Spill Prevention, Control, and Countermeasure Plan (SPCC)

Policy

The University of Chicago shall maintain a Spill Prevention, Control and Countermeasure (SPCC) Plan as required by the United States Environmental Protection Agency (US EPA) to prevent any discharge of oil into or upon navigable water of the United States or adjoining shorelines.

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Applicability

The SPCC Plan applies to non-transportation-related onshore or offshore facilities engaged in drilling, producing, gathering, storing, processing, refining, transferring, distributing, using or consuming oil and oil products.

These facilities shall meet the following criteria:

  • The facility must be non-transportation-related;
  • There must be an aggregate aboveground storage capacity greater than 1,320 gallons or a completely buried storage capacity greater than 42,000 gallons (excluding those tanks and oil filled equipment below 55 gallons in capacity); and
  • If due to its location, the facility could reasonably be expected to discharge oil into or upon the navigable water or adjoining shorelines of the United States.

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Authority and Responsibility

Environmental Health and Safety (EHS) is responsible for:

  • Maintaining and modifying the SPCC Plan as necessary for the University and the Medical Center;
  • Monthly inspections of tanks without secondary containment, excluding the hydraulic elevator oil tanks;
  • Annual inspections of tanks with secondary containment, excluding the hydraulic elevator oil tanks;
  • Responding to a reported incident in a timely manner;
  • Responding with appropriate action to control and remedy the incident;
  • Providing training to personnel who work with fuel oil tanks;
  • Amending the SPCC Plan whenever there is a change in facility design, construction, operation or maintenance that materially affects the facility’s spill potential;
  • Providing oil spill kits on campus as required by the SPCC regulation;
  • Checking campus oil spill kit inventory on a semi-annual basis and re-stocking kits as necessary; and
  • Respond to oil spills when requested by University personnel.

Safety and Environmental Compliance is responsible for:

  • Collaborating with EHS to review the SPCC Plan;
  • Report any tank failures and/or oil spills entering the drains to EHS; and
  • Respond to reported incidents according to the University of Chicago Medicine "Hazardous Material Emergency Response Plan".

Facilities Services - Operations is responsible for:

  • Ensuring the University’s elevator contractor performs annual inspections of hydraulic elevator oil tanks;
  • Ensuring that ‘bulk storage containers’ as defined in 40 CFR 112.2 undergo tank integrity testing (often referred to as thickness testing) every five years;
  • Recordkeeping for tank integrity testing;
  • Providing Environmental Health and Safety with copies of records;
  • Responding with appropriate action to control and remedy an incident;
  • Notifying the University Police and EHS of a spill or release; and
  • Attending training on an annual basis.

Physical Plant is responsible for:

  • Ensuring weekly inspections of the Medical Center hydraulic elevator oil tanks;
  • Providing oil spill kits as required by the SPCC regulation within the Medical Centers;
  • Checking oil spill kit on a semi-annual basis and re-stocking kit as necessary;
  • Cleaning up spills as necessary;
  • Informing EHS when there is a change in facility design, construction, operation or maintenance that materially affects the facility's spill potential within the Medical Centers;
  • Responding to an incident according to the University of Chicago Medicine "Hazardous Material Emergency Response Plan";
  • Notifying EHS and Safety and Environmental Compliance of a spill or release of oil into drains, navigable water or adjoining shorelines; and
  • Attending training on an annual basis.

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SPCC Plan Components

SPCC Plans shall address the following areas:

  • A description of the University’s location, proximity to navigable waterways, and use of oil;
  • Spill history at the University;
  • Potential spill volumes of the various oil tanks around campus;
  • Spill response procedures;
  • Emergency response procedures;
  • Emergency phone numbers;
  • Notification requirements; and
  • Training requirements.

EHS currently maintains a copy of the University of Chicago SPCC Plan and the locations of oil sources throughout campus and the medical centers (aboveground storage tanks and hydraulic elevator locations).

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Notification Requirements

Internal Facility Notification for University Campus

Notification procedures upon discovery of an oil spill into the environment:

  • Notify the University of Chicago Police Department (UCPD) by dialing 123 or 773-702-8181;
  • The UCPD shall immediately page the "On-Call" Safety Officer;
  • The "On-Call" Safety Officer, upon receiving the page, shall contact the UCPD Dispatcher and gather information pertaining to the incident;
  • The "On-Call" Safety Officer shall notify the Director of Environmental Health and Safety or Senior Safety Officer in his/her absence regarding the incident; and
  • The Director of Environmental Health and Safety or Senior Safety Officer in his/her absence are the individuals having full authority to implement and manage an emergency response.

