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Spill Prevention, Control, and Countermeasures Plan and Installation Spill Contingency Plan
Section 5 - Inspection, Security, and Preventative Maintenance Programs [40 CFR 112.7(e)]
As a component of CSSA's spill prevention program, preventive maintenance is performed on equipment and facilities associated with the management of oil and hazardous wastes and substances. The program includes regular inspections of equipment and facilities, security, and required maintenance.
5.1 - Inspection Program [40 CFR 112.7(e)(8)]
As required by 40 CFR 112.7(e)(8), the organizations responsible for operation of aboveground storage tanks documents that inspections are performed on the tanks and ancillary equipment. A tank inspection checklist and sample tank inspection form are provided in Appendix C. Completed tank inspection forms, signed by the supervisor or inspector, will be maintained in Appendix C of this plan for a minimum period of 5 years.
5.1.1 Aboveground Storage Tanks
All CSSA fuel storage tanks are double-walled for secondary containment. Data gathered from equipment inspections are reviewed to ensure that the tank system is being operated according to design. The ground area surrounding the tank and the area immediately surrounding the externally accessible portion of the tank system is inspected to detect erosion or signs of releases of fuel oil (e.g., wet spots, stains). According to tank inspection guidelines of the American Petroleum Institute, ASTs are visually inspected weekly at the minimum during normal operation.
5.1.2 Waste Accumulation Areas
Waste accumulation activities are monitored and inspected by the authorized personnel (waste generator) to ensure that the potential spills or release of hazardous constituents are minimized. Personnel inspect and ensure the following items on a regular basis:
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Containers are kept closed except when necessary to add or remove waste, |
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Containers are handled or stored in such a manner as to avoid ruptures or releases, |
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Containers are inspected weekly for leaks and deterioration, and the information recorded on a log form, and |
Incompatible or reactive wastes and materials are not placed in the same container. Containers with incompatible wastes located within the accumulation area are separated by the maximum possible distance.
CSSA has one less-than-90-day hazardous waste storage facility, a container storage area (Building 86). This area stores wastes in a variety of containers, which are typically 55 gallons or less in size.
At a minimum, the container storage area is inspected weekly. Any deterioration or malfunction of equipment or structures noted during an inspection will be remedied. If the problem poses an imminent hazard to human health or the environment, remedial action will be taken immediately. The inspection program shall ensure the following:
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Container is labeled on the outside with words "HAZARDOUS WASTE," and container surface is free of leaks, spills, or any apparent contamination. |
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Containers are stored properly according to their waste compatibility. |
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No more than three 55-gallon waste containers are stored on each pallet, and the pallets are stacked with waste containers no more than two rows high. At no time, is the maximum waste storage capacity of the area (2,560 gallons at Building 86) exceeded. |
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Sufficient aisle space (3 ft., when possible) is maintained for inspections and spill or emergency response activities. |
The container storage area is inspected at least once a week, or more often in the event of potential threat to human health or the environment. At a minimum, the following items will be inspected:
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All monitoring equipment, safety and emergency equipment, and security devices. |
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Physical conditions of drums for any indications of leaks, corrosion, deterioration, bulging, or damage. |
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Proper storage conditions such as aisle space, stack height, and bungs and covers in place. |
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Any actual or imminent spills and leaks. |
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Condition of the secondary containment structure. |
An example inspection form is included in Appendix C. Any spills or leaks found during the inspections must be immediately responded to as described in Figure 4.2 and the ISCP. Any deficiencies and corrective actions taken should be noted in the inspection form.
5.2 - Security [40 CFR 112.7(e)(9)]
5.2.1 Fencing and Access [40 CFR 112.7(e)(9)(i)]
The entire CSSA installation is bounded by a fence. Entry and access to the installation are controlled at all times by security personnel. The installation is frequently patrolled by security personnel. All oil and hazardous substance activities and areas are under the control of authorized personnel. Bulk fuel delivery vehicles are supervised by CSSA escorts at all times.
5.2.2 Locking of Tanks [40 CFR 112.7(e)(9)(ii)]
Flow and drain valves of all storage tanks at CSSA are locked in the closed position while tanks are not being used. Only authorized CSSA personnel have access to oil and hazardous substance storage facilities.
5.2.3 Starter Control on Pumps [40 CFR 112.7(e)(9)(iii)]
Starter controls on fuel pumps are locked in the "off" position when pumps are not in use. Pumps may only be accessed by authorized personnel.
5.2.4 Out-of-Service Oil Pipelines [40 CFR 112.7(e)(9)(iv)]
Loading/unloading connections of oil pipelines are securely capped when not in service or when on standby service for an extended time.
5.2.5 Facility Lighting [40 CFR 112.7(e)(9)(v)]
Lighting at fuel oil storage areas is very limited and is probably not adequate to allow cleanup of spills or leaks after dark. However, because receipt and transfer of fuels occurs during working hours only, there should be sufficient natural light to initiate containment and cleanup actions as needed. Hazardous materials use and storage occurs inside buildings at CSSA. All of these buildings have ample lighting to allow inspection, containment and clean-up to take place at any time of day.
Preventive maintenance, as a part of the spill prevention program, involves the periodic lubrication, adjustment, and replacement of worn parts in all equipment where equipment failure could result in a spill of oils or hazardous substances, or could impede response efforts. This includes implementation of all standard operating procedures and recurring maintenance programs for the specific areas. In addition to preventive maintenance, repairs are made as appropriate where determined necessary through the inspection program discussed in Section 5.