Spill Prevention and Control Planning Services
Posted on July 13, 2015
Client: Spill Prevention and Control Planning Services
Project Type: Compendium of Private Sector Clients
The firm has provided engineering services to a number of large corporate clients, gas and electric utilities and commuter railroads in supporting full-service multimedia environmental compliance programs, many of which include management of chemical and petroleum bulk storage facilities, the preparation of Contingency Plans, Emergency Preparedness and Prevention Plans, as well as preparation of and/or updating of SPCC Plans. As part of these services, the firm typically conducts site inspections, tank integrity assessments, compliance audits, the review and preparation of major oil storage facility licenses and CBS/PBS registration, contingency plans, facility response plans and permit applications, as well as auditing the facilities’ current operations to assess compliance with the many nuances of various environmental regulatory programs of the New York State Department of Environmental Conservation and United States Environmental Protection Agency.
The firm has provided Spill Prevention and Control Planning Services for the following New York City metropolitan area and New York State facilities:
• Consolidated Edison Company of New York, Inc.
• Northrop Grumman Corporation (formerly Grumman Aerospace Corporation), Bethpage and Calverton Facilities, New York
• PETRO (Petroleum Heat and Power Corporation), Southampton, New York
• Entenmann’s, Inc., Inez and Fifth Avenue Facilities, Bay Shore, New York
• International Business Machines Corporation, East Fishkill, New York
• Safety-Kleen Corp., Buffalo, New York
• United States Merchant Marine Academy, Kings Point, New York
• Rochester Regional Healthcare Association/Joint Ventures Corporation
Consolidated Edison Company of New York, Inc.
– SPCC Plans for 13 Facilities in New York
The firm was retained by Consolidated Edison to prepare and/or update Spill Prevention, Control and Countermeasure Plans for the fossil fuel and gas turbine power generating stations located in the New York metropolitan area. These facilities included the following:
• 59th Street Generating Station
• 60th Street Steam Station
• 74th Street Generating Station
• East River Generating Station
• Hudson Avenue Generating Station
• Waterside Generating Station
• North First Street Fuel Oil Terminal
• Arthur Kill Generating Station
• Astoria Gas Turbine Site
• Astoria Generating Station
• Astoria PCB Storage Facility
• Astoria Transformer Shop
• Ravenswood Generating Station and Gas Turbine Site
As part of this major assignment, the firm conducted detailed engineering inspections at each of these complex facilities to confirm and update the inventory and capacity of both above and underground petroleum storage tanks at each generating station. The firm then reviewed information related to petroleum spill prevention and control for the facilities, including the portions of the facilities used for storage, loading/unloading and transfer of oil, secondary containment facilities and storm water collection and conveyance. Specific activities that were conducted included: review of current SPCC Plan; site inspections to evaluate the adequacy of the secondary containment systems and the location of all petroleum tanks; and evaluation of potential spill direction, rate and total quantity of oil which could be discharged from the facility as a result of each major type of failure.
Following the information review and facility inspection, the firm prepared an SPCC Plan for each of the 13 facilities. Preparation of the SPCC Plan involved incorporating applicable provisions of 40 CFR Part 112 into the SPCC Plan. The firm also reviewed the hazardous waste contingency plan for each facility to ensure consistency with the SPCC Plan.
Northrop Grumman Corporation
– SPCC Plans for Bethpage and Calverton
Northrop Grumman Corporation is a Department of Defense contractor engaged in the manufacture of aircraft and aerospace products including sophisticated electronic support and navigational equipment. On Long Island, it operates a number of facilities in Nassau and Suffolk Counties including plants in Bethpage and Calverton. The firm is one of Grumman’s principal environmental engineering consultants and has provided Grumman Aerospace Corporation (GAC) with quality environmental services since 1975.
