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GSU SPCC Plan

This document is a spill prevention, control, and countermeasure plan for Georgia State University. It provides an inventory of oil storage on campus, details on bulk storage requirements and controls, drainage system controls, potential spill scenarios and volumes, training procedures, loading and unloading operations, inspection requirements, security measures, and spill response procedures.

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Mokrani Jaber
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0% found this document useful (0 votes)
25 views80 pages

GSU SPCC Plan

This document is a spill prevention, control, and countermeasure plan for Georgia State University. It provides an inventory of oil storage on campus, details on bulk storage requirements and controls, drainage system controls, potential spill scenarios and volumes, training procedures, loading and unloading operations, inspection requirements, security measures, and spill response procedures.

Uploaded by

Mokrani Jaber
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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SPILL PREVENTION, CONTROL, AND

COUNTERMEASURE PLAN

Prepared for:
TM

Reviewed and Updated by:

Smith Aldridge, Inc.


6000 Lake Forrest Drive
Atlanta, GA 30024
(404) 255-0928

January 2014

SPCC Plan
Georgia State University Page i
TABLE OF CONTENTS
1. INTRODUCTION ............................................................................................................ 1
1.1 Applicability .................................................................................................................... 1
1.2 Cross-Reference with Regulations....................................................................................... 2
1.3 Location of SPCC Plan...................................................................................................... 2
1.4 Management Approval/PE Certification............................................................................... 2
1.5 Substantial Harm Criteria Certification ................................................................................ 2
1.6 Amendments and Revisions ............................................................................................... 3
2. FACILITY IDENTIFICATION.......................................................................................... 4
2.1 Facility Owner and Operator .............................................................................................. 4
2.2 Facility Contacts ............................................................................................................... 4
2.3 Coordinates and Identification Numbers .............................................................................. 4
3. GENERAL CAMPUS LAYOUT AND SITE PLAN DRAINAGE SYSTEMS......................... 5
3.1 Campus Summary Description ........................................................................................... 5
3.2 Site Drainage Systems ....................................................................................................... 6
3.3 Discharge Pathways .......................................................................................................... 6
4. OIL STORAGE INVENTORY .......................................................................................... 7
4.1 Stationary Aboveground Storage Tanks (AST’s)................................................................... 7
4.2 Underground Storage Tanks (UST’s)................................................................................... 8
4.3 Oil-Filled Electrical, Operating and Manufacturing Equipment............................................... 9
4.4 Oil Storage in Containers with a Capacity of 55 Gallons or Greater (Other Than AST’s, UST’s
and Mobile Bulk Storage Containers) .................................................................................10
4.5 Dedicated (Onsite) Mobile Bulk Oil Storage Containers .......................................................11
4.6 Tank Truck Loading/Unloading Areas................................................................................11
4.7 Additional Oil Storage Areas or Oil Handling Activities .......................................................11
5. Bulk Oil Storage ..............................................................................................................12
5.1 Construction and Secondary Containment for Bulk Oil Storage Tanks....................................12
5.2 Construction and Secondary Containment for Other Oil Storage Areas...................................12
5.3 Oil Storage in Containers with a Capacity of 55 Gallons or Greater (Other Than AST’s, UST’s
and Mobile Bulk Storage Containers) .................................................................................13
5.4 Oil-Filled Electrical, Operating and Manufacturing Equipment..............................................14
5.5 Drainage of Containment Areas .........................................................................................15
5.6 Corrosion Protection ........................................................................................................15
5.7 Partially Buried and Bunkered Storage Tanks......................................................................15
5.8 Inspections and Tests........................................................................................................15
5.9 Heating Coils ..................................................................................................................15
5.10 Overfill Prevention Systems ..............................................................................................15

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Georgia State University
5.11 Visible Discharges ...........................................................................................................15
5.12 Release Reporting ............................................................................................................16
5.13 Preventing the Mixing of Incompatible Substances ..............................................................16
5.14 Spill Prevention at Pumps and Valves.................................................................................16
5.15 Secondary Containment for Transfer Stations......................................................................16
6. Drainage Controls ............................................................................................................17
6.1 Diked Storage Areas.........................................................................................................17
6.2 Undiked Storage Areas .....................................................................................................17
6.3 Undiked Transfer Areas....................................................................................................17
6.4 Drainage Inspections ........................................................................................................18
7. POTENTIAL SPILL PREDICTION, VOLUMES, RATES AND CONTROLS.......................19
7.1 Spill Scenarios.................................................................................................................19
7.2 Potential Chemical Reaction..............................................................................................21
7.3 Spill History....................................................................................................................22
8. TRAINING OF SPILL PREVENTION PROCEDURES ......................................................23
8.1 Personnel Training ...........................................................................................................23
8.2 Visitor Training ...............................................................................................................23
9. Facility Transfer Operations ..............................................................................................24
9.1 Facility Transfer of Oils....................................................................................................24
10. Loading and Unloading Operations ....................................................................................25
10.1 Loading/Unloading of Oils................................................................................................25
11. Inspections, Tests and Records ..........................................................................................28
11.1 Monthly Visual Inspections...............................................................................................28
11.2 Annual Inspections...........................................................................................................28
11.3 Bulk Oil Storage Integrity Testing......................................................................................28
11.4 Brittle Fracture Evaluation ................................................................................................29
11.5 Record Keeping ...............................................................................................................29
11.6 Good Housekeeping .........................................................................................................30
12. Security ..........................................................................................................................31
12.1 Fencing...........................................................................................................................31
12.2 Flow Valves and Starter Controls Locked ...........................................................................31
12.3 Loading/Unloading Connections Securely Capped ...............................................................31
12.4 Lighting Adequate to Detect Spills.....................................................................................31
13. Spill Response Procedures ................................................................................................32
13.1 Response to a Minor Discharge .........................................................................................32
13.2 Response to a Major Discharge..........................................................................................33
13.3 Spill Response Materials...................................................................................................34

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13.4 Waste Disposal................................................................................................................34
13.5 Spill Notification, Reporting and Response Requirements.....................................................34
14. Spcc plan amendments by the regional Administrator...........................................................37

LIST OF FIGURES
Figure 1: GSU Main Campus Site Plan
Figure 2: Diesel Storage Map
Figure 3: Waste Grease Storage Map
Figure 4: Elevator Lift Hydraulic Fluid Storage Map

LIST OF TABLES
Table 1 - Stationary Aboveground Storage Tanks ............................................................................. 7
Table 2 – Oil Filled Equipment ...................................................................................................... 9
Table 3 – Oil Containers...............................................................................................................11
Table 4 - Drum Containment.........................................................................................................14
Table 5 - Spill Prediction Volumes ................................................................................................20
Table 6 - Inspection Schedule .......................................................................................................29

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Georgia State University
LIST OF APPENDICES
Appendix A: Signatures and Certifications
Appendix B: SPCC Cross Reference
Appendix C Sanitation Chemical and Oil Material Safety Data Sheets
Appendix D Annual SPCC Training Outline and Log Sheet
Appendix E: Transfer Procedures and Forms
Appendix F: Inspection Forms
Appendix G: Emergency Procedures and Forms

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1. INTRODUCTION
This document presents the Spill, Prevention, Control and Countermeasure (SPCC) Plan for the Georgia
State University (GSU) located in Atlanta, GA. Figure 1 provides a site location map for the campus.
This SPCC Plan has been prepared and implemented in accordance with the requirements of Title 40 of
the Code of Federal Regulations Part 112 (40 CFR Part 112).
The purpose of this SPCC Plan is to form a comprehensive spill prevention program that:
 Identifies and assesses areas where oil and hazardous materials are handled, stored or
managed.
 Prevents spills, leaks or other releases of oil or hazardous materials that could result in the
discharge to navigable waters.
 Ensures appropriate control and countermeasure equipment or procedures are in place to
adequately contain and control an inadvertent release of oil.
 In addition to the requirements of 40 CFR Part 112, all hazardous chemicals stored in excess
of 55-gallons are accounted for in this plan.

1.1 Applicability

1.1.1 SPCC Plan


In accordance with the requirements of Title 40 of the Code of Federal Regulations (CFR) Part 112, the
United States Environmental Protection Agency (U.S. EPA) requires SPCC Plans to be prepared by the
owner or operator of a facility engaged in the storage, transfer, distribution, or consumption of oil and oil
products in quantities above regulated thresholds and those facilities that could reasonably be expected to
discharge oil to navigable waters. Oil is defined as “oil of any kind or in any form, including but not
limited to fats, oils, or greases of animal, fish, or marine mammal origin; vegetable oils, including oils
from seeds, nuts, fruits, or kernels; and, other oils and greases, including petroleum, fuel oil, sludge,
synthetic oils, mineral oils, oil refuse, or oil mixed with wastes other than dredged spoil” (40 CFR 112.2),
as amended July 17, 2002.
Under 40 CFR Part 112, facilities are required to prepare, maintain, and implement an SPCC Plan if oil
could potentially be spilled into navigable waterways, and if any of the following storage thresholds are
exceeded:
1. 42,000 gallons or more of oil is stored in underground tanks; or
2. 1,320 gallons or more of oil is stored aboveground.

Since GSU stores greater than 1,320 gallons of oil aboveground, and there is a potential for oil to be
discharged to surface waters, GSU is subject to 40 CFR Part 112.
This SPCC plan has been prepared in accordance with the most recent SPCC requirements of 40 CFR
Part 112. The final rule included compliance dates in §112.3 for preparing, amending, and implementing
SPCC Plans. The original compliance dates were amended on January 9, 2003, again on April 17, 2003,
a third time on August 11, 2004, a fourth time on February 17, 2006, and a fifth time on May 16, 2007.

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On June 19, 2009, EPA published in the Federal Register a SPCC compliance date extension for all
facilities until November 10, 2010. Facilities must amend or prepare, and implement SPCC Plans by the
compliance date in accordance with revisions to the SPCC rule promulgated since 2002. It is noted that
the most recent in a series of amendments occurred on November 5, 2009, when the EPA Administrator
signed a notice amending certain requirements of the SPCC rule.
This SPCC Plan (Plan) provides the procedures that will be followed by GSU personnel to prevent and
contain the release of oil and chemicals.

1.1.2 Other Regulations Addressed By This Plan


As necessary, the Plans refers to or fulfills other applicable regulations including:
 40 CFR Part 110, Discharge of Oil;
 40 CFR Part 302, EPA designation, reportable quantities, and notificatioon requirements for
hazardous substances under the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA);
 Fulton County, GA Slug Plan; and
 Georgia Environmental Protection Division spill event reporting.

1.2 Cross-Reference with Regulations


This Plan has been developed in accordance with 40 CFR Part 112, including Section 112.7. However,
this Plan does not follow the exact order presented in 40 CFR Part 112. Appendix B provides a cross
reference for the requirements of 40 CFR Part 112 with the respective sections of the SPCC Plan where
the requirement has been addressed. For each requirement of 40 CFR Part 112 that is listed in Appendix
B, the referenced Plan section provides a discussion of the campus’s conformance with the listed
requirement.

1.3 Location of SPCC Plan


In accordance with 40 CFR 112.3(e), a complete copy of this SPCC Plan is maintained in the office of the
Environmental Program Officer. This SPCC Plan will be made available to the Regional Administrator
for review during normal working hours.

1.4 Management Approval/PE Certification


A facility that stores less than 10,000 gallons in aggregate aboveground oil storage capacity and meets oil
discharge history criteria may self-certify their SPCC Plan. Since GSU stores less than 10,000 gallons of
oil, this option is available. Therefore this plan has not been reviewed by a Professional Engineer (PE).
A Management Approval and Certification signature sheet has been included in Appendix A.

1.5 Substantial Harm Criteria Certification


In 1990, Congress passed the Oil Pollution Act (sometimes called OPA-90). This Act amended Section
311 of the Clean Water Act and required an owner or operator to prepare and implement a Facility
Response Plan (FRP) for any facility that could cause substantial harm to a navigable water body or its

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adjoining shoreline. This act was amended in 2000 and 2002. The final EPA rules for OPA-90 [40 CFR
112.20 and 112.21) published in the Federal Register on July 17, 2002 and June 30, 2000, requires
owners or operators to submit to EPA for review and approval a FRP for responding to a worst-case
discharge.
The GSU campus does not meet the substantial harm criteria established by EPA and thus does not have
to prepare and maintain a FRP. Certification by the unversity that the university could not, because of its
location, reasonably be expected to cause substantial harm to the environment by discharging oil into or
on the navigable waters of the United States or its adjoining shorelines is provided in Appendix A, in
accordance with the provisions of 40 CFR Part 112.20(e).

