Emergencies 24 Hours

Medical/Fire           -  Dial 911
Harvard Police       -  617.495.1212
Operations Center -  617.495.5560

Services

Online Tools

Spill Prevention Control and Countermeasures (SPCC) Manual

Environmental & Safety Compliance Officer (ECO) Implementation Guidance Manual

Purpose

This implementation Guidance Manual is designed to provide Environmental & Safety Compliance Officers (ECOs) (and their designees) with practical instruction and useful tools for the development and effective implementation of SPCC procedures within their faculties and/or departments. This manual serves to enhance and supplement the University's Spill Prevention Control and Countermeasures (SPCC) Program. Questions regarding specific regulatory and procedural requirements may be directed to your local EH&S representative. Additional assistance may be obtained by contacting the EH&S Department at 495-2060. Copyright (c) 1998.

Introduction

EPA regulations (40 CFR 112) mandate that facilities which store oil and hazardous substances develop and maintain a Spill Prevention, Control and Countermeasures (SPCC) Plan. A facility's SPCC Plan must describe the procedures and equipment in-place to minimize the potential of spills, leaks or releases of oil and/or hazardous material to the environment, as well as describe the reporting and response procedures in the event of a spill, leak or release to the environment. Failure to implement and maintain these SPCC procedures can result in substantial fines and penalties.

Harvard's SPCC Program

Harvard University maintains SPCC Plans for its Cambridge/Allston, Longwood, Southborough and Harvard Forest campuses. Harvard's SPCC Plans establish University-wide procedures for the prevention, detection, and reporting/response (mitigation) of spills and/or releases of oil and hazardous materials.

Consistent with the University's EH&S management structure, designated ECOs are responsible for the development, implementation and maintenance of these SPCC procedures within their faculty and/or department. EH&S provides ECOs and the University community with technical/management consultation and specific operational support. Harvard's SPCC Plans designate ECOs as SPCC management Coordinators and EH&S as SPCC Technical Coordinators. The following outlines the specific responsibilities of each:

SPCC Management Coordinators (ECOs) are responsible for:

Ensuring the allocation of necessary resources (e.g. manpower and equipment) to complete site-specific SPCC implementation issues.

Implementing identified corrective actions.

Consulting with SPCC Technical Coordinator on spill mitigation/reporting requirements and compliance implications.

Communicating issues of concern regarding SPCC implementation to site personnel.

Maintaining a local responsibility matrix for SPCC compliance.

Site -specific implementation of the SPCC Plan by:

Ensuring personnel requiring training are identified, notified and are properly trained.

Maintaining appropriate training records.

Ensuring implementation of operational issues (e.g. integrity testing/tank management, maintenance of oil device inspections/records for 3 years, ensuring that appropriate spill equipment is maintained/available, etc.).

Maintaining up-to-date information on site-specific oil storage/use and providing updated information to SPCC Technical Coordinator or designee.

SPCC Technical Coordinators (EH&S) are responsible for:

This Manual is designed to provide ECO's with sufficient technical information and management tools so it can act as a "starter-kit" for the development, implementation and maintenance of local SPCC procedures.

Starter Kit: 3-Step Plan

Listed below are three recommended steps for ECOs to follow to begin the process of implementing the SPCC program at their school, department or operating facility. These steps are offered as a general guideline and may be modified by ECOs to meet specific circumstances.

Step 1: Review Harvard's SPCC Plan

Review the content of Harvard's SPCC Plan to gain an understanding of the University's overall spill/release prevention and response procedures and your responsibilities. Ensure that key personnel within the faculty and/or department are also familiar with the relevant sections of the Plan, in the event that they may become involved in SPCC response/reporting activities. Key information for this purpose is contained in the following sections:

Section I

Section II

Section III

Step 2: Develop a Local SPCC Implementation Plan

Based on your review of the SPCC Plan, develop a local SPCC Implementation Plan to ensure that individual roles and responsibilities are identified, adequate resources dedicated, schedule deadlines established, etc. Depending on the size and scope of local implementation, it may be advisable to assemble a local SPCC implementation team to align internal resources with specific needs. The SPCC Program Implementation Plan - Responsibilities Matrix (Appendix 1) identifies the specific action items required to develop a local SPCC program and ensures that personnel are designated as responsible for the completion and on-going maintenance of the program.