This project called for the update and preparation of Spill Prevention Control, and Countermeasure (SPCC) Plans at two major Grumman facilities (Bethpage and Calverton) in accordance with Article 12 of New York State’s Navigation Law. Components of this plan were also utilized to comply with aspects of Grumman’s RCRA hazardous waste management program. The elements of a typical SPCC include:
• General Site Information
• Facility Description
• Spill History
• Potential Spill Prediction and Control
• Facility Drainage
• Bulk Storage Tanks
• Transfer Operations
• Tank Truck Loading and Unloading
• Inspections and Record Keeping
• Personnel Training
• Oil Spill Contingency Plan
• Administrative Controls
Petroleum Heat and Power Corporation (PETRO)
– Environmental Compliance Program
PETRO is one of the largest fuel oil retailers in the Northeast. PETRO retained the firm to provide full service engineering in areas of environmental compliance, design and implementation of subsurface soil and groundwater investigations, oil recovery programs, tank inspection and testing program, tank registrations and permits, tank closures and general assurance that its New York facilities are in compliance with applicable USEPA, New York State and Nassau and Suffolk County environmental requirements.
As part of its work on the Petroleum Bulk Storage Compliance Program for the Southampton Facility, the firm completed a compliance audit of a major petroleum bulk storage facility with federal, state and local county health department regulations.
A detailed facility wide environmental compliance audit and engineering inspection of all aboveground and underground fuel oil storage tanks to assure compliance with the Clean Water Act (Spill Prevention, Control and Countermeasure provision), New York State 6 NYCRR Parts 612 614 and the Suffolk County Sanitary Code. The work culminated in the preparation of a Spill Prevention, Control and Countermeasure Plan (SPCC) for the facility.
Entenmann’s Bakery – SPCC Plans for Bay Shore and Inez Facilities
As part of this project, the firm was retained to prepare a SPCC Plan for two of its Long Island, New York, facilities. As part of this work, Entenmann’s corporate directive required the SPCC Plans to identify not only petroleum products but other hazardous substances stored at the facility as well. To complete this assignment, the firm conducted a detailed inspection of each facility to identify all storage tanks and areas. Each area was documented in a database program which identified the tank location, identification number, contents, capacity, type of potential failure and spill flow rate and flow direction. The firm then prepared an SPCC Plan for each facility that identified the procedures, methods and equipment to prevent discharges or releases from the facility. Each of the SPCC Plans was prepared in accordance with USEPA guidance documents and was certified by a Registered Professional Engineer.
In addition to the preparation of an SPCC Plan to address petroleum bulk storage tanks, the firm also provided technical support to Entenmann’s with regard to its chemical bulk storage program. This work included conducting annual and five-year inspections of chemical bulk storage tanks at the facility and completing an update of the Spill Prevention Report (SPR). The SPR included an evaluation of spill potential, possible spill consequences and required emergency response, and was prepared in accordance with New York State Regulations. The SPR included observations and concerns identified during the inspection program, as well as recommendations for corrective action.
International Business Machines Corporation
The firm was retained by IBM to prepare an SPCC Plan for its semiconductor manufacturing plant in East Fishkill, New York. As part of this project, the firm evaluated over 50 petroleum storage tanks with respect to spill potential, possible spill consequences and required emergency response. The SPCC Plan was prepared in accordance with the applicable federal and state laws and regulations and addressed the following subject areas:
• Facilities used for storage, loading/unloading and transfer of oil
• Secondary containment facilities
• Storm water drainage facilities
• Past oil spill incidents
• Programs established by IBM for operator training, inspection, testing, monitoring, reporting and security
• Procedures to be followed in the event of an oil spill
• A program for further controlling or reducing the possibility of oil spills
In addition, the firm evaluated the applicability of the Facility Response Plan requirements to the operations conducted at the East Fishkill facility and included the Substantial Harm Criteria Certification Form in the SPCC Plan for the facility.