1.6 Amendments and Revisions


This SPCC Plan will be appropriately amended by the university when there is a change in the campus
design, construction, operation or management that materially affects its potential for a discharge of oil in
harmful quantities. Examples of changes that may require amendment of the SPCC Plan include, but are
not limited to: installation or removal of containers; replacement, reconstruction, or movement of
containers or piping; change in drainage and/or secondary containment; changes of product or service; or
changes to procedures and/or maintenance at the campus. Amendments to the Plan made to address these
kinds of changes are referred to as technical amendments, and must be certified by a professional
engineer. However, non-technical amendments (changes in telephone numbers or spill prevention
personnel) can be made by the facility owner and/or operator. Updated pages should be inserted in the
proper place and the obsolete pages discarded. Record of these amendments shall be maintained in this
section.
Notwithstanding any amendments to the SPCC plan that are required as a result of changes at the campus,
a complete review and evaluation of the SPCC portions of this plan will be completed at least once every
five years. As a result of this review, the SPCC plan should be amended to include more effective
prevention and control technology if the technology has been field-proven at the time of the review and
will significantly reduce the likelihood of a discharge from the campus.
Any required amendments to the SPCC Plan will be completed within six months and will be
implemented as soon as possible, but not later than six months following preparation of the amendment.
Each required (i.e. technical) SPCC Plan amendment will be reviewed and certified by a Licensed
Professional Engineer (if applicable) and approved by campus management.
Scheduled reviews and Plan amendments are recorded in the SPCC Plan Review Log (Table 1).
Signature sheets for SPCC Plan Review and Evaluation are found in Appendix A. The signature sheets
should be filled out and appended to Appendix A of the SPCC Plan any time a review is performed.
Unless a technical or administrative change prompts an earlier review of the Plan, the next scheduled
review of this Plan must occur by January 2019.

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2. FACILITY IDENTIFICATION
2.1 Facility Owner and Operator
The GSU campus is located at and around:
Georgia State University
30 Courtland Street
Atlanta, Georgia 30302
(404) 651-4866

See Figure 1 for map.

2.2 Facility Contacts


The following primary campus contact is the designated person (Emergency Coordinator) accountable for
oil and hazardous material spill prevention:
Name: Michael Thompson, Senior Environmental Program Officer
Office: 404-413-3551 (Office)
24-hour: 404-886-4289

The following backup campus contact is the designated person accountable for oil and hazardous material
spill prevention in the absence of the Emergency Coordinator:
Name: Paul Hysell
Office: 404-413-3515

2.3 Coordinates and Identification Numbers


Following are the coordinates for the GSU campus in Fulton County.
 Latitude 33.753632°N, 84.385038°W, (33° 45' 13"N, 84° 23' 6"W)
Identification numbers and codes used on various permits are as follows:
 Standard Industrial Codes (SIC): 8221
 National Industry Classification System Codes (NAICS): 611310
 AIRS No.: 121-0792
 EPA Facility ID: GAD073425951
 Hydrologic Unit (HUC) Code: 03070103

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3. GENERAL CAMPUS LAYOUT AND SITE PLAN DRAINAGE


SYSTEMS
3.1 Campus Summary Description
The University is one of the leading research institutions in the University System of Georgia. More than
30,000 students attend the University annually, and are enrolled in more than 50 degree programs in more
than 200 fields of study. The University consists of over thirty (30) buildings located in a high density,
urban environment in downtown Atlanta.
The University’s main campus is topographically centered on a local high elevation at the approximate
intersection of Courtland and Gilmer Streets. A local drainage divide runs on an approximate line
coincident with Gilmer and descending to the north of the line. South of Gilmer, Courtland is an elevated
viaduct above the original ground elevation Collins Street. Drainage south of the Gilmer Street divide is
highly modified due to construction activity over the past 150 years. However storm water and run-off
generally runs to City of Atlanta storm drains.
The underlying geology is highly metamorphosed rock (migmatitic gneisses, schists, quartzites, etc.) of
variable type known collectively as Clairmont Melange. This is part of a larger geologic thrust stack
consisting of both autochthonous and allocthonous components associated with the opening and closing
of both the Iapetus Ocean and the proto-Atlantic. Ground water is fracture-controlled.
Buildings on the main downtown Atlanta campus are equipped with emergency back-up electrical
generators of various types and sizes. With the exception of the natural gas-fueled back-up generators
located at the main campus radio station (WRAS) and Library North building, all generators are diesel-
fueled. Diesel fuel storage tanks are primarily above-ground tanks local to their respective generators.
Generators utilizing fuel stored in underground storage tanks (USTs) are:

Generator No. Brand Serial Number Generator Location

NSC, 1st Floor


EG3 Cat 350B 23Z03666
Mechanical Room
Classroom South,
EG10 Cat 3406 5GA03577
Basement *
Classroom South,
EG21 Cat 3412 3FZ04545
Outside *
EG24 MTU T1638A36 5272003403 Petit Science Center
* EG10 & EG21 share a common UST of 250 gallons capacity.

Complete lists of all generators and their respective above ground and underground diesel fuel storage
tanks are located in Section 7.0 of this Plan. Please refer to Tables 7.4 and 7.5.

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A waste grease dumpster and ten (10) grease traps are also located on the University property. These
serve food preparation/serving and general use areas. Current grease trap and dumpster capacity, service
frequency and service vendor(s) are listed below. A complete list of grease traps is located in Section 7.0
of this Plan. Please refer to Table 7.6.
The main campus also has a number of hydraulic elevators, lifts, dumb waiters and similar devices
utilizing hydraulic fluids. A complete list of this equipment with oil reservoirs holding greater than 55
gallons of hydraulic fluid appears in Section 7.0. Please refer to Table 7.7.

3.2 Site Drainage Systems


Storm water discharges from the property at several points and includes building runoff, parking lot
runoff, and uncontaminated air conditioner condensate. All of these discharges go to the City of Atlanta
municipal wastewater collection and treatment system.
GSU does not have or discharge any water that would be considered process water.

3.3 Discharge Pathways


In the unlikely event of an oil spill from the tanks that spread beyond the immediate location, the oil
would enter adjacent drains that are connected to the City of Atlanta municipal wastewater collection and
treatment system where the oil will be removed prior to discharge to a stream. Stormwater in the location
of the main campus also drains to the City of Atlanta municipal wastewater collection and treatment
system. The Chattahoochee River is ultimately the receiving water for the City of Atlanta municipal
wastewater discharge.

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4. OIL STORAGE INVENTORY


The oil stored on the GSU campus is primarily of three different types. They are: fuel oil, hydraulic oil,
and oil associated with cooking. The fuel oil stored on campus is used to power emergency power
generators. The hydraulic oil is used in the operation of hydraulic elevators and lifts, and the cooking oil
is used in the food preparation areas primarily for frying. Other maintenance and lubricating oils are used
on the campus but they are not stored in containers that are 55 gallons or larger and are, therefore, not
addressed in this plan.
In addition, GSU utilizes several pieces of oil-filled equipment, primarily hydraulic elevators, which are
located throughout the campus. Each of the oil storage locations are summarized in Table 1-5 and shown
on Figure 2. The following sections summarize the campus’s oil storage inventory and associated
handling operations.

4.1 Stationary Aboveground Storage Tanks (AST’s)


Storage of oil on campus consists of the storage of diesel fuel to power the emergency power generators
and the storage of grease from campus cooking activities. Each of the aboveground tank locations is
noted on Figure 2. A summary of these tanks is provided below:

Table 1 - Stationary Aboveground Storage Tanks

MAP TANK/ TANK CAPACITY YEAR


CONTENTS LOCATION
ID STORAGE ID MATERIAL (gallons) INSTALLED

Fuel Tanks
G Deck, Mechanical
EG1 Diesel Fuel Room. Opposite Steel 110
Motorcycle Bay1
30 Pryor, Basement
EG2 Diesel Fuel Steel 110
Parking Deck
Natural Sciences
EG3 Diesel Fuel Steel 100
Center, Day Tank1
35 Broad Street. Top
EG4 Diesel Fuel Steel 250
floor mechanical room
35 Broad Street. Top
EG4 Diesel Fuel floor mechanical room Steel 440
(8 55-gal drums)
Urban Life, Parking
EG5 Diesel Fuel Steel 100
Lot B1
Standard Building,
EG6 Diesel Fuel Steel 110
Basement
Haas Howell,
EG7 Diesel Fuel Steel 110
Basement

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MAP TANK/ TANK CAPACITY YEAR


CONTENTS LOCATION
ID STORAGE ID MATERIAL (gallons) INSTALLED

Art and Humanities.


EG8 Diesel Fuel Outside next to Steel 120
entrance1
GCB, L-Lot Parking
EG9 Diesel Fuel Steel 100
Lot1
Student Center
EG14 Diesel Fuel Loading Dock (Grease Steel 100
Container)1
Student Center
Loading Dock
EG14 Diesel Fuel Steel 200
Mechanical Room.
Room 170
EG19 Diesel Fuel Aderhold. Room 014A Steel 250
Rec Center. Outside at
EG20 Diesel Fuel Steel 270
back
Piedmont-Ellis Student
EG22 Diesel Fuel Steel 660
Housing
EG25 Diesel Fuel 75 Piedmont Steel 275
100 Auburn Avenue –
TBD2 Diesel Fuel Steel
President’s Office
TBD2 Diesel Fuel Steel

Grease Containers
Waste Cooking
Trap Panther Den Steel 1,500
Grease
Waste Cooking
Dumpster Panther Den Steel 250
Grease
1
Will be provided with temporary berms/absorbent socks until double-walled tanks can be purchased and
installed. Check on the status of this.
2
These tanks are new tanks that have not been officially assigned an identifier yet.

4.2 Underground Storage Tanks (UST’s)


GSU maintains two underground storage tanks. One is at 103 Decatur Street in Atlanta and has a
capacity of 2,000 gallon. The other is located at 50 Decatur Street in Atlanta and has a capacity if 4,000
gallons. Because these are fully covered tanks subject to UST regulations, they are exempt and otherwise
not included in this plan. Loading and unloading procedures for these tanks are similar to other fueling
activities at the campus performed by truck.

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4.3 Oil-Filled Electrical, Operating and Manufacturing Equipment


Oil is stored within several pieces of the campus’s electrical, operational and manufacturing equipment in
the form of hydraulic fluid and operational lube oil. A summary is provided in Table 2 – Oil Filled
Equipment

Table 2 – Oil Filled Equipment

BUILDING BUILDING EQUIPMENT CAPACITY


LOCATION CONTENTS
NUMBER NAME NAME (gallons)1

Basement
Elevator
36 Rialto Theater Mechanical Room Hydraulic Oil 115
Reservoir
Across Room 002
Mechanical Room Elevator
37 Haas Howell Hydraulic Oil 140
Across Room 16 Reservoir
3rd Floor Elevator
33 Science Annex Hydraulic Oil 115
Mechanical Room Reservoir
Mechanical Room Elevator
2 Sparks Hall Hydraulic Oil 200
Near Cashier Reservoir
Elevator
4 Library North Plaza Elevator Hydraulic Oil 100
Reservoir
Across from Elevator
32 Library South Hydraulic Oil 200
Elevator #5 Reservoir
SW Entrance on Elevator
Hydraulic Oil 165
Alumni Hall Side Reservoir #1
Elevator
54 Parking Deck M SE Deck Corner Hydraulic Oil 165
Reservoir #2
of
Gilmer/Piedmont Elevator
Hydraulic Oil 165
Reservoir #3
Elevator
Penthouse Hydraulic Oil 140
University Reservoir
3
Center 1st Floor Elevator
Hydraulic Oil 140
Mechanical Room Reservoir
Ambulance Lift Lift Reservoir Hydraulic Oil 175
Sports Arena
8 (Physical Mechanical Room
Elevator
Education) in Parking Lot Hydraulic Oil 85
Reservoir
Behind
Courtland
11 Cabinet Shop Hydraulic Oil 140
Building
Elevator Hydraulic Oil
21 Alumni Hall Left of Room G35 140
Reservoir #1

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BUILDING BUILDING EQUIPMENT CAPACITY


LOCATION CONTENTS
NUMBER NAME NAME (gallons)1

Elevator Hydraulic Oil


140
Reservoir #2
Drum Hydraulic Oil 55
Hallway Next to
University Elevator
29 Panther Card Hydraulic Oil 140
Bookstore Reservoir
Office
Elevator Hydraulic Oil
Room 169 85
Reservoir
Elevator Hydraulic Oil
55 Student Center 85
Reservoir
Main Elevators
Elevator Hydraulic Oil
85
Reservoir
Elevator
Glass Elevator Hydraulic Oil 70
Reservoir
Recreation Elevator
58 Hydraulic Oil 70
Center Reservoir
Room 47
Elevator
Hydraulic Oil 70
Reservoir
Mechanical Elevator
60 University Lofts Hydraulic Oil 140
Shop/Break Room Reservoir
1
Under 55-gallons, SPCC Rule does not apply.

