Environmental Consulting & Contracting · 2019-12-06 · Environmental Consulting & Contracting...

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Environmental Consulting & Contracting

April 19, 2019 File No. 25217182.00 Mr. Chuck Hermes Director of Operations and Maintenance Facilities University of Wisconsin-Oshkosh 800 Algoma Boulevard Oshkosh, WI 54901

Subject: Spill Prevention, Control, and Countermeasure Plan University of Wisconsin-Oshkosh 800 Algoma Boulevard, Oshkosh, Wisconsin 54901

Dear Mr. Hermes:

SCS Engineers (SCS) prepared the attached Spill Prevention, Control, and Countermeasure (SPCC) Plan update for the University of Wisconsin-Oshkosh. SCS conducted an on-site review on June 20, 2018, and completed the required 5-year review of the University of Wisconsin-Oshkosh SPCC Plan. The next 5-year review is due in June 2023.

SCS amended the SPCC Plan to incorporate the following changes:

• Updates to oil storage summary

– Modification/Addition of drum storage areas D1 through D5

– Addition of grease trap at the Welcome Center

– Addition of used cooking oil tank (AST8)

– Addition of diesel fuel generators AST7 and AST9

• Updated contacts throughout the SPCC Plan

• Changed minor administrative items to be consistent with current SPCC rule interpretation and related guidance documents

• Modified monthly and annual inspection forms (Attachments B and C) to be consistent with current industry guidance (STI SP 001-18)

• Revised Cross-Reference with the SPCC Rule (Attachment A)

PROFESSIONAL ENGINEER CERTIFICATION OF THIS SPCC PLAN RENEWAL This SPCC Plan has been re-certified by a Professional Engineer licensed in Wisconsin.

Mr. Chuck Hermes April 19, 2019

SPCC Plan Requirements 1. Issue identified: Insufficient secondary

containment for the 55-gallon drum (D2) storing SPCC-regulated oils in the Auto Shop.

Recommended corrective action: Provide passive secondary containment for the drum. Place appropriately sized 1-drum or 2-drum secondary containment pallet beneath the drum storage in this room with a minimum capacity of 60.5 gallons.

2. Issue identified: Insufficient secondary containment for the 55-gallon drums (D4) storing SPCC-regulated oils in the Grounds Facility Building.

Recommended corrective action: Provide passive secondary containment for the drums. Place appropriately sized 2-drum or 4-drum secondary containment pallet beneath the drum storage at this location with a minimum capacity of 60.5 gallons each.

3. Issue identified: Insufficient secondary containment for the 55-gallon drum (D2) storing SPCC-regulated oils in the Auto Shop.

Recommended corrective action: Provide passive secondary containment for the drum. Place appropriately sized 1-drum or 2-drum secondary containment pallet beneath the drum storage in this room with a minimum capacity of 66 gallons.


SPCC Plan Recommendation 1. Issue identified: Insufficient general

secondary containment (for fuel/oil transfers) in close proximity to a storm sewer at these locations:

• 520-gallon diesel fuel tank outside

Dempsey Hall (AST2)

• 275-gallon used cooking oil and grease tank at the Service Building (AST8)

• 319-gallon diesel fuel tank outside Fletcher Hall (AST9)

• Near fuel dispensers at the back of the Campus Service Center

Recommended corrective action: Purchase, store, and place storm drain covers over the storm sewer inlet drains located within 50 feet of these oil sources during fuel/oil transfers by mobile tankers to re-fill these tanks. Provide/post instructions on process for covering drains by delivery drivers or campus staff.

IMPLEMENTATION STEPS FOR SPCC • Post the Notice to Petroleum Product Vendors. Post the notice (attached and laminated

or metal signage) near the higher use or risk tanks serving the campus. Post this notice such that it is visible for vendors coming to the facility to re-fill/empty these tanks/containers. Suggested locations include:

– AST4 – 185-gallon diesel fuel tank (Gruenhagen Conference Center) – AST7 – 300-gallon diesel fuel tank (Clow Hall) – AST8 – 275-gallon used cooking oil and grease (Reeve Memorial Union) – AST9 – 319-gallon diesel fuel tank (Fletcher Hall) – Campus Service Center (Near fuel dispensers)

• Post the Spill Response Flow Chart. Post the flow chart (attached and laminated) in suitable locations near oil sources on campus to give your staff a visual aid to respond to spills properly (Attachment I)

– AST2 – 520-gallon diesel fuel tank (Dempsey Hall) – AST4 – 185-gallon diesel fuel tank (Gruenhagen Conference Center)


– AST7 – 300-gallon diesel fuel tank (Clow Hall) – AST8 – 275-gallon used cooking oil and grease (Reeve Memorial Union) – AST9 – 319-gallon diesel fuel tank (Fletcher Hall) – Campus Auto Shop (D1 and D2 oil storage) – Campus Service Center (Near Dispensers)

ONGOING SPCC ITEMS

1. Monthly and Annual Inspections. Conduct routine inspections of on-site oil sources. You can find the Monthly and Annual Inspection Checklists in Attachments B and C.