Step 3: Conduct Regular Self Assessment/"Check-Ups"

Perform regular "check-ups" to ensure the implementation of the SPCC program and evaluate the performance of local SPCC procedures. These "check-ups" identify weaknesses with the SPCC procedures to allow timely corrective actions. The SPCC Program Self Assessment (Appendix 7) should be used on a regular basis (recommended semi-annually) by ECOs to ensure that areas of potential or actual non-compliance are identified and promptly corrected.

APPENDIX 1

SPCC Program Implementation Plan Responsibilities Matrix

Environmental & Safety Compliance Officer (ECO):

Name: ___________________________________________

School/Department: _______________________________

SPCC Action Item(s):

Responsible Person(s):

SPCC Inspections

SPCC Spill Kits

Purchase/install SPCC Spill Kits (refer to Appendix 3):

Maintain/Inspect SPCC Spill Kits

SPCC Corrective Actions

Implement identified corrective actions (furnished by E&U Dept.)

Several examples of potential corrective actions include:

Oil Storage/Use Inventory

Verify/complete current oil storage/use inventory.

Update oil storage/use inventory as oil storage/use removed, added or modified (refer to Oil Storage/Use Tables in SPCC Plan).

SPCC Training

Identify personnel requiring annual SPCC training (Note: Initial SPCC training should be classroom; annual refresher via EH&S Web-based SPCC training program.)

SPCC Records Management

Maintain SPCC records (3-year retention required)

Contractor Management

Provide "Notice to Fuel Delivery Vendor" (refer to Appendix 5) to fuel delivery/equipment maintenance vendors.

Provide Spill/Release Response/Reporting Quick Reference Summary (Appendix 6) to all contractors.

Tank Management

SPCC Drill

APPENDIX 2

SPCC Inspection Form

Building/Room: _____________________

Inspector: ______________________

Oil Storage Tanks

Aboveground Storage Tank Status (Mark No Repair Required or Some Repair Required)

Seams

Piping

Containment/Foundation

Spill/Leak Detection Systems

If Repair Required checked, specify tank(s):

Underground Storage Tank Status (Mark No Repair Required or Some Repair Required)

Piping

Containment/Foundation

Spill/Leak Detection Systems

If Repair Required checked, specify tank(s):

Oil-Containing Storage Areas

Room Number _______

Virgin/Waste Material Stored _______________________

Storage Area Condition (Mark No Repair Required or Some Repair Required)

If Repair Required checked, specify Room Number and Material Stored:

Oil-Containing Equipment

Description of Equipment: _________________________

Location: ______________________________

Storage Area Condition (Mark No Repair Required or Some Repair Required)

If Repair Required, specify Equipment and Location:

Notification/Corrective Actions Taken:

Inspector Signature: __________________________

Date: _________________

Note: Report any conditions requiring corrective action to the Area or Building Supervisor. Maintain copies of this inspection form for three full calendar years.

APPENDIX 3

SPCC Spill Response Equipment Guidelines

It is recommended that all buildings/facilities which maintain oil storage/use devices should maintain the following as a minimum level of spill response equipment:

Spill Equipment Requirements

  1. Equipment should be maintained in a "kit" in an area readily accessible by trained personnel.
  2. Equipment should be regularly inspected to ensure operability and fully stocked.
  3. Only SPCC-trained personnel can utilize spill response equipment.