4.4 Oil Storage in Containers with a Capacity of 55 Gallons or Greater (Other Than AST’s, UST’s
and Mobile Bulk Storage Containers)
Various oils are stored on campus in 55-gallon containers. These oils are primarily fuel (diesel) to fuel
generators and equipment, lubricating oils for machinery, or hydraulic oils for elevators or equipment. A
summary of these containers is provided in Table 4.

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Table 3 – Oil Containers

CONTAINER(S)
LOCATION CONTENTS
CAPACITY (gallons)

Various fuels, lubricating oils, 55-gallon. Number in


National Science Center
and hydraulic oils. storage varies.
35 Broad Street – Various fuels, lubricating oils, 55-gallon. Number in
College of Business and hydraulic oils. storage varies.
Sparks Hall – Basement Various fuels, lubricating oils, 55-gallon. Number in
Mechanical Room and hydraulic oils. storage varies.
Various fuels, lubricating oils, 55-gallon. Number in
Aquatics Building
and hydraulic oils. storage varies.
University Commons – Various fuels, lubricating oils, 55-gallon. Number in
Mechanical Room and hydraulic oils. storage varies.
100 Auburn Building – Various fuels, lubricating oils, 55-gallon. Number in
Mechanical Room and hydraulic oils. storage varies.

4.5 Dedicated (Onsite) Mobile Bulk Oil Storage Containers


The campus does not utilize mobile bulk storage containers.

4.6 Tank Truck Loading/Unloading Areas


In general, there is little loading and unloading of oils from trucks at the GSU campus. This is because
the primary uses of the oil are maintenance or emergency related. For example, emergency generators are
only operated for a short time per year to demonstrate operability. The general locations of the
loading/unloading areas are shown on Figure 2. See Section 10 for details pertaining to loading and
unloading operations.

4.7 Additional Oil Storage Areas or Oil Handling Activities


Oil storage that is exempt from 40 CFR Part 112 includes but is not limited to:
 Any aboveground storage tank/container with a capacity of less than 55 gallons of oil, such as
quarts of motor oil or small operational tanks;
 Systems for collecting storm water and wastewater; and
 Onboard oil containers used to power the movement of a vehicle.

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5. BULK OIL STORAGE


The SPCC regulations require that the SPCC Plan describe the spill prevention techniques used to prevent
discharged oil from reaching a navigable water course. One or more of the minimum spill prevention
standards provided in the regulations must be employed at each potential oil discharge area. In addition
to the minimum prevention standards, the regulations require that the SPCC Plan discuss the campus’s
conformance with applicable spill prevention guidelines listed under 40 CFR Part 112.7(j), other effective
spill prevention and containment procedures, or, if more stringent, State rules, regulations and guidance.
Appropriate containment and diversionary structures are provided for the campus’s bulk oil storage areas.
All oil storage containers and associated piping on campus are steel and are compatible with their
contents. Each container installation is engineered or updated in accordance with good engineering
practices to avoid discharges. Fail-safe engineering devices associated with the on-site containers are
listed in Table 1. Details of containment and/or diversionary structures are presented and discussed in the
following sections.

5.1 Construction and Secondary Containment for Bulk Oil Storage Tanks

Many of the bulk storage tanks on campus are double-wall constructed tanks. This construction provides
adequate volume for containment as well as the ability to monitor for leaks in the primary (inner) tank.
The tanks on campus that are currently double walled tanks include: EG6, EG7, EG9, EG14, EG19,
EG20, EG22, EG25.
Secondary containment for other tanks on campus is provided by constructed berms and absorbent socks.
These containment areas are in place until more permanent curbs can be constructed. The tanks that
utilize the berms and socks for containment are: EG1, EG2, EG3, EG5, and EG8.
These containers are subject to only the full secondary containment requirement, which is intended to
address the full capacity of the containers plus adequate freeboard for precipitation. The materials and
method of construction for each container are compatible with the material stored in the tank and the
conditions of storage such as pressure and temperature.

5.2 Construction and Secondary Containment for Other Oil Storage Areas
GSU stores various petroleum products in smaller containers throughout the campus. These containers
consist of drums, and oil-filled operational equipment. These containers are subject to only the general
secondary containment requirement, which is intended to address the most likely oil discharge and allows
for both active and passive secondary containment. The materials and method of construction for each
container are compatible with the material stored in the tank and the conditions of storage such as
pressure and temperature. The oil storage containers subject to the general secondary containment
requirements are described in detail in the following sections.

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5.3 Oil Storage in Containers with a Capacity of 55 Gallons or Greater (Other Than AST’s,
UST’s and Mobile Bulk Storage Containers)
The oil stored on the GSU campus is primarily of three different types. They are: fuel oil, hydraulic oil,
and oil associated with cooking. The fuel oil stored on campus is used to power emergency power
generators. The hydraulic oil is used in the operation of hydraulic elevators and lifts, and the cooking oil
is used in the food preparation areas primarily for frying. Other maintenance and lubricating oils are used
on the campus but they are not stored in containers that are 55 gallons or larger and are, therefore, not
addressed in this plan.
These containers are subject to only the general secondary containment requirement, which is intended to
address the most likely oil discharge and allows for both active and passive secondary containment. Each
container is provided with a secondary means of containment for at least the total container capacity. The
materials and method of construction for each container are compatible with the material stored in the
tank and the conditions of storage such as pressure and temperature.
Table 4 provides detailed information regarding the campus’s oil storage areas. The table includes
construction information, piping information, and other construction information. The container materials
and method of construction are compatible with the material stored in the tanks and the conditions of
storage such as pressure and temperature.

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Table 4 - Drum Containment

TANK/ CONTAINER
SECONDARY CONTAINMENT
STORAGE AREA CAPACITY (gallons)

National Science Various fuels, lubricating


Center oils, and hydraulic oils. Containment Pallets.

35 Broad Street – Various fuels, lubricating


Containment Pallets.
College of Business oils, and hydraulic oils.
Sparks Hall – Basement Various fuels, lubricating
Containment Pallets.
Mechanical Room oils, and hydraulic oils.
Various fuels, lubricating
Aquatics Building Containment Pallets.
oils, and hydraulic oils.
University Commons – Various fuels, lubricating
Containment Pallets.
Mechanical Room oils, and hydraulic oils.
100 Auburn Building – Various fuels, lubricating
Containment Pallets.
Mechanical Room oils, and hydraulic oils.

5.4 Oil-Filled Electrical, Operating and Manufacturing Equipment


All oil-filled electrical, operational and manufacturing equipment provide a secondary means of
containment for at least a portion of the total container capacity. Oil-filled electrical, operational and
manufacturing equipment is subject to only the general secondary containment requirement, which is
intended to address the most likely oil discharge and allows for both active and passive secondary
containment.
All oil-filled electrical equipment owned by Georgia Power provide an initial means of secondary
containment.
A large leak or rupture at the Georgia Power-owned transformer would generally disrupt the power
service to the campus, at which time the leak would become known. No additional secondary containment
is provided for these transformers. Small amounts of oil releases would be contained within the rock area
until it could be cleaned up within a short time period. GSU’s responsibility is notifying Georgia Power
in the event of a spill and/or leak; phone numbers to provide such notification are provided in Section
13.5.

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5.5 Drainage of Containment Areas


Any rainwater that falls within the outside containment areas is inspected for signs of oil contamination
including sheen, discoloration, and odor. If no signs of contamination are found, the storm water is
allowed to evaporate or is released by the manually activated valve to the city storm sewer. If
contamination is found, the contents of the containment will be pumped into drums by qualified personnel
or a contractor and disposed of properly (see Section 13.4 Waste Disposal)

5.6 Corrosion Protection


This section is not applicable since there are no completely buried metallic storage tanks or piping on
campus.

5.7 Partially Buried and Bunkered Storage Tanks


This section is not applicable since there are no partially buried or bunkered storage tanks on campus.

5.8 Inspections and Tests


The SPCC rule requires aboveground bulk storage containers be tested for integrity on a regular schedule
and whenever material repairs are made to the tank. The frequency and type of testing must take into
account container size and design. Visual inspection of the storage containers and the container’s
supports and foundations is conducted monthly. In addition, the diked areas around the container are
inspected for signs of deterioration, discharges, or accumulation of oil. Records of inspections and tests
are kept and compared to previous records, for the purpose of noting deteriorating condition. Inspections
and tests are discussed further in Section 11 - Inspections, Tests and Records.

5.9 Heating Coils


GSU does not use heating coils with any of its oil storage tanks.

5.10 Overfill Prevention Systems


Each of the campus’ oil containers that require routine filling is equipped with a direct vision gauge or the
ability to see the level of oil in the tank. Filling procedures require the tanks to be gauged prior to
receiving product and for the tanks to be filled to a safe fill height, which is designated to be 90% of the
tank capacity. During filling and transfer operations, a GSU or fueling vendor employee is present and
visually monitors the gauges for the entire duration of the filling. Secondary containment is provided in
the event of overfill as described throughout this Plan. All drums are manually filled by campus
personnel within buildings. The level of material in tanks, drums, and containers is determined visually
prior to filling to prevent overfill.

5.11 Visible Discharges


Visible oil leaks including leaks from container seams, gaskets, piping, pumps, valves, rivets, and bolts
are addressed immediately and reported to the Environmental Program Officer. Any accumulation of oil
in diked areas is removed immediately. Cleanup is performed using onsite materials by GSU personnel
or, for larger spills, by an outside contractor. The cause for the discharge is corrected promptly. Oil

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contaminated rain water is pumped into drums for proper disposal off site at an appropriate licensed
disposal facility.

5.12 Release Reporting


Protocol for release reporting shall be in accordance with the Spill Response Plan outlined in Section 13.

5.13 Preventing the Mixing of Incompatible Substances


The bulk storage tanks and associated equipment are clearly labeled and identified for their intended use.
The fill port for each tank is directly adjacent to each tank to prevent the mixing of incompatible
substances.
Separate pallets are utilized for drums containing incompatible substances.

5.14 Spill Prevention at Pumps and Valves


Pumps and valves are located within the secondary containment provided for the storage tank. In
addition, all storage areas are located within buildings on a concrete floor, which provide additional
containment. The campus is typically manned 24-hours per day. All pumps and valves that could cause a
release if opened are locked or are located in restricted access (i.e. locked) areas.

5.15 Secondary Containment for Transfer Stations


There are no remote transfer stations for the bulk storage tanks.

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6. DRAINAGE CONTROLS
6.1 Diked Storage Areas
All outdoor, uncovered, diked areas on campus are inspected regularly for the accumulation of rainwater.
Drainage controls from these containment areas are kept closed and off are manually actuated. Drainage
from the containment areas is piped to the storm sewer only after it has been inspected for oil
contamination including sheen, discoloration, or oil odor.

6.2 Undiked Storage Areas


All oil storage areas at the GSU campus are either diked or contained in such a way that spilled oil will
drain to a diked area. Undiked areas are protected with temporary containment on an as needed basis.

6.3 Undiked Transfer Areas


The campus’ outdoor truck loading/unloading areas are undiked. The potential for oil to accumulate or
otherwise be present in this area will arise primarily from leakage or spillage during active truck
unloading operations. As is described in Section 10, below, the truck unloading activity is continuously
monitored by campus personnel. Temporary containment is installed during each loading/unloading event
as deemed necessary.
Other outdoor transfer areas are safeguarded prior to transfer operations via the placement of either drain
covers or temporary curbing.
Accumulated stormwater in the temporary loading/unloading areas is inspected prior to removing the
containment devices. If there is any sign of contamination, the water is either treated on-site or pumped
to 55-gallon drums and disposed of at approved municipal or commercial disposal facilities. The policy at
GSU is to immediately clean up any spills. Each area is cleaned after each delivery to eliminate any
potential for stormwater contamination.

In the event of a small spill as a result of transfer operations, the delivery personnel and the GSU
employee monitoring the transfer will immediately implement spill response procedures, including using
spill pads, booms and/or absorbent materials to control the material and/or drainage that may contact the
material. Secondary containment of the area will be provided by the placement of the spill booms or
equivalent measures to divert material away from local drainage courses and structures. Final cleanup
and housekeeping measures will be verified by the Environmental Program Officer or his designee to the
extent necessary to ensure that no residual material remains that could adversely impact subsequent
drainage from the area, which may include soil removal or other methods. Absorbent materials will be
used to cleanup and remove the released material.

