulman
N
Recycle Building
Rotz Lab
880849A1
Ventures
215
500
Concrete Pad
Rose-Hulman
N
143
300
Concrete Pad
Duke Energy
N
Concrete Pad
Duke Energy
N
Ventures
Speed Hall
N241264
255
750
Concrete Pad
Rose-Hulman
N
SRC
Stadium
960471A1
75G020157
525
266
2000
500
Concrete Pad
Concrete Pad
Rose-Hulman
Rose-Hulman
N
N
Prepared by: Jacob Campbell
Revised:
March 1, 2010
February 5, 2013
Office of Environmental Health & Safety
Appendix G
Elevators
Building
Capacity (gal)
Hatfield Hall
90
Hulman Memorial Student Union (Freight)
Hulman Memorial Student Union
(Passenger)
Logan Library
70
170
Moench Hall (B-Section)
90
Moench Hall (E-Section)
120
Myers Hall
150
New Apartment Res Hall (East)
150
New Apartment Res Hall (West)
150
90
New Olin
16
Old Olin
75
Percopo Hall
150
South Campus (Ventures)
80
Sports and Rec Center
110
Prepared by: Jacob Campbell
Revised:
March 1, 2010
February 5, 2013
Office of Environmental Health & Safety
APPENDIX H
Prepared by: Jacob Campbell
Revised:
March 1, 2010
February 5, 2013
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