Spill Equipment Suppliers

Below are several suppliers who can offer spill response equipment:

APPENDIX 4

SPCC Records File

SPCC regulations require the maintenance of various records including:

  1. Copy of up-to-date SPCC Plan and SPCC Responsibilities Matrix.
  2. SPCC training attendance records (web & classroom).
  3. SPCC Inspections Forms (signed & dated).
  4. Tank and other oil-containing equipment as-built drawings.
  5. Tank testing records:
    • Interstitial monitoring
    • Integrity (pressure) testing
    • Cathodic protection
  6. Tank & Oil-containing equipment Inventory (up-to-date).
  7. Contractor Notifications/Qualifications.
  8. Spill/release History (Log Book).
  9. All SPCC correspondence.

APPENDIX 5

Notice to Fuel Delivery Vendor

Acknowledgment of Responsibility

To prevent the release of hazardous substances to the environment and in accordance with Harvard University's Spill Prevention Control and Countermeasures Plan, all tank truck drivers loading or unloading materials at the University shall adhere to the following guidelines:

  1. Remain with the vehicle at all times, and observe the fuel transfer process;
  2. Drain the loading/unloading lines to the storage tank and close the drain valves before disconnecting loading/unloading lines;
  3. Ensure a drain pan or other appropriate containment device is located under all connections;
  4. Inspect the vehicle before departure to ensure all loading/unloading lines have been disconnected and all drain and vent values are closed; and
  5. Immediately report any leakage or spillage, including quantity, to the University Operations Center at 495-5560.
  6. Ensure that the fuel truck driver has been trained and qualified to cleanup and report oil spills to appropriate external agencies and the Harvard University Operations Center.
  7. The fuel delivery vendor is requested to maintain equipment necessary for the cleanup of incidental spills, drips or leaks on the fuel delivery truck at all times. Suggested equipment includes absorbent, industrial wipers, and cleanup containers.
  8. Fuel vendor is to attach a list of facilities serviced at Harvard University, and names of primary University contact.

Instructions:

It is recommended that personnel involved in the purchase or management of fuel oil at Harvard University provide a copy of this form to their vendors on an annual basis. The vendor is to provide a signed acknowledgment to the Harvard University representative. It is suggested that the Harvard representative maintain a signed acknowledgment in his/her vendor file until renewed.

Provided By: _________________________

Date: ______________

Harvard University Representative: ______________________

Received and Acknowledged By: _________________________

Vendor's Company Name: _________________________

Authorized Representative: _________________________

APPENDIX 6

Spill/Release Response/Reporting

Quick Reference Summary

In the event of a spill or release of oil or other hazardous material:

  1. Extinguish all sources of ignition and isolate incompatibles or reactive chemical substances.
  2. Determine if the spill/release is incidental 1 or non-incidental 2.
  3. For incidental 1 spills/releases - attempt to stop or contain the spill/release at the source without endangering yourself and others.
  4. For non-incidental 2 spills/releases - immediately report the spill/release to the University Operations Center at 495-5560. The Operations Center will notify the SPCC Coordinators and initiate contact with spill response vendors.
  5. Isolate all potential environmental receptors including drains, sumps, soil, etc.
  6. Report to outside agencies - the SPCC Technical Coordinator (from EH&S) or designee will conduct necessary reporting to outside agencies.
    • If a spill/release of oil exceeds 10-gallons and has entered the environment - it must be reported to the state Department of Environmental Protection.
    • If spill/release migrates off Harvard properties and/or results in personal injury - also report to the local emergency agencies.
    • If spill/release enters a stormwater drain system or sewer system - also report to the local sewer authority.
    • If spill/release causes a sheen or discoloration of navigable waters or adjoining shorelines -also report to the National Response Center (NRC).

7. Recover material spilled and clean-up spill area.

8. Decontaminate tools and equipment. Collect all rinsate and debris.

9. Under the guidance of the SPCC Technical Coordinator, dispose of waste materials in accordance with applicable regulations and University procedures.

10. The SPCC Technical Coordinator will conduct all required follow-up written notifications to applicable agencies.

11. The SPCC Management Coordinator will conduct an incident analysis and develop plans necessary to prevent recurrence.

 

Contact Webmaster | Privacy Policy | The President and Fellows of Harvard College

Valid CSS Valid HTML Section 508