Information regarding the type of absorbent materials and other spill response materials and equipment
maintained onsite by the university, as well as the onsite storage areas for these materials, is provided in
Section 13.

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6.4 Drainage Inspections


The campus is routinely inspected to ensure that there is no contamination that could affect stormwater.
Spills on campus are cleaned as soon as they occur.

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7. POTENTIAL SPILL PREDICTION, VOLUMES, RATES AND


CONTROLS
7.1 Spill Scenarios
Materials handled on campus have a low potential for release to ground and surface waters. All tanks,
containers and equipment are stored inside some form of containment such as double walled tanks and
areas with concrete floors and berms. Any material spilled within the containment areas are absorbed
with absorbent material or pumped out by a removal contractor. GSU uses primary and secondary
containment measures throughout the plant. Primary containment measures include tank and system
designs, maintenance procedures, and handling and storage procedures to prevent a release. Secondary
containment measures consist of engineering controls, response procedures and equipment (containment
walls, drain covers, absorbent materials) to prevent releases.
To reduce the chance that materials will be exposed to a fire, all indoor storage areas are equipped with
fire extinguishers. In many areas, these extinguishers are backed up with a sprinkler system. In many
areas of campus a dedicated alarm system will be activated in case of fire and will alert Campus Police
and the Fulton County Fire Department.
Leaks can develop if seals become worn at pumps and valves. Loose flanges at pipe and valve
connections and worn out flange gaskets are especially subject to leakage. Because valves and pumps are
located inside enclosed buildings with concrete floors and floor drains, the risk of a release from these
sources is low throughout the plant.
Pipe leaks and rupture are a potential source for spills. Because all pipes are aboveground and are located
either inside enclosed buildings or within diked areas with concrete floors, the risk of a release from these
sources is low throughout the plant.
A tank failure (loss of integrity of the primary tank) is also a potential spill scenario. While a tank rupture
can be catastrophic and can occur on any tank, this mode of failure is rare. The risks are greatest where
there is a large volume of material being stored and venting for in-breathing and out-breathing is
inadequate. Secondary containment areas are designed to contain the contents of the largest tank and
sufficient freeboard for precipitation. The majority of the tanks are located within buildings or diked
areas which are large enough to contain the contents of the largest tank within the building.
Forklifts place drums at risk throughout the plant. One possible spill scenario includes damage to one or
more 55-gallon drums. Campus personnel are trained on traffic safety to minimize accidents. Spill kits
including pigs, sorbent pads and granulated oil sorbent are kept at various locations throughout the
campus to address small spills. University personnel are trained on materials handling and the location
and proper use of spill response equipment. Spill response kits are routinely inspected and materials are
replenished as needed.
Table 5 provides a prediction of the potential type of failure(s), estimated amount of material which may
be released, the probable flow direction of a spill, should one occur, and the existing secondary
containment facility for each container or area of concern. Potential types of equipment failure include
tank overflow, tank rupture, leakage of the tank or associated piping, and failure of unloading equipment.

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Table 5 - Spill Prediction Volumes


Potential
Estimated Rate
Source Event Spill Volume Remarks
GPM
(gals)

Probable. Spill kits or absorbent


materials will be placed near the
Overfilling or a storage tank and/or will be made
ruptured hose during 0 to 401 802 available by fuel delivery vendor
filling until overfill prevention equipment
is installed.

Low probability event that primary


containment structure would fail
Structural failure or and/or unauthorized personnel
AST 0 to 660 Variable
vandalism gained access to storage tank
areas. Secondary containment
present to prevent impact.
Low probability event. Most ASTs
are housed within a closed structure.
Vehicle collision 0 to 370 Variable
The remaining ASTs are not in
regular path of vehicle traffic.
Low probability event. Weight of
Overturn or puncture in
0 to 370 Variable tank and generator offers protection
a storm event
against liftoff in excessive wind.
All of the hydraulic elevators are
located within buildings in rooms
that are locked to unauthorized
personnel. Equipment and supplies
are occasionally stored in these
Equipment impact or
Hydraulic Elevators 0 to 300 Variable rooms and placement or retrieval
puncture
creates a situation where the
container might be impacted. The
impact would likely be minor. Spill
kits and spill response would enable
effective containment or cleanup.
Transfer of fuel contents from
drums to smaller containers is
frequent and is achieved by a pump
system. Rupturing of the pump line,
Content Transfer <1 gallon <0.5
overfilling, or other spill is probable,
Drums (55-gallon) but amount would be minimal. Spill
kits and spill response would
mitigate potential spills.
Vehicle and equipment traffic is
heavy in the garage area.
Vehicle collision 0 to 55 Variable Containment measures and spill kits
are in place to mitigate possible
spills.

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Potential
Estimated Rate
Source Event Spill Volume Remarks
GPM
(gals)

Oxidation (Rust) or breakdown of


tank integrity is possible but
unlikely. New tanks are provided
with new product shipment. Tanks
Structural failure 0 to 55 Variable
stored for <1 year. Spill
containment measures are intended
with spill kits being available in
the interim.
Low probability event that primary
containment structure would fail
Structural failure or and/or unauthorized personnel
0 to 1,500 Variable gained access to storage areas.
vandalism Secondary containment and fencing
Grease Traps needed where practicable, along
with adequate lighting.
Low probability event. Grease
containers are sheltered or are in a
Vehicle collision 0 to 1,500 Variable
location where there is no vehicle
access.
1
Based on a maximum pumping rate of 80 gallons per minute from the fill truck and a maximum of 30 seconds to turn off the
pump.
2
Approximate maximum pumping rate of the fill truck.

7.2 Potential Chemical Reaction


Employees are trained in chemical handling and on the potential chemical reactions and chemical
compatibility of on-site materials. Any written operating procedures for handling materials are
maintained on-site. No incompatible chemicals are stored together on spill pallets within the facility. As
new materials are introduced to facility operations, an incompatibility review is performed by the
Environmental Program Office. Material compatibility of the chemicals stored on site is shown in MSDSs
or SDSs. MSDSs and SDSs are stored onsite in specific binders around the campus and the master set is
maintained in the Environmental Program Officer’s office.

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7.3 Spill History


This section will provide a discussion of future releases on campus. GSU has not had any reportable oil
spill within the last five years. The table below will be utilized to record incidences of future spills.
Date Spill Spill Description Approximate Spill
Reported Volume

If there is a spill on campus, an assessment of the cause of the spill is conducted. Documentation of spills
shall be recorded and filed on campus (Environmental Program Office) and listed in this section of the
Plan.

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8. TRAINING OF SPILL PREVENTION PROCEDURES


Training protocols are explicitly outlined to help prevent spills and keep employees and visitors aware of
the potential hazards on campus.

8.1 Personnel Training


The primary method of spill management at GSU is prevention. Prevention of spills has been emphasized
through the training of personnel. All university personnel involved in the handling of oil and chemicals
are properly trained in general facility operations, operations and maintenance of equipment to prevent
discharges, discharge (spill) response procedures and protocols, applicable pollution control laws, rules
and regulations, general facility operations, and the contents and requirements of this SPCC Plan.
New employees attend an orientation program which includes a prevention, awareness and spill response
training. All university representatives are instructed to report oil spills and releases from equipment so
that early corrective action can be initiated. In addition, all employees are trained in the proper methods
and equipment for containment of spills so that if possible, employees can clean up spills as they occur.
Maintenance personnel are additionally instructed to watch for unusual conditions that may precede the
loss of materials from equipment or systems.
Annual safety and spill prevention briefings are held with responsible employees. Annual briefings also
serve as refresher training and include a review of any spills, discharges, and failures or malfunctions of
equipment from the previous year in addition to recently developed safety protocols and any updates to
federal or local regulations. These briefings and training sessions facilitate discussions of spill events,
methods for improving operations, failures, malfunctioning equipment and precautionary measures.
Records of the annual briefings and discharge prevention training maintained with the Environmental
Program Officer. An Annual SPCC Training Outline and Participant Log form is included in Appendix D

8.2 Visitor Training


Visitors are required to sign the visitor log prior to entering parts of the campus associated with material
storage and handling, manufacturing or packaging. If needed, GSU staff will brief the visitor on any
environmental rules or concerns in the area the visitor will be going.

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9. FACILITY TRANSFER OPERATIONS


9.1 Facility Transfer of Oils
Facility transfer operations of oils include transfer of new and used fuel oil, and new and used
lubrication and maintenance oils. The majority of facility transfer operations take place within the
building. Spills inside the main facility would be visible and confined within the buildings to the concrete
floor in proximity of the storage areas or area of use. Drains from the buildings are connected ultimately
to the sewer. Therefore, building drains are protected during transfers as needed and during spill control
activities. Drums are stored in designated areas and all filling occurs in these areas.

9.1.1 Fuel Oil


Fuel oil is used to run emergency power generating units. Since these units are operated infrequently, the
demand for fuel is low. This fuel oil is brought to campus in two primary ways. First, it is brought in 55-
gallon drums. The drums are used to transport the fuel by drum dolly or similar device to the mechanical
room where the generator is located. A mechanical hand drum pump is then used to fill the generator’s
tank. If the drum is not empty by the end of the transfer, it is either returned or appropriately stored in the
mechanical room.
The other way the fuel is transferred is from a fuel truck to the tank. This method is used on generators
and tanks that are accessible from the outside of the building.

9.1.2 Equipment Containing Oil (Elevators)


In the event a hydraulic elevator or lift oil reserve becomes low, oil is transferred from drums of hydraulic
oil either directly to the oil reserve or to a smaller container which is then transferred to the elevator
reservoir. These transfers are typically small amounts of oil and are constantly supervised by GSU staff
or elevator service vendors.

9.1.3 New Maintenance and Compressor Oil


New lubrication, maintenance and compressor oils are stored in original 55-gallon or smaller
drums. Drum contents are transferred to smaller containers (usually 5-gallon buckets) for use in
equipment through the campus using a transfer pump, or rack and gravity feed valve. Drip pans are
utilized below transfer valves. If necessary, drums may be moved to another location on campus using
purpose built drum dollies or by forklift and pallets.

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10.LOADING AND UNLOADING OPERATIONS


All of the campus’s loading/unloading procedures meet the minimum requirements and regulations
established by the United States Department of Transportation (USDOT). Bulk storage tank filling
operations are performed in such a way to ensure that a tank is not overfilled. Drums and other containers
are handled and unloaded carefully to prevent damage. Additional spill prevention procedures that are
not noted below may be used per the carrier’s standard practices.

10.1 Loading/Unloading of Oils


In general, unloading of oils on campus is either via transfer from tanker truck to a bulk storage tank or
via the unloading of drums of oil. Loading/unloading areas for filling any of the bulk storage tanks are
located adjacent to each stationary tank on campus. The general locations are shown on the detailed site
plan (Figure 2). In addition to loading/unloading areas for the tanks, drums are generally delivered to
loading docks. The following sections describe the regulations in place governing the transfer of oils and
discuss the campus’s procedures and conformance with the regulations.

10.1.1 Federal DOT Regulations


The federal Department of Transportation (DOT) places some responsibility on the carrier to ensure the
delivery is completed successfully. These regulations are described in detail in 49 CFR 171, 173, 174,
177 and 179.