Internal Facility Notification for the University of Chicago Medicine

Notification procedures listed in the University of Chicago Medicine "Hazardous Material Emergency Response Plan" shall be followed.

Regulatory Notification

The Director of Environmental Health and Safety shall immediately notify the National Response Center (NRC) (800-424-8802), Illinois Emergency Management Agency (IEMA) (800-782-7860) and the City of Chicago - Office of Emergency Management (OEM) (312-746-9111) if the discharge of oil:

  • Exceeds 25 gallons on land;
  • Violate applicable water quality standards;
  • Cause a film or sheen upon or discoloration of the surface of the water or adjoining shorelines; or
  • Cause a sludge or emulsion to be deposited beneath the surface of the water.

The following spill information shall be submitted to the EPA Regional Administrator within 60 days in the event of a discharge of more than 1,000 gallons of oil in a single discharge or a discharge of more than 42 gallons of oil in each of two discharges within a 12 month period.  The report shall contain the following information:

  • Name of the facility and the owner or operator of the facility;
  • Name of the individual submitting the information;
  • Location of the facility;
  • Maximum storage handling capacity of the facility and normal daily throughput;
  • The corrective actions and/or countermeasures taken, including an adequate description of equipment repairs and/or replacements;
  • Description of the facility including maps, flow diagrams and a topographical map;
  • The cause(s) of such spill(s), including a failure analysis of system or subsystem in which failure occurred;
  • Additional preventive measures taken or contemplated in order to minimize the possibility of recurrence; and
  • A complete copy of the SPCC Plan with any amendments.

IEMA shall also be contacted in the event that someone is killed, hospitalized or if the facility is evacuated by the authorities.

Metropolitan Water Reclamation District (MWRD) shall be notified via phone and sent a completed notification report (RD-116 form) within five calendar days if more than 1,000 gallons or more than 42 gallons of oil in each of two discharges reaches any sewer.

The SPCC plan shall be amended by EHS within six months whenever there is a change in the campus and medical center facility design, construction, operation, or maintenance that materially affects the facility’s spill potential.

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Spill Response Procedures

The primary goal of responding to an oil spill is to prevent oil from reaching the sewers. The following steps shall be taken to meet this objective:

  • Don personal protective equipment;
  • Encircle the spill using oil-dri or absorbent boom to surround the spill beginning in the direction of the flow (downhill);
  • Once spill is surrounded, apply absorbent pads, pillows and/or oil-dri moving toward the center of the spill;
  • After all oil has been absorbed, place all materials into garbage bag(s) or other sealable container using non-sparking equipment (e.g., shovel); and
  • All waste shall be disposed of hazardous waste and picked up by the hazardous waste contractor.

EHS shall respond to oil spills when requested by University personnel and arrange for hazardous waste pick-ups.

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Inspections and Records

The Tank Inspection Checklist provides a guide to use during monthly and annual inspections. The inspector shall record any comments in addition to his/her name and the inspection date directly onto the checklist and provide a copy to EHS. The record with the original files shall be on file for three years. The items covered in the inspections are performed in accordance with American Petroleum Institute (API) standards and good engineering practices. The inspector shall report any unsatisfactory conditions to the department managing the tanks and EHS. The Director of Environmental Health and Safety or Senior Safety Officer in his/her absence shall be responsible for ensuring any unsatisfactory conditions are corrected. The hydraulic elevator tanks on campus and in the medical center must be tested annually for the presence of metals to determine if the tank is corroding.

SPCC-regulated tanks on campus without secondary containment must be inspected monthly by EHS, not including hydraulic elevator tanks.  Currently, this applies to the six 100-gallon tanks at the South Steam Plant.  Monthly tank inspections are completed by using the iPhone App, Orange QC.

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Training

All oil-handling personnel shall be properly instructed in the operation and maintenance of equipment to prevent the discharge of oil. Supervisors shall observe the performance of all employees and advise them of appropriate operational and maintenance procedures when required.

Training is required annually and includes oil spill prevention, containment, retrieval methods, applicable pollution control laws, rules, and regulations.

Reviewed: June 30, 2015

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