SPCC Marina Inspection

Update - 2018

Oklahoma Marina Association

Inspector Tom McKay

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

5

No SPCC Plan

• 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.

Common Violation

6

No PE Certification

• 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:

– Name

– Registration number and State

– Date of Certification

– PE seal affixed to Plan

Common Violation

Qualified Facility ApplicabilityIf the facility total aboveground oil storage capacity is 10,000 gallons or less …

And… And the facility has… Then the facility is a:

Within three years prior to the

Plan certification date, or since

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

navigable waters or

adjoining shorelines

exceeding 1,000 gallons, or

• Two discharges of oil to

navigable waters or

adjoining shorelines each

exceeding 42 gallons within

any 12-month period.1

No individual aboveground

oil containers greater than

5,000 gallons;

Tier I Qualified Facility:

Complete and self-certify

Plan template (Appendix G

to 40 CFR part 112) in lieu of

a full PE-certified Plan.

Any individual aboveground

oil container greater than

5,000 gallons;

Tier II Qualified Facility:

Prepare a self-certified Plan

in accordance with all

applicable requirements of

§112.7 and subparts B or C

of the rule, in lieu of a PE-

certified Plan.

8

No Records

• 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 **

Common Violation

Totes and Drums not in

secondary containment

Common Violation

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

Inadequate containment 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

Identify Standard Used

STI SP001

Best Standard for Marinas

API 653

Identify Inspection and

Testing Protocols

External inspection

Shell Testing(ultrasonic)

Implementation

Conduct & Record

external inspections per

standard used

Conduct & Record Non-

destructive shell

thickness testing; ie

ultrasonic or hydrostatic.

STI SP001 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) SP001 Standard

STI SPOO1 Inspection Protocols For Typical Marina Tanks

STI SP001 - 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 SP001

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 1st

• 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 McKay

• Office Phone: (214) 665-2180

• E-Mail: mckay.tom@epa.gov