10.1.2 Loading/Unloading Procedures


Loading/unloading at the plant is a joint activity of the operator and the carrier. In addition to the
requirements for spill prevention control and countermeasures, GSU requires drivers to comply with DOT
regulations in 49 CFR 177 and university standard operating procedures. A trained employee of
performs or monitors and supervises every delivery, thus spills from the fill port or the delivery truck are
likely to be small and to be contained in the vicinity through the use of absorbent material stored at each
tank at the plant.
Written loading/unloading procedures that include determining the safe volume of product to be
unloaded, safe practices to be followed, requirements for spill response materials, etc. are also followed.
Copies of the written loading/unloading procedures can be found in Appendix E. These loading/unloading
procedures are posted adjacent to each delivery area in order to minimize the potential for a release during
unloading activities.
Tank filling is performed by qualified GSU vendors. The tank filling process is observed so that spills
from the fill port or the delivery truck would be discontinued quickly and contained before impacting the
environment. For each bulk loading/unloading event, a Bulk Material Receiving Form is completed by
university personnel overseeing the loading/unloading event (Appendix E).
Fuel is transferred at the site of each generator. Transfers are attended at all times by university personnel
or personnel from the fueling vendor. Spill containment materials are located in the transfer area. All
piping for ASTs is located aboveground. Drip pans are placed below hose connections at the truck and at
the transfer piping. Any leakage from the piping at the transfer point would be contained on the within the
drip pans and concrete floor within the concrete containment berm. Terminal connections are blank

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flanged or capped at the transfer point when not in service or in standby for an extended time and marked
as to its origin.
The most likely spill scenario is a tank overfill or loading-related spill. Spills related to disconnecting the
fill hose are usually only a few gallons. Tank overfills are usually larger, resulting in a discharge through
the vent of 150 to 250 gallons per minute (the filling rate typical of a truck-to-tank transfer). The risk of
tank overfill is minimized on campus since the filling is attended by personnel, level gauges are
periodically inspected and maintained as needed and written delivery procedures are up to date and
followed.
Although GSU implements preventive maintenance programs and site-specific unloading procedures that
are designed to minimize the potential for spills, it is possible that a release from tank vents, fill ports or
from the tank truck could occur. The unloading operations are observed so that spills from the fill port or
the delivery truck are likely to be small and to be contained in the vicinity through the use of absorbent
material. In the event of a spill as a result of transfer operations, the oil supplier and/or university
personnel overseeing the unloading event will immediately implement oil spill response procedures,
including using oil spill booms and/or absorbent materials to control the oil and/or drainage that may
contact the oil. Secondary containment of the area will be provided by the placement of the oil spill
booms or equivalent measures to divert oil away from local drainage courses and structures. Final
cleanup and housekeeping measures will be provided by the emergency response contractor to the extent
necessary to ensure that no residual oil remains that could adversely impact subsequent drainage from the
area, which may include triple-flushing the area or other methods. Oil absorbent materials will be used to
cleanup and remove the released oil.
Information regarding the type of oil spill booms, oil absorbent materials and other spill response
materials and equipment maintained on campus by the university, as well as the onsite storage areas for
these materials, is provided in Section 13.

10.1.3 Secondary Containment Provisions for the Tank Unloading Area


All of the fuel tanks on diesel generators receive deliveries via truck. All of these fuel tanks contain the
same type of oil, diesel fuel.
Trucks are offloaded at loading areas adjacent to each tank. An accident involving overfill, hose rupture,
or a disconnection spill could discharge to the asphalt pavement surface in these areas. However,
temporary secondary containment is erected in the loading areas for Tank Nos. 1 and 2 during each
delivery as for the containment of a potential leak or spill. Upon each delivery, a drain cover is installed
at the nearest grate drain. The cover is removed when the delivery is complete and the loading area is
inspected to ensure there were no spills.
Grease traps and containers are located at the Panther Den and the Student Center Loading Dock. These
traps and containers are only unloaded via qualified vendors (currently Griffin Industries) using waste
oil/grease tanker trucks. Unloading procedures for the grease include similar measures as those used for
loading the fuel storage tanks.
No other bulk oil loading/unloading operations take place at the campus.

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10.1.4 Measures to Prevent Vehicle Departure Prior to Line Disconnect


Delivery personnel are advised to follow all guidelines in Appendix E in order to prevent vehicles from
departing before complete disconnection of flexible or fixed oil transfer lines.

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11. INSPECTIONS, TESTS AND RECORDS


11.1 Monthly Visual Inspections
Visual inspections of all bulk storage tanks at the plant are conducted monthly as required by federal
regulations 40 CFR 112.7(e). In addition, these visual inspections include other storage areas such as
drum storage, grease collection areas, etc. A typical inspection log sheet which is used for this purpose is
provided in Appendix F. This inspection includes:
 Inspection of exterior surfaces of all tanks, dikes, pipes, valves and other equipment for leaks,
corrosion and maintenance deficiencies;
 Identification of visually observable cracks, areas of wear, corrosion, poor maintenance and
operating practices, excessive settlement of the structures, poor pipe support or alignment,
malfunctioning equipment and structural and foundation weaknesses; and
 Inspection and monitoring of level gauges.

The more detailed inspection components applicable to the campus’s storage and handling are indicated
on the inspection form.

Any deficiencies identified during the visual inspection program are promptly repaired; deficient
equipment is drained of liquid and taken offline if necessary to accommodate the required repairs.
Documentation of adequate response measures for all deficiencies identified during the visual inspection
is maintained together with the completed inspection logs.

In addition to response measures provided as a result of the monthly inspection program, at all times,
discharges which are observed to result in a loss of liquid from any container, including, but not limited to
seams, gaskets, piping, pumps, valves, rivets, and bolts are promptly corrected.

11.2 Annual Inspections


GSU performs a more thorough inspection of campus equipment on an annual basis. This annual
inspection complements the monthly inspection described above and is performed in the first quarter of
each year using the checklist provided in Appendix F of this Plan.
The annual inspection is preferably performed after a large storm event in order to verify the
imperviousness and/or proper functioning of drainage control systems. Written annual inspection records
are signed by the Environmental Program Officer and maintained with this SPCC Plan for a period of
three years.

11.3 Bulk Oil Storage Integrity Testing


GSU does not deviate from the integrity testing provision of 40 CFR 112.8(c)(6) for drums and for
storage tanks. All of the tanks on campus are made of steel, have Continuous Release Detection Methods
(CRDM), and have spill prevention measures. This puts the storage containers in SP001 Category 1, and
the prescribed inspection requirements are only monthly inspections.

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11.4 Brittle Fracture Evaluation


The university does not maintain any field-constructed aboveground containers. Therefore, brittle
fracture evaluation is unnecessary.

11.5 Record Keeping


Records of inspections and maintenance are on file at GSU in the office of the Environmental Program
Officer. GSU also keeps written and electronic delivery records for fuel oil. These forms and records are
proprietary and thus not included in this plan. They are available for review on a case-by-case basis.
Table 6 - Inspection Schedule, below, lists the records that should be maintained at the plant.
The following additional records are also maintained at the plant: equipment age, make and
specifications; piping and instrumentation diagrams (P&ID); maintenance/repair records; spills, accidents
and near misses; results of release investigations; and personnel training records.

Table 6 - Inspection Schedule


INSPECTION RECORD
STORAGE
REGULATION TYPE/FREQUE INSPECTION DESCRIPTION RETENTION
TYPE
NCY PERIOD
Daily None Required N/A
Inspection of campus with Monthly Inspection
Monthly 3 years
Form.

40 CFR Inspection of campus with Annual Inspection


Oil Storage Annual 3 years
112.7(e) Form.
Not required, but, if
performed, retained
Structural Non-destructive integrity testing.
until the next
integrity test

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11.6 Good Housekeeping


Good housekeeping involves the maintenance of a clean and orderly work environment. It is part of
GSU’s overall accident prevention effort. All personnel are responsible for the cleanliness of their work
area. They are instructed in the importance of good housekeeping procedures and receive periodic
training on good housekeeping practices.
Examples of good housekeeping techniques being used on campus include;
 Maintenance of fire extinguishers and spill response kits in dedicated locations, which are
known by all personnel;
 Neat and orderly storage of materials in dedicated areas;
 Open and marked traffic lanes free of debris, supplies and equipment;
 Prompt cleanup of spills to prevent accidents, migration of contaminants and runoff to
surface and ground waters; and
 Labeling of all materials.

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12.SECURITY
The university’s 24/7 security prevents unauthorized access and aids in the prevention of accidental or
intentional release of materials to stormwater runoff as a result of vandalism or other improper use of the
campus.

12.1 Fencing
In general, the university does not implement fencing around the property. However, entrances to areas
were oil is stored are restricted to university personnel. Contractors and visitors are required to sign a
visitor’s log. The site is fully illuminated and typically manned 24 hours a day, 7 days a week.
Personnel are present during normal working hours and conduct routine patrols of the plant.

12.2 Flow Valves and Starter Controls Locked


Master flow and drain valves and any other valves permitting direct outward flow of a container’s
contents to the surface remain in the closed position when in non-operating or non-standby status.

12.3 Loading/Unloading Connections Securely Capped


The majority of the portable containers are enclosed within buildings which are locked.
Loading/unloading connections are securely capped or blank flanged when not in service or in standby
service for an extended time.

12.4 Lighting Adequate to Detect Spills


University lighting is provided to facilitate the following activities:
 Transfer of oil from tank trucks to bulk storage tanks;
 Unloading of oil;
 Discovery of discharges occurring during hours of darkness by operating personnel, if present;
and
 Prevention of discharges occurring through acts of vandalism.

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13.SPILL RESPONSE PROCEDURES


This section describes response and reporting procedures in the event of a discharge on campus. The spill
response procedures are also included in Appendix G and thus are readily accessible in an emergency. A
copy of the spill response procedures is kept in or near the storage areas. A list of Emergency Contacts is
provided in Appendix G as well as in the front of this document. The list is also posted at prominent
locations throughout the university. A list of discharge response material kept on campus is included in
Section 14.3 below.
The following measures should be implemented upon the discovery of a spill or release:
 Halt any transfer operations
 Determine the source, type of product and amount spilled
 Stop the source of the spill or leak and initiate clean up response if possible (see
procedures below)
 Notify the Environmental Program Officer.
 If outside response in necessary, the Environmental Program Officer initiates calls to
listed contractors
 Continue to take all necessary corrective actions by keeping the product away from
traffic and waterways
For the purpose of establishing appropriate response procedures, this SPCC Plan classifies discharges as
either “minor” or “major,” depending on the volume, characteristics of the material released, and the
location of the spill.

13.1 Response to a Minor Discharge


Minor discharges are generally those where the quantity of product discharged is small, the discharge is
easily stopped and controlled, the discharge is localized near the source and is not likely to reach water,
and where the discharge poses no significant harm (or threat) to human health and safety or to the
environment.
The university is prepared to recover a spill on its property and minor discharges can typically be cleaned
up by GSU personnel. Equipment that is maintained for spill recovery includes sorbents, empty buckets
and drums, and shovels. Appropriate response materials are maintained by the Environmental Program
Officer who locates the equipment throughout the site and is prepared for its proper use during a spill
event.
In the event of a minor discharge, the following tasks will be completed:
 Ascertain that all unnecessary individuals are removed from the hazard area.
 Remove all ignition sources and utilize spark/explosion-proof equipment and proper
protective clothing if flammable substances are involved.
 Secure the source and contain the material having been released.
 The Environmental Program Officer, Michael Thompson, who serves as the Emergency
Coordinator, shall be notified by dialing:
Office: 404-413-3551
24-hour: 404-886-4289

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 Remove all surrounding materials which could potentially react with the material release,
if required.
 Utilize appropriate absorbent materials or pump liquid into proper storage containers.
 Place all contaminants and used materials in drums for proper disposal.
 Place all other wastes and contaminated soil in drums for proper disposal.
 Clean and test for reuse all emergency equipment utilized prior to resumption of
operations in affected area.

13.2 Response to a Major Discharge


A major discharge is one that cannot be safely controlled or cleaned up by GSU personnel, such as when
the discharge is large enough to spread beyond the immediate discharge area, the discharge requires
special equipment or training to clean up, the discharged material poses a hazard to human health or
safety; or there is a danger of fire or explosion.
If the spill cannot be handled by university personnel, an outside contractor is called. The contractors are
available 24 hours per day and their contact information is included in Appendix G. A list of telephone
numbers for campus notification and for fire departments and appropriate governmental agencies is also
included in Appendix G. However, initial response by GSU personnel shall include the following:
 Secure the area to protect all personnel and the public from any immediate danger.
 Evacuate the discharge site via the designated exit routes and move to a safe distance from the
discharge.
 Attempt to contain the spill with equipment from the spill kits (only if it is safe to do so).
 The Environmental Program Officer, Michael Thompson, shall be notified by dialing:
Office: 404-413-3551
24-hour: 404-886-4289
 Call 911, if necessary, to alert the fire department or other emergency services.
 Call an emergency response contractor if directed to by the Emergency Coordinator:
SPILL CONTACT ADDRESS PHONE
Hull’s Environmental 29 Southern Court Office: 678-909-5282
Service Hiram, GA 30141 Fax: 678-909-5245
24 Hour Emergency Response:
866-450-9077
EP&S of Vermont, Inc. 4625 Stonegate Industrial Blvd. (770) 888-1698 or
Stone Mountain, Georgia (800) 5-SPILLS
(577-4557)

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13.3 Spill Response Materials

Spill control equipment maintained on campus, in close proximity to the storage areas/tanks (Figure 2),
for responding to spill incidents includes but is not limited to:

 Sorbent pads/booms
 Pigs
 Granular absorbent material (e.g. speedi-dry)
 Empty drums/overpack drums
 Hand tools
University personnel are trained on materials handling and the location and proper use of spill response
equipment. Product that is released to the environment is reported in accordance with applicable local,
state, and federal regulations.