2. Complete the Fuel/Oil Transfer Checklist. Complete this Best Management Practice (BMP) for fuel/oil deliveries. You can find the Fuel/Oil Transfer Checklist in Attachment F.

3. Annual SPCC Training. UW-System EH&S staff provides materials and guidance to satisfy the training requirement. The Campus Emergency Coordinator will lead an annual training session for oil-handling personnel at this facility.

4. Conduct an Annual SPCC Plan Review. Complete the form annually to confirm the oil storage at this facility is accurately represented in the SPCC Plan.

5. Record Retention. Retain inspection records for a minimum of 3 years. We recommend that SPCC oil-handling personnel training records also be kept for at least 3 years.

SPILL INCIDENT – QUICK REFERENCE • Take initial response steps per the Spill Response Flow Chart (posted at the facility)

• Complete spill notification per the Spill Response Flow Chart (posted at the facility)

• Complete the Spill Incident Report for each spill event (Attachment H)

• Report spills to the appropriate agencies as described in Sections 3.1 through 3.3

SPCC PLAN AMENDMENTS When changes to the facility with regards to oil storage occur, coordinate with the UW-System Environmental Health Specialist to have an SPCC Plan Amendment completed within 6 months. Examples of changes that may require amendment of the SPCC Plan include, but are not limited to:

• Commissioning or decommissioning containers • Replacement, reconstruction, or movement of containers • Reconstruction, replacement, or installation of piping systems • Construction or demolition that might alter secondary containment structures • Changes of product or service • Revision of standard operation or maintenance procedures at a facility


If you have any questions or comments on the SPCC Plan, please call us at (608) 224-2830.

Sincerely,

Tony Kriel, PE Christopher J. Jimieson, PE Professional Engineer Project Manager SCS Engineers SCS Engineers

TRK/AJR/CJJ/EJN

cc: Mr. Marisa Trapp, UW-System (via email only) Ms. Sally Schumaker, Department of Administration (via email only)

Encl. SPCC Plan I:\25217182.00\Deliverables\UW-Oshkosh\190419_UW-Oshkosh_SPCC Plan_FINAL.docx

Spill Prevention, Control, and Countermeasure Plan University of Wisconsin-Oshkosh 800 Algoma Boulevard Oshkosh, Wisconsin 54901

2830 Dairy Drive Madison, WI 53718

608-224-2830

25217182.00 | April 19, 2019

Section Page

SPCC Plan – University of Wisconsin-Oshkosh, Oshkosh, Wisconsin www.scsengineers.com Page i

Table of Contents

Management Approval and Commitment of Resources .......................................................................... iii SPCC Plan Certification ................................................................................................................................ v Certification of the Applicability of the Substantial Harm Criteria ........................................................... vii

Introduction ........................................................................................................................................ 1 1.0 Applicability ............................................................................................................................... 1 1.1 Key Facility Information ............................................................................................................ 2 1.2

Roles and Responsibilities ................................................................................................................ 9 2.0University of Wisconsin-Oshkosh Emergency Coordinators Responsibilities ....................... 9

UW-System Environmental Health Specialist Responsibilities ........................................... 10

Spill Response ................................................................................................................................. 11 3.0 Verbal Oil Spill Notification Requirements ........................................................................... 12 3.1 USEPA Written Spill Notification Requirements .................................................................. 13 3.2 Spill Response Materials and Waste Disposal .................................................................... 13 3.3

Spill Prevention and controls .......................................................................................................... 14 4.0 Potential Oil Spill Sources ..................................................................................................... 14 4.1 General Spill Prevention Measures ...................................................................................... 15 4.2 Secondary Containment ........................................................................................................ 15 4.3

Impracticability Determination ................................................................................ 16 4.3.1 Oil Transfer Activities ............................................................................................................. 17 4.4