The firm also provided technical support to the IBM East Fishkill chemical bulk storage program. This program included an evaluation of over 50 tanks storing a variety of chemical products including hydrochloric acid, sulfuric acid, phosphoric acid, methanol, methyl isobutyl ketone and sodium hydroxide. As part of the project, comprehensive tank inspections were conducted that included an evaluation of facilities used for storage, loading/unloading and transfer of bulk chemicals, secondary containment facilities and storm water collection and conveyance. This information was then utilized in the preparation of a Spill Response Plan for the chemical bulk storage tanks at the facility. The SPR was prepared in accordance with NYSDEC guidance documents and was certified by a Registered Professional Engineer.
Safety-Kleen Corporation – Environmental Compliance Review and Permitting
The firm was retained by Safety-Kleen Corp., an organization recognized throughout North America as a leader in waste oil recycling, to provide environmental permitting and overall multi-media compliance services in connection with its 25,000,000 gallon per year waste oil recycling and reprocessing facility located in Buffalo, New York. All environmental engineering activities were completed in support of Consent Order negotiations with the New York State Department of Environmental Conservation (NYSDEC) and in coordination with the requirements of an on-site Environmental Monitor.
Safety-Kleen Corp. also retained the firm to update the facility Spill Prevention, Control and Countermeasure (SPCC) Plan and provide a Registered Professional Engineer’s certification as required by 40 CFR 112. In this capacity, the firm worked closely with Safety-Kleen operating and engineering personnel to identify non-compliant equipment, practices and procedures, and implement corrective actions. The scope of this work included a comprehensive evaluation of facility drainage structures, transfer operations, pumps and in-plant process equipment, tank and rail car unloading racks, and facility security measures.
United States Merchant Marine Academy – Kings Point, New York
The firm was retained by the U.S. Department of Transportation, Maritime Administration to undertake and complete a comprehensive multimedia compliance audit of its facility located in Kings Point, New York. The Academy is located on Long Island Sound and it maintains approximately 115,000 gallons of aboveground and underground petroleum storage tank capacity. These locational and storage capacity considerations, combined with the fact that the facility transfers fuel oil from land to its maritime vessels at the pier located on Long Island Sound, requires the facility to maintain for implementation a Spill Prevention, Control and Countermeasure Plan (SPCC) and Facility Response Plan (FRP). In this instance, the Academy was required to update its SPCC Plan and prepare an FRP in conformance with the requirements of the Oil Pollution Act of 1990.
Toward that end, the firm conducted a detailed engineering inspection at the facility utilizing its storage tank inventory as a “blueprint.” The firm then completed a vulnerability assessment of each storage tank relative to its location to Long Island Sound and the probability of a release resulting from a potential failure. Spill flow rate and flow direction calculations were completed and an SPCC Plan was prepared identifying the procedures, methods and equipment to be used to prevent releases from the facility discharging to the Long Island Sound. The SPCC Plan was prepared in accordance with USEPA guidance documents and was certified by a Registered Professional Engineer.
Rochester Regional Healthcare Association/Joint Ventures Corporation
The firm was retained by individual hospitals within the Rochester Regional Healthcare Association/Joint Ventures Corporation network to prepare Spill Prevention, Control and Countermeasure Plans for hospitals that were determined to require these plans during environmental compliance audits conducted for each hospital. The firm prepared SPCC Plans for the following hospitals:
• Clifton Springs Hospital and Clinic
• Highland Hospital
• Lakeside Memorial Hospital
• Medina Memorial Hospital
As part of this assignment, the firm conducted detailed inspections of each facility to determine locations where oil was stored in capacities exceeding 55 gallons. Information on each individual tank and container was recorded along with facility specific information such frequency of inspections, personnel responsibilities, spill response procedures, spill equipment, etc. This information was evaluated for conformance with the SPCC requirements and upgraded as necessary. For each facility, the firm identified issues that required modification in order to be compliant with the SPCC regulations. In many instances, this involved the preparation of an Oil Spill Contingency Plan and a Capital Improvement Schedule which detailed the dates by which the facility would achieve compliance.
Once the plan was prepared, it was presented to the respective hospital for implementation. The firm assisted each hospital with recommending training topics and procedures to ensure that the plan and all of its respective procedures and policies were properly implemented to ensure compliance with the SPCC regulations.
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