13.4 Waste Disposal

If a spill is contained and cleaned up by university personnel, all materials recovered from oil spill
response measures will be appropriately containerized and labeled as to contents, date and nature of
organization, etc. The university will complete a hazardous waste characterization of the containerized
waste in accordance with the requirements of state and federal regulations as applicable.

In the event that the material is determined to be a regulated hazardous waste, it will be managed and
disposed of appropriately as a hazardous waste. In the event that the recovered material is determined to
be non-hazardous, it will be managed as part of the university’s routine non-hazardous waste stream. If a
spill response contractor is necessary for cleanup activities, the contractor will properly dispose of the
recovered materials.

13.5 Spill Notification, Reporting and Response Requirements


A list of Emergency Contacts, such as the agencies to be contacted in the event of an emergency, is
included in Appendix G. Appendix G is meant for reference use only since names and numbers may
change over time. The list shall be updated any time names or numbers change. The list is maintained
onsite and is posted outdoors in the oil storage locations and transfer areas.

13.5.1 Internal Notification


In response to any spill, local university personnel must immediately notify the Environmental Program
Officer (or alternate listed in Section 0), who will then contact the reporting agency and complete the
Incident Reporting Form provided in Appendix G. The Incident Report is to be completed upon detection
of a discharge and prior to reporting a spill to regulatory agencies.

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Regulatory agencies should not be contacted until and unless directed to do so by the Environmental
Program Officer or his/her designee. The spill report should be prepared and shall include the following.

1) The name of the person making the report, their job title, and the name of the
company
2) Name(s) and telephone number(s) of individual(s) who discovered the spill
3) Exact Location on campus and phone number
4) Time and date of the discharge
5) Type of material discharged
6) Estimate of total quantity discharged.
7) Estimate quantity discharged to water body (if any)
8) Location and source of the discharge
9) Cause and circumstances of the spill
10) Description of all affected media (soil, water, etc.)
11) Existing and potential hazards
12) Whether an evacuation may be needed
13) Any damages or injuries caused by the discharge, if any
14) Corrective action being taken and an appropriate timetable to control, contain, and
clean up the spill
15) Identification of the personnel currently at the site of the spill
16) Other unique or unusual circumstances
17) Other individuals and/or organizations that have been notified or will be notified

13.5.2 GA EPD Notification and State of Georgia SPCC Rules


Any spill subject to the reporting requirements of 40 C.F.R. Part 302 - Designation, Reportable
Quantities and Notification, as discussed in Section 13.5.3 below, must be immediately reported to the
Georgia Department of Natural Resources, Environmental Protection Division (GA EPD) Spill Hotline at
404-656-4300 as soon as that person knows of the spill or release.
The State of Georgia defaults to federal regulations with reference to SPCC Rules. Georgia’s UST rules
do apply to the GSU campus since there are two USTs located on campus.
A spill in a dirt or gravel parking lot is considered to have impacted land and is reportable. The specific
reporting requirements are outlined below based on the size of the discharge and the affected media.

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13.5.3 Federal Notification


Regulations specified in 40 CFR Part 110.3 define a spill as the discharge of oil into, or upon the
navigable waters of the United States or adjoining shoreline in harmful quantities. Harmful quantities are
defined as a discharge that violates applicable water quality standards or causes a sheen upon, or
discoloration of, the surface water or adjoining shoreline.
If there is a spill of oil into or upon navigable water or adjoining shoreline which:
 exceeds 1,000 gallons in a single spill event
OR
 causes a film or sheen, or discoloration of the water or adjoining shoreline, or causes
sludge
OR
 emulsion to be deposited beneath the water surface
OR
 causes a violation of applicable water quality standards

In the event that such a discharge of oil upon navigable waters occurs, the Environmental Program
Officer (Section 2.2 above), or his designee, is to be notified immediately. The Environmental Program
Officer, or his designee, will then immediately notify the National Response Center (NRC) at 800-424-
8802. 40 CFR part 110.6 will be further consulted for appropriate notification procedures in the event
that direct reporting to the NRC is not practicable.

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14.SPCC PLAN AMENDMENTS BY THE REGIONAL ADMINISTRATOR


In the event that the university has discharged more than 1,000 gallons of oil in a single discharge in
harmful quantities into or upon the navigable waters of the U.S. or adjoining shorelines, or discharged
more than 42 gallons of oil in each of two discharges in harmful quantities into or upon the navigable
waters of the U.S. or adjoining shorelines within any twelve month period, the university must submit the
following information to the Regional Administrator within 60 days from the time that the university
exceeds these discharge thresholds:

(1) Name of facility, including owner and operator


(2) Name of personnel providing this information
(3) Location of facility
(4) Maximum storage or handling capacity of the facility and normal daily throughput
(5) Corrective action and countermeasures that have been taken by the facility, including
a description of equipment repairs and replacements
(6) An adequate description of the facility, including maps, flow diagrams and
topographical maps, as necessary
(7) The cause of such discharge(s), including a failure analysis of the system or
subsystem in which the failure(s) occurred
(8) Additional preventative measures that the facility has taken or contemplated to
minimize the possibility of recurrence
(9) Such other information as the Regional Administrator may reasonably require
pertinent to this SPCC Plan or discharge

Following submittal of this information, the university will appropriately amend this SPCC Plan as may
be specified by the Regional Administrator, in accordance with the requirements and procedures of
§112.4(f).

SPCC Plan
Georgia State University Page 37
FIGURES

SPCC Plan
Georgia State University
Figure 1: GSU Main Campus Site Plan
Figure 2: Diesel Storage Map
Figure 3: Waste Grease Storage Map
Figure 4: Elevator Lift Hydraulic Fluid Storage Map
SPCC Plan
Georgia State University

APPENDIX A
Signatures and Certifications

SPCC Plan – Appendix A


Georgia State University
SPCC Plan
Georgia State University

CERTIFICATION OF THE APPLICABILITY OF THE SUBSTANTIAL HARM


CRITERIA

Does the facility transfer oil over-water to or from vessels and does the facility have a
total oil storage capacity greater than or equal to 42,000 gallons?

Yes No X

Does the facility have a total oil storage capacity greater than or equal to 1 million
gallons and, within any storage area, does the facility lack secondary containment that is
sufficiently large to contain the capacity of the largest aboveground oil storage tank plus
sufficient freeboard to allow for precipitation?

Yes No X

Does the facility have a total oil storage capacity greater than or equal to 1 million
gallons and is the facility located at a distance (as calculated using the appropriate
formula in Appendix C of 40 CFR 112.20 or an alternative formula1 considered
acceptable by the RA) such that the discharge from the facility could cause injury to fish
and wildlife and sensitive environments?

Yes No X

Does the facility have a total oil storage capacity greater than or equal to 1 million
gallons and is the facility located at a distance (as calculated using the appropriate
formula in Appendix C of 40 CFR 112.20 or an alternative formula1 considered
acceptable by the RA) such that the discharge from the facility would shut down a public
drinking water intake?

Yes No X

SPCC Plan – Appendix A


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Georgia State University

Does the facility have a total oil storage capacity greater than or equal to 1 million
gallons and has the facility experienced a reportable oil spill in an amount greater than or
equal to 10,000 gallons within the last 5 years?

Yes No X

Certification:

"I certify under penalty of law that I have personally examined and am
familiar with the information submitted above, and that based on my
inquiry of those individuals responsible for obtaining information, I
believe that the submitted information is true, accurate, and complete."

Name (Type or Print) Title

Signature Date

SPCC Plan – Appendix A


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SPCC Plan
Georgia State University

FIVE-YEAR SPCC PLAN REVIEW AND EVALUATION


[40 CFR 112.5]

In accordance with 40 CFR Part 112.5(b), a review and evaluation of this SPCC Plan is
conducted by Georgia State University at least once every five years. As a result of this
review and evaluation, Georgia State University will amend the SPCC Plan within six
months of the review to include more effective prevention and control technology if: (1) such
technology will significantly reduce the likelihood of a discharge of oil in quantities that may
be harmful, as described in 40 CFR Part 110, into or upon the navigable waters of the United
States or adjoining shorelines; and if (2) such technology has been field proven at the time of
review. Any technical amendment(s) to the SPCC Plan will be reviewed and certified by a
Licensed Professional Engineer within six months after a change in the facility design,
construction, operation, or maintenance occurs which materially affects the facility’s
potential for the discharge of oil in quantities that may be harmful, as described in 40 CFR
Part 10, into or upon navigable waters of the United States or adjoining shorelines.
As such, Georgia State University has completed a full review of this SPCC Plan, as herein
described. The following result of the review is noted (check one):
[ ] Major changes to the Georgia State University campus have occurred since
the last review, therefore the SPCC Plan must be appropriately updated and
re-certified by a Licensed Professional Engineer.
[ ] The SPCC Plan for the Georgia State University campus was reviewed on the
date specified below and no amendment to the SPCC Plan is necessary per 40
CFR Part 112.5(b).
[ ] The SPCC Plan for the Georgia State University campus was reviewed on the
date specified below and the SPCC Plan has been amended to include more
effective prevention and control technology.
[ ] Minor administrative (non-technical) changes to the Georgia State University
campus have occurred since the last review, and the SPCC Plan has been
appropriately updated.

Reviewed On: __________________________________________

Reviewer’s Signature: __________________________________________

Reviewer’s Name: __________________________________________


(Copies of this page should be made for subsequent reviews, and all completed pages must be signed and appended to
the SPCC Plan. If the Plan is amended based on the above review, a copy of the previous version of this page should
be made and the Licensed Professional Engineer’s Certification of the amendment must be completed and maintained
with the SPCC Plan.)

SPCC Plan – Appendix A


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Georgia State University

FACILITY MANAGEMENT APPROVAL

[40 CFR 112.7]

Georgia State University (GSU) is committed to the prevention of discharges of oil to navigable
waters and the environment, and to maintaining the highest standards for spill prevention control
and countermeasures through the implementation and regular review and amendment to the Spill
Prevention Control and Countermeasure (SPCC) Plan. GSU has committed the necessary
resources to implement the measures described in this Plan. The GSU Senior Environmental
Program Officer is the designated person accountable for oil and chemical spill prevention at the
facility and has the authority to commit the necessary resources to implement this Plan.
Furthermore, GSU pledges to commit the necessary resources as may be required to protect the
public health, safety, and the environment.

This SPCC Plan is prepared in accordance with good engineering practices and has the full
approval and support of GSU management. Furthermore, GSU pledges to commit the necessary
resources as may be required to protect the public health, safety and the environment. The SPCC
has the full approval of GSU management.

Authorized Facility Representative Name:

______________________________

Authorized Facility Representative Signature:

______________________________

Authorized Facility Representative Title:

______________________________

Date:
______________________________

SPCC Plan – Appendix A


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Georgia State University

LICENSED PROFESSIONAL ENGINEER CERTIFICATION

[40 CFR 112.3(d)]


I hereby attest and certify that (i) I am familiar with the requirements of Part 112 of Title 40 of
the Code of Federal Regulations (40 CFR Part 112) and I, or my agent, have visited and
examined the facility; (iii) this SPCC Plan for the Georgia State University facility located in
Atlanta, Georgia has been prepared in accordance with good engineering practices, including
consideration of applicable industry standards, and with the requirements of 40 CFR Part 112
procedures for required inspections and testing have been established in this SPCC Plan, and (v)
this SPCC Plan is adequate for the facility.
This certification in no way relieves the owner or operator of the facility of his/her duty to
prepare and fully implement this SPCC Plan in accordance with the requirements of 40 CFR Part
112. Certain information in this SPCC Plan has been provided by Georgia State University. This
Plan is valid only to the extent that the facility owner or operator maintains, tests, and inspects
equipment, containment, and other devices as prescribed in this Plan.
This SPCC Plan has been prepared for the exclusive use of Georgia State University and should
be used only for the purpose for which it was intended. Should the user of this report change, the
certification is no longer valid and the new user must comply with requirements outlined within
40 CFR Part 112.
If conditions at the facility have changed as they were on the date of the field visit, then this Plan
may no longer be applicable and the certification may not be valid unless the plan is updated in
accordance with the regulations. The findings presented are relative to the dates of our site work
and information provided by the facility and should not be relied on to represent conditions at
substantially later dates or under different management or ownership.

