Oil Spill Prevention, Control and Countermeasure (Environmental)

Purpose

This document provides the procedures to be used in conjunction with the St. Mary’s Spill Prevention, Control and Countermeasure Plan (SPCC) to prevent migration of oil into waterways (navigable waters of the United States) in case of oil spills.

Background

Spill Prevention Control and Countermeasure (SPCC) plans for facilities are required by U.S. EPA regulations contained in Title 40, Code of Federal Regulations, Clean Water Act (40 CFR 112), Texas Water Code (Section 26.351), and the Oil Pollution Act of 1990. A non-transportation related facilities is subject to SPCC regulations if: the total aboveground storage capacity exceeds 1320 gallons; or the underground storage capacity exceeds 42,000 gallons; and if due to its location, the facility could reasonably expect to discharge oil into or upon the navigable waters of the United States.

Applicability

This document applies to all personnel responsible for preventing, controlling, and or cleaning up oils spills on the St. Mary’s University campus.

Reference Documents

• Mary’s University Spill Prevention, Control, and Countermeasure (SPCC) Plan
• Spill Clean-up Suggestions Poster: Appendix-A

Sources of Oil (Routine Maintenance and Leaks)

• Elevator Equipment Rooms: hydraulic oil
• Trash Compactors: hydraulic oil
• Emergency Generators: Blume, Founders Hall, AA&CC, and Charles Francis
• Facilities Compound: Golf Carts, Gators, Trucks, Vans, and Lawn Equipment
• Central & Satellite Plants: HVAC equipment (Cooling towers, Chillers)
• Kitchen Grease: University Center (Grease Tank)

Note: Refer to the SPCC Plan (EHS Website) for a list of all oil containing equipment (>55 gals) on campus as well as additional spill containment procedures.

Defining Small Spills and Large Spills

Based upon the information provided by the San Antonio Fire Department Hazmat and the University Police Department:

• Large spill is considered six (6) gallons or more and a small spill is considered less than six (6) gallons.
• Consideration must be given to the type of oil that has been spilled (i.e. a hazardous material of a smaller quantity may require HazMat assistance).

Note: Whether a small or a large spill, refer to the SPCC Plan to supplement the procedures for spill control outlined in this procedure.

Response Procedure

Small Spills (Less Than 6 Gallons)

• Find and resolve source of leak.
• Use PPE and isolate area: identify slip hazards, place warning cones & barricades.
• Contain the spill by using booms and spill berms.
• Prevent oil from entering storm or sewer drains (seal floor drains, drain inlets and curb inlets).
• Use spill kits, sorbent pads, and granular oil sorbents to clean up spill.
• Use granular oil sorbents to clean up oil spill. Sand may be used but sand is not as effective as granular sorbents.
• Collect contaminated granular oil sorbent or sand into containers label as “contaminated with used oil”. Containers will be disposed using an environmental disposal vendor.

Large Spills (More Than 6 Gallons) Notify University Police Department Immediately and proceed as follows

• Execute all the above (steps 1 – 7).
• Comply with any additional UPD or HazMat (SAFD) instructions.
• Contact approved environmental disposal vendor to dispose of contaminated materials.
• Comply with all federal, state, and local reporting requirements based on the spill quantity and environmental impact.

Special Considerations for Indoor Spills and Outdoor Spills

• Indoor spills are more easily controlled although damage to flooring (carpet) and walls (drywall and baseboards) may require demolition. Use cones and warning tape to prevent the oil from being tracked through the building. Oil soaked building material should be collected, wrapped in plastic to avoid leakage, and disposed of using an environmental disposal firm.
• Outdoors, spills on pavement can be cleaned using sorbents, pads, and booms. When spills occur on the dirt, the dirt must be collected and disposed as contaminated material using an environmental disposal firm.

Location of Spill Kits on Campus

Campus Spill Kits can be used for either oil or chemical spills. Two types of spill kits are currently located on campus:

• Yellow bag (smaller spills)
• White Bucket (larger spills)

Facilities compound

Central Plant, Satellite Plant, Maintenance Shop, Grounds Equipment cage, Automotive Shop, Housekeeping, and HW Primary Storage Bldg. – 3 spare spill kits and spill control material (pads, bags, gloves, etc.)

Campus

Outdoor and Indoor Swimming Pools, University Center (Mechanical Room), Center for Legal and Social Justice (Mechanical Room), Counselor Education and Family Life Center (Mechanical Room).

Science, Engineering, and Technology:

Richter Math-Engineering Building (Production and Robotics Labs), and Moody Life Sciences Building (Biology Rooms 208 and 322), Garni Hall (Chemistry and Physics Labs).

Normal Operations Collection, Storage and Disposal of Used Oil and Oily Material

• Used oil (not contaminated with PCBs or halogens) is collected in the Facilities Compound in the Grounds/Automotive area in 33-gal barrels marked “Used Oil”.
• Used oil filters are disposed in a container marked “Used Oil Filters”.
• Oil contaminated absorbent should be placed in a labeled and located in the HW Primary Storage Accumulation Bldg.
• Oily rags should be disposed of in the red containers marked “Oily Rags” located in Automotive and Central Plants.

Regulated disposal by approved “Waste Oil Service” (non-PCB)

• Motor oils (from vehicles and machinery),
• hydraulic oils from trash compactors and elevators
• cooking oils and greases from the cafeteria
• dielectric and mineral oils from electrical transformers

Regulated disposal by “HW Disposal Service”

• Refrigerant Oil containing Halogens
• Transformer Oil containing PCB’s

Spill Prevention

• Use safe barrel handling procedures (see Facilities Staff Handbook, #57):

Unloading barrels: Care should be taken when loading and unloading barrels with chemicals. Chemical barrels delivered by freight companies should be unloaded by the freight company, requiring them to use their lift to set the barrels on the ground and transporting the barrel with a hand dolly. The practice of unloading barrels with forklift blades is strictly forbidden.

• Use drum funnels during oil transfer.
• Secondary containment:
• Purchase equipment and tanks that are double-walled.
• Use spill pallets for all Bulk Stg (110% containment of largest container).

Responsibilities

All personnel responsible for preventing, controlling, and/or cleaning up oils spills on the St. Mary’s University campus are required to be trained and to follow this Standard Operating Procedure. Training will be conducted annually by the Facilities Administrator or qualified delegate. All spills will be documented and maintained by the EHS Manager in the Facilities Services Office.

Training

Annual training for SPCC will be held at the Facilities Departmental Quarterly Safety Training Meeting. The training will consist of review of the St. Mary’s University SPCC Plan and Oil Spill Prevention, Control and Countermeasure SOP; viewing of the Coastal Safety and Environmental video entitled Spill Prevention and Control: Insuring a Safer World; and answering the questions in the booklet by the same name.

Record Keeping

Records of any oil/fuel spills will be maintained and filed in the Facilities Department Front Office, per St. Mary’s University Record Retention Policy.

Available in the Administration and Finance Office:
Appendix A: Oil Spill Clean Up Suggestions Poster