Printed Name of Licensed Professional Engineer


(Seal)

Signature of Licensed Professional Engineer

Date

Registration Number

Registration State

SPCC Plan – Appendix A


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Georgia State University

SPCC Plan Review Log

Certification
Date of Action: Action Conducted By: Action: Comments
by PE:

SPCC Plan – Appendix A


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SPCC Plan
Georgia State University

APPENDIX B
Cross Reference

SPCC Plan – Appendix B


Georgia State University
SPCC Plan
Georgia State University

SPCC Rule Cross-Reference

40 CFR Part 112 Section Description SPCC Plan Section

112.1(a) - (e) applicability Section 1


112.3(b) plan must be implemented before operation begins Section 1
112.3(d) plan is certified by professional engineer Appendix A Or N/A
112.3(e) copy of plan maintained at facility Section 1
112.4 amendment of plan by regional administrator Section 16
112.5(a) amendment of plan for changes in design Section 1
112.5(b) five-year plan review Section 1 and Appendix A
112.5(c) professional engineer certification of amendments Appendix A or N/A
112.7(a)(1) discuss facility's conformance with Part 112 Section 1 and Appendix B
112.7(a)(2) cross reference of Part 112 and SPCC plan Appendix B
112.7(a)(3) facility layout and diagram Section 3 and Figure 1-4
112.7(a)(3)(i) type of oil stored and capacity of containers Sections 4
112.7(a)(3)(ii) discharge prevention measures for unloading Section 10
112.7(a)(3)(iii) discharge controls - secondary containment Section 5
112.7(a)(3)(iv) countermeasures - response and cleanup Appendix G
112.7(a)(3)(v) methods of disposal of recovered material Section 13
112.7(a)(3)(vi) contact list Sections 2, 14 and Appendix G
112.7(a)(4) procedure for reporting a discharge Section 13
112.7(a)(5) discharge response procedure Section 13 and Appendix G
112.7(b) prediction of discharge flow and volume Section 8
112.7(c) provide appropriate containment Section 5
112.7(d) if no containment, need oil spill contingency plan N/A
112.7(e) inspections, tests, records Section 11
112.7(f) personnel training requirements Section 8
112.7(g) security requirements Section 12
112.7(h) tank truck unloading rack Section 10
112.7(i) evaluate containers after repair Section 11
112.7(j) discuss state discharge prevention regulations Section 13
112.8(b) facility drainage Section 6
112.8(c) bulk storage containers Sections 3, 4 and 5
112.8(d) facility transfer operations Section 10

SPCC Plan – Appendix B


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Georgia State University

APPENDIX C
Oil Material Safety Data Sheets

SPCC Plan – Appendix C


Georgia State University
SPCC Plan
Georgia State University

APPENDIX D
Annual SPCC Training Outline and Log Sheet

SPCC Plan – Appendix D


Georgia State University
SPCC Plan
Georgia State University

ANNUAL SPCC TRAINING OUTLINE AND PARTICIPANT RECORD

1. REVIEW OF SPCC RULES AND PURPOSE

2. REVIEW OF SPCC PLAN


 Storage and Containment System
 Loading/Unloading Procedures
 Potential Sources of Spills or Leaks

3. PLAN MODIFICATIONS
 Have storage or equipment changes taken place?
 Do they represent new or different spill or response potentials?
 Are there improvements which can be recommended for the plan or prevention
activities?

4. DISCUSSION OF PLAN IMPLEMENTATION


 Review of Spill Prevention Activities
 Review of Routine Inspection Forms and Procedures
 Review of Spill Response Equipment Inventories and Locations
 Review of Responsibilities and Notification Procedures
 Past Spills and Lessons Learned

Training Date: __________________

Signature Printed Name


Training Presented By:
Attendees:

SPCC Plan – Appendix D


Georgia State University Appendix D Page 1 of 1
SPCC Plan
Georgia State University

APPENDIX E
Oil Transfer Forms:

Fuel Delivery Unloading Checklist


Oil Drum Delivery Checklist

SPCC Plan – Appendix E


Georgia State University
SPCC Plan
Georgia State University

Fuel Delivery Unloading Checklist

Date: _____________________ Time: _____________

GSU Supervisor: ____________________

Truck Driver: ________________________ Delivery Company: ___________________

ACTIVITY VERIFIED
Activities prior to delivery:
Truck is parked at unloading station
Truck chocks are set behind wheel
Verify that the proper Fuel is to be delivered
Verify tank has capacity to receive quantity of fuel to be delivered
All valves, hoses, pipes and connections are in good condition
Post-delivery activities
Cap Terminal Connection
Verify no oil has spilled during transfer
Wheel chocks are removed

SPCC Plan – Appendix E


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Georgia State University

Oil Drum Delivery Checklist

Date: _____________________ Time: _____________

GSU Supervisor: ____________________

Truck Driver: ________________________ Delivery Company: ___________________

ACTIVITY VERIFIED
Verify materials in drums against manifest
Confirm that MSDS sheets for the materials are on file at the
facility
Verify that sufficient space exists within drum storage secondary
containment area for the new delivery

SPCC Plan – Appendix E


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Georgia State University

APPENDIX F
Inspection Forms:
Monthly SPCC Inspection Form
Annual SPCC Inspection Form
Inspection and Drainage Form for Secondary Containment
Areas

SPCC Plan – Appendix F


Georgia State University
SPCC Plan
Georgia State University

Monthly SPCC Inspection Form


If any deficiencies are found, please attach a description and remediation actions taken.
Any leaks, missing
caps, leaking or
damaged piping,
Generator damaged tank or Date of Name of
No. Location structure? Inspection Inspector
EG1 G Deck, Mechanical Room, opposite motorcycle bay
EG2 30 Pryor, Basement Parking Deck
EG3 Natural Sciences Center, Day Tank
EG4 35 Broad Street. Top floor mechanical room
EG4 35 Broad Street. Top floor mechanical room. Drums.
EG5 Urban Life, Parking Lot B
EG6 Standard Building, Basement (Note 1)
EG7 Haas Howell, Basement (Note 1)
EG8 Art and Humanities. Outside next to entrance
EG9 GCB, L-Lot Parking Lot (Note 1)
EG14 Student Center Loading Dock (Grease Container) (Note 1)
EG14 Student Center Loading Dock Mechanical Room 170 (Note 1)
EG19 Aderhold. Room 014A (Note 1)
EG20 Rec Center. Outside at back (Note 1)
EG22 Piedmont-Ellis Student Housing. (Note 1)
EG25 75 Piedmont
Note 1: Inspect interstitial space for presence of any liquid

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Annual SPCC Inspection Form

This inspection record must be completed each year. If any response requires further
elaboration, provide comments in Description & Comments space provided. Further
description and comments, if necessary, must be provided on a separate sheet of paper and
attached to this sheet. *Any item that receives “yes” as an answer must be described and
addressed immediately.

Y* N Description & Comments


Storage tanks
EG1 - G Deck, Mechanical Room, opposite
motorcycle bay
Tank surfaces show signs of leakage
Tank is damaged, rusted or deteriorated
Bolts, rivets or seams are damaged
Tank supports are deteriorated or buckled
Tank foundations have eroded or settled
Level gauges or alarms are inoperative
Vents are obstructed
EG2 - 30 Pryor, Basement Parking Deck
Tank surfaces show signs of leakage
Tank is damaged, rusted, or deteriorated
Bolts, rivets, or seams are damaged
Tank supports are deteriorated or buckled
Tank foundations have eroded or settled
Level gauges or alarms are inoperative
Vents are obstructed
EG3 - Natural Sciences Center, Day Tank
Tank surfaces show signs of leakage
Tank is damaged, rusted, or deteriorated
Bolts, rivets, or seams are damaged
Tank supports are deteriorated or buckled
Tank foundations have eroded or settled
Level gauges or alarms are inoperative
Vents are obstructed

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EG4 - 35 Broad Street. Top floor mechanical


room
Tank surfaces show signs of leakage
Tank is damaged, rusted or deteriorated
Bolts, rivets or seams are damaged
Tank supports are deteriorated or buckled
Tank foundations have eroded or settled
Level gauges or alarms are inoperative
Vents are obstructed
EG5 - Urban Life, Parking Lot B
Tank surfaces show signs of leakage
Tank is damaged, rusted, or deteriorated
Bolts, rivets, or seams are damaged
Tank supports are deteriorated or buckled
Tank foundations have eroded or settled
Level gauges or alarms are inoperative
Vents are obstructed
EG6 - Standard Building, Basement (Note 1)
Tank surfaces show signs of leakage
Tank is damaged, rusted, or deteriorated
Bolts, rivets, or seams are damaged
Tank supports are deteriorated or buckled
Tank foundations have eroded or settled
Level gauges or alarms are inoperative
Vents are obstructed
EG7 - Haas Howell, Basement (Note 1)
Tank surfaces show signs of leakage
Tank is damaged, rusted or deteriorated
Bolts, rivets or seams are damaged
Tank supports are deteriorated or buckled
Tank foundations have eroded or settled
Level gauges or alarms are inoperative
Vents are obstructed

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EG8 - Art and Humanities. Outside next to


entrance
Tank surfaces show signs of leakage
Tank is damaged, rusted, or deteriorated
Bolts, rivets, or seams are damaged
Tank supports are deteriorated or buckled
Tank foundations have eroded or settled
Level gauges or alarms are inoperative
Vents are obstructed
EG9 - GCB, L-Lot Parking Lot (Note 1)
Tank surfaces show signs of leakage
Tank is damaged, rusted, or deteriorated
Bolts, rivets, or seams are damaged
Tank supports are deteriorated or buckled
Tank foundations have eroded or settled
Level gauges or alarms are inoperative
Vents are obstructed
EG14 - Student Center Loading Dock (Grease
Container) (Note 1)
Tank surfaces show signs of leakage
Tank is damaged, rusted or deteriorated
Bolts, rivets or seams are damaged
Tank supports are deteriorated or buckled
Tank foundations have eroded or settled
Level gauges or alarms are inoperative
Vents are obstructed
EG14 - Student Center Loading Dock
Mechanical Room 170 (Note 1)
Tank surfaces show signs of leakage
Tank is damaged, rusted, or deteriorated
Bolts, rivets, or seams are damaged
Tank supports are deteriorated or buckled
Tank foundations have eroded or settled
Level gauges or alarms are inoperative
Vents are obstructed

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EG19 - Aderhold. Room 014A (Note 1)


Tank surfaces show signs of leakage
Tank is damaged, rusted, or deteriorated
Bolts, rivets, or seams are damaged
Tank supports are deteriorated or buckled
Tank foundations have eroded or settled
Level gauges or alarms are inoperative
Vents are obstructed
EG20 - Rec Center. Outside at back (Note 1)
Tank surfaces show signs of leakage
Tank is damaged, rusted, or deteriorated
Bolts, rivets, or seams are damaged
Tank supports are deteriorated or buckled
Tank foundations have eroded or settled
Level gauges or alarms are inoperative
Vents are obstructed
EG22 - Piedmont-Ellis Student Housing.
(Note 1)
Tank surfaces show signs of leakage
Tank is damaged, rusted or deteriorated
Bolts, rivets or seams are damaged
Tank supports are deteriorated or buckled
Tank foundations have eroded or settled
Level gauges or alarms are inoperative
Vents are obstructed
EG25 - 75 Piedmont
Tank surfaces show signs of leakage
Tank is damaged, rusted, or deteriorated
Bolts, rivets, or seams are damaged
Tank supports are deteriorated or buckled
Tank foundations have eroded or settled
Level gauges or alarms are inoperative
Vents are obstructed

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Piping
Valve seals or gaskets are leaking
Pipelines or supports are damaged or
deteriorated
Joints, valves and other appurtenances are
leaking
Buried piping is exposed
Out-of-service pipes are not capped
Warning signs are missing or damaged
Loading/unloading and transfer equipment
Loading/unloading rack is damaged or
deteriorated
Connections are not capped or blank-flanged
Drip pans have accumulated oil or are leaking
Security
Fencing, gates, or lighting is non-functional
Pumps and valves are not locked (and not in
use)
Response equipment
Response equipment inventory is incomplete
Note 1: Inspect interstitial space for presence of any liquid

Annual reminders:
 Hold SPCC Briefing for all oil-handling personnel (and update briefing log in the Plan);
 Check contact information for key employees and response/cleanup contractors and update them
in the Plan as needed;

COMMENTS____________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________

Date________________ Signature _______________________

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Inspection and Drainage Form For Secondary Containment Areas

This form is completed each time a containment dike is inspected and/or drained
of rainwater.

Date Tank Location -Time of Day - -Time of Day - Employee verifies that there was no
oil sheen on the water in the dike at
Valve is Opened Valve is Closed the time the water was drained.

(Employee Signature below)

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APPENDIX G
Emergency Procedures and Forms:

Emergency Contact List


Spill Response Procedures
GSU’s Incident Report

SPCC Plan – Appendix G


Georgia State University
SPCC Plan
Georgia State University

EMERGENCY CONTACT LIST

Contact Name Address Telephone


Michael Thompson, Senior Environmental 404-413-3551 (Office)
Program Officer, Georgia State University 404-886-4289 (Cell)
Paul Hysell Office: 404-413-3515
Atlanta Fulton County Emergency 130 Peachtree Street SW 404-730-5600
Management Agency (AFCEMA)
Suite G-157
Atlanta, Georgia 30303
Atlanta Bureau of Wastewater Treatment 55 Trinity Avenue SW 404-330-6190
and Collection
Atlanta, Georgia 30303
Georgia Dept. of Natural Resources -
Environmental Protection Division
404-656-4300
State Operations Center (Atlanta Area – 24-
Hr Emergency Operations)
7 Martin Luther King Jr. Dr. 404-656-6905 (office)
Al Frazier , Manager, Emergency Response
Team and Risk Management Program Room 643
404-657-7893 (Fax)
Atlanta, GA 30334
National Response Center 800-424-8802

U.S. Environmental Protection Agency (US 404-562-9055


EPA) (24-Hr Call Center)
Georgia Power Company (Electrical Power) 888-655-5888
Atlanta Fire Department 911
404-413-2100
Georgia State University Police Department
3-3333 (GSU Campus)
Atlanta Police Department 911
DeKalb County Police Department 911
(Language Research Center emergencies
only)
DeKalb County Fire Department 911
(Language Research Center emergencies
only)

SPCC Plan – Appendix G


Georgia State University
SPCC Plan
Georgia State University

SPILL RESPONSE PLAN

In the event of a spill or release, the emergency procedures to be followed are outlined below. A
copy of the emergency procedures should be kept in or near all oil storage areas.

The following measures should be implemented upon the discovery of a spill or release:

 Assess the risk


 Notify facility personnel of the release
 Control the release to the extent possible
 Clean up the impact area as soon as possible
 Report the release to the applicable agencies
 Follow up with preventive measures.

(1) Assess the Risk

The risks presented by a release should be assessed the moment the release is observed or
discovered. A major release may require response by outside services equipped to handle
oil releases. All available resources should be assessed for use in stopping the spill or
release.

Procedures for the emergency evacuation of the facility are in place and review of each
department's evacuation route and outside assembly points are covered during new
employee orientation and during monthly safety meetings. Evacuation route maps are
posted at key locations throughout the facility. The decision to evacuate is made by the
senior manager on-site at any time for any type of emergency.

(2) Notifications to Facility Personnel and Containment

 Any employee noticing a release of petroleum will immediately notify the Senior
Environmental Program Officer, Michael Thompson, who serves as the
Emergency Coordinator, by dialing:

Office: 404-413-3551
24-hour: 404-886-4289 (Cell)

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The Emergency Coordinator will collect the following information (see Initial Spill
Information Form included as Appendix I), if possible:

1) What material was spilled?


2) Is a fire involved?
3) Extent of injuries, if any?
4) Where was the material spilled?
5) Is the spill contained or on what surface (grass, concrete, asphalt, etc.)
did the spill occur?
6) What is the approximate surface area (sq. ft.) of the spilled material?
7) Is the spilled material flowing off-site?
8) How much material was spilled?
9) What time was the spill discovered?

The person discovering the release will utilize the emergency contact list provided in the
SPCC plan to provide proper notifications. If the Emergency Coordinator is not
available, then proceed down the list of GSU contacts until an alternate is contacted.
Once contacted, the Emergency Coordinator will forward the spill information along with
the Initial Spill Information Form to the Alternates and/or other involved parties.

The Emergency Coordinator or Alternate will then determine the action which
will be taken in accordance with the Spill Response Procedures outlined in Section 14.

While awaiting arrival of the Emergency Coordinator or his designee, Facility personnel
shall commence containment activities immediately, using all available trained
manpower and materials on-hand. It should be noted that Facility personnel will not
assist in the cleanup of hazardous materials spills, only in the containment of the spill
itself. These procedures are discussed in the following section of this Appendix.

In the event that the spill is beyond the means of available manpower and materials on-
hand or presents a risk to facility personnel, the Emergency Coordinator will contact the
nearest available clean-up contractor. Several contacts are listed below:

SPILL CONTACT ADDRESS PHONE


Hulls Environmental 29 Southern Court Office: 580-668-3456
Hiram, GA 30141 Fax: 580-668-3460
24 Hour Emergency
Response: 866-450-9077
EP&S of Vermont, 4625 Stonegate Industrial Blvd. EP&S of Vermont, Inc.
Inc.

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The Emergency Coordinator or his designee will oversee the spill clean-up. In addition,
the Emergency Coordinator will ensure that the following information is provided to
document spill clean-up operations:

 Material released;
 Amount of material released;
 Location of release;
 Date and time release discovered;
 Name of personnel and outside contractors, if appropriate, that responded
to release;
 Actions taken to contain, clean-up and remove spilled material;
 Location and type of samples (i.e. soil, groundwater, etc.) collected,
laboratory analysis and results;
 Additional actions required, if any; and
 Department and agency notified, if any.

It is noted that if a spill occurs from a Georgia Power-owned transformer at GSU,


Georgia Power will respond using their own controls and countermeasures. GSU
personnel are not trained to respond to emergencies related to the transformers and, due
to the safety concerns associated with response, Georgia Power takes complete
responsibility for discharges from its transformers. In the event of a release from a
Georgia Power transformer, the Emergency Coordinator or his designee should contact
Georgia Power. The following Georgia Power reporting number is used for transformer
leaks or for any power outage or equipment failure: 1-888-891-0938.

(3) Control and Cleanup of the Release

Every effort should be made to confine a spill to the immediate area and keep the spill
from discharging off site. Facility personnel should immediately commit all necessary
manpower, equipment and materials required to prevent the spill from reaching catch
basins or waterways.

Methods that can be used for controlling spills include:

Absorption – Use absorbent granular material to absorb oil.


Covering – Spill areas can be covered with appropriate materials, such as plastic
sheets, until cleanup efforts can be completed.
Booms/Dikes – These temporary physical barriers can be used to retain spills,
change the direction of flow of the liquid, or minimize storm water run-on to the
impacted area
Plugs/Patches – Compatible plugs and patches can temporarily stop the flow of
oil through small holes.

If the spill is small enough to be absorbed, neutralized or otherwise controlled at the time
of release by employees in the immediate release area or by maintenance personnel, and
does not pose an adverse exposure hazard to employees, then the spill will be handled in
the following manner:

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a. Make sure all unnecessary persons are removed from the hazard area.
Have workers involved in clean-up put on protective clothing and equip-
ment.

b. If flammable waste is involved, remove all ignition sources, and use


spark and explosion proof equipment and clothing in containment and
clean up.

c. If possible, try to stop the leak.

d. Remove all surrounding materials that could be especially reactive with


the materials in the waste. Determine the major components in the waste
at the time of the spill.

e. Use absorbent pads, booms, earth, sandbags, sand, and other inert
materials to contain, divert, neutralize and clean up a spill if a dike or
sump has not contained it. Most spills contained within a dike or sump
can be pumped back into the appropriate storage tank or drum.
Absorbent materials should be placed in direct contact with the oil,
working inward from the farthest point of progression of the spill. The
quicker the response, the smaller the affected area will be.

f. If oil begins to spread outside of the immediate area, attempts should be


made to stop the flow before it enters a catch basin or waterway. A
portable catch basin cover or, as an alternative, sheets of plastic weighed
down, should be placed over all nearby catch basin grating. In the event
that oil enters the catch basin, absorbent materials should be used at the
discharge.

g. Procedure to follow for leaking drum:

1. Move drum into or construct containment area;


2. Roll drum or stand up on end away from leak;
3. Drain contents (transfer to clean drum);
4. Label drum accordingly;
5. Absorb spillage or leakage with absorbent;
6. Transfer absorbent waste to drum, label accordingly; and
7. Store until final disposal.

g. If waste reaches a storm sewer, try to stop flow from the source by using
sand, earth, sandbags, etc. If this is done, pump this material out into a
temporary holding tank or drum as soon as possible.

h. Place all containment and clean-up materials in drums for proper


disposal. Some items, such as absorbent rags or booms, may have to be
cut.

i. Place all recovered liquid wastes in drums for removal to an approved


disposal site.

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Facility personnel will not assist in handling hazardous materials spills unless it is a
minor spill which presents no risk to facility personnel and can be cleaned up easily using
absorbent materials (as noted above).

For a spill that requires a commercial clean-up firm for oil containment and cleanup
services, the Emergency Spill Response Contractor will perform all cleanup activities.
Arrangements shall be made for the proper disposal of spill materials. Contaminated
materials shall be removed as soon as possible and placed into proper containers. All
equipment and manpower shall be utilized to remove spilled materials promptly and in a
safe manner.

(4) Report the Release

Immediately after initiating appropriate response measures to confine the spill,


designated facility personnel should report an oil release to the appropriate government
agencies, if required. Immediately means as soon as a person is available to call without
further endangering the environment, but in no event longer than two hours after the
release. Spills will be reported ONLY by the Emergency Coordinator or his designee.

A spill of an oil product which reaches the waters of the state (including streams, rivers,
storm sewers, and drainage ditches) and causes a sheen must be reported to the Georgia
EPD 24-hour State Emergency Operations Center at 404-656-4300 and the National
Response Center.

When making an EPD notification, the following information should be provided:

 The name of the substance involved in the spill/release


 An estimate of the quantity spilled
 The time and duration of the release
 The source of the release
 The medium into which the release occurred (waterway or soil)
 Actions taken in response to the spill
 The name and telephone number of the person to be contacted for further
information

Federal regulations at 40 CFR Part 110.3 define a spill as the discharge of oil into, or
upon the navigable waters of the United States or adjoining shoreline in harmful
quantities. Harmful quantities are defined as a discharge that violates applicable water
quality standards or causes a sheen upon, or discoloration of, the surface water or
adjoining shoreline.

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In the event that such a discharge of oil occurs, the facility’s designated employee
accountable for oil spill prevention (Section 2.2 above), or his/her designee, is to be
notified immediately. The Emergency Coordinator, or his/her designee, will then
immediately notify the National Response Center (NRC) at 1-800-424-8802. 40 CFR part
110.6 will be further consulted for appropriate notification procedures in the event that
direct reporting to the NRC is not practicable.

NRC will ask a caller to provide as much information about the incident as possible
including:

When making a NRC notification, the following information should be provided:

 Name, organization, and telephone number


 Name and address of the party responsible for the incident
 Date and time of the incident
 Location of the incident
 Source and cause of the discharge
 Types of material(s) discharged
 Quantity of materials discharged
 Danger or threat posed by the discharge
 Number and types of injuries (if any)
 Weather conditions at the incident location
 Other information to help emergency personnel respond to the incident

(5) Preventive Measures

Facility personnel shall review the cause of the oil spill or release and initiate corrective
actions to prevent similar occurrences. Additionally, all spill response materials, such as
absorbents and booms, should be restocked. The facility should also prepare any written
follow-up reports required by government agencies. These reports are described in
Section 14.0 of the SPCC Plan.

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FORM 9.1
INCIDENT INFORMATION FORM
(A) Reporting Party (B) Suspected Responsible Party
Name: Name:
Phone 1: ( ) _____ _____ Phone 1: ( )
Company: Company:
Organization Type: Organization Type:
Address: Address:
City: City:
State: State:
Zip Code: Zip Code:

Person Discovering Discharge


Name: Company/Org:
Incident Description
Description of Incident and Cause:

Incident Date: Time: Occurred ( ) Discovered ( )


Material Involved
Material Amount Released Unit of Measure Amount in Water

1.
2.

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Impact
Fire ?: (Y) (N) (Unknown) Fire Extinguished ?: (Y) (N) (Unknown)
Injuries ?: (Y) (N) (Unknown) Number of Injuries:
Fatalities ?: (Y) (N) (Unknown ) Number of Fatalities:
Evacuations ?: (Y) (N) (Unknown) Number of Evacuations:
Damages ?: (Y) (N) (Unknown) Damages in Dollars:
Road Closed ?: (Y) (N) (Unknown) Road:

Weather Information
Weather Conditions: Air Temp: Wind Speed: Wind Direction:

Description of Containment Actions


Description of Containment and Clean-up operations

Procedures to Prevent Recurrence


Procedures, methods and precautions instituted to prevent recurrence

Incident report submitted by:____________________________________

Date of incident report:________________________________________

SPCC Plan – Appendix G


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