Transfer Procedures ................................................................................................. 17 4.4.1 General Secondary Containment in Transfer Areas ............................................... 17 4.4.2 Overfill Protection ..................................................................................................... 18 4.4.3

Inspections and Integrity Testing .......................................................................................... 18 4.5 Periodic Visual Inspections ...................................................................................... 18 4.5.1 Integrity Testing ........................................................................................................ 19 4.5.2

Personnel Training ................................................................................................................. 20 4.6 Security .................................................................................................................................. 21 4.7 Tank Construction Material .................................................................................................. 21 4.8

Conformance With Applicable State Requirements ...................................................................... 21 5.0 Certification Requirements ............................................................................................................. 21 6.0 Records ............................................................................................................................................ 22 7.0

http://www.scsengineers.com/

SPCC Plan – University of Wisconsin-Oshkosh, Oshkosh, Wisconsin www.scsengineers.com Page ii

Table of Contents

Tables

Table 1. Oil Storage Capacity and Plan Details ................................................................................. 5 Table 2. Cross-Reference with Spill Contingency Rules ................................................................. 16

Figures

Figure 1. Site Location Map Figure 2. Facility Site Plan – East Figure 3. Facility Site Plan – West

Attachments

Attachment A Cross-Reference with the SPCC Rule Attachment B Monthly Inspection Checklist Attachment C Annual Inspection Checklist Attachment D SPCC Training Record Attachment E Notice to Petroleum Product Vendors Attachment F Fuel/Oil Transfer Checklist Attachment G Annual SPCC Plan Review Attachment H Spill Incident Report Attachment I Spill Response Flow Chart Attachment J Spill Reporting Compliance Documentation Log Attachment K Oil Spill Disposal Record Attachment L Amendment Log Attachment M Plan Amendment Certification I:\25217182.00\Deliverables\UW-Oshkosh\190419_UW-Oshkosh_SPCC Plan_FINAL.docx


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SPCC Plan – University of Wisconsin-Oshkosh, Oshkosh, Wisconsin www.scsengineers.com Page 1

INTRODUCTION 1.0This document is the Spill Prevention, Control, and Countermeasure (SPCC) Plan for the University of Wisconsin-Oshkosh, a public university in downtown Oshkosh.

APPLICABILITY 1.1The Clean Water Act Oil Pollution Prevention (SPCC) regulation (Code of Federal Regulations, Title 40, Part 112 [40 CFR 112]), as issued by the U.S. Environmental Protection Agency (USEPA), aims to prevent the discharge of oil into or upon the navigable waters or adjoining shorelines of the United States.

A cross-reference checklist identifying how this plan complies with the SPCC regulation is provided in Attachment A.

The SPCC regulation applies to all oil products, 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 • Other oils and greases including petroleum, fuel oil, sludge, synthetic oils, mineral oils, oil

refuse, or oil mixed with wastes other than dredged spoil.

A facility is subject to SPCC regulation if, due to its location, the facility could reasonably be expected to discharge oil in quantities that may be harmful into or upon navigable waters or adjoining shorelines of the United States and the aggregate:

• Aboveground oil storage capacity exceeds 1,320 gallons in containers with volumes of 55 gallons or greater, or

• Underground oil storage capacity of the facility exceeds 42,000 gallons—excluding sources that are currently subject to all technical requirements of 40 CFR 280 or all technical requirements of state programs approved under 40 CFR 281

Because the facility has more than 1,320 gallons of oil (see Table 1 on page 5) in containers with a capacity of 55 gallons or greater (sources), this SPCC Plan was prepared and will be implemented consistent with the current version of 40 CFR 112.

This SPCC Plan is used as a:

• Reference for proper oil storage • Tool for spill prevention • Guide for facility inspections and tank testing • Resource during emergency response to control, contain, and clean up an oil spill



KEY FACILITY INFORMATION 1.21. Name of the Facility: University of Wisconsin-Oshkosh

Facility Address: 800 Algoma Boulevard Oshkosh, Wisconsin (Winnebago County) 54901

Name, direction, and distance to the nearest body of water:

The Fox River borders the west side of the main campus and then flows southeast into Lake Winnebago. Most oil sources on the campus are within ½ mile of the Fox River. A discharge could potentially impact this navigable water, via overland flow or the storm sewer system. The Fox River is a critical use area.

2. Campus Emergency Coordinator: Chuck Hermes, Director of Operations and Maintenance Facilities Work: 920-424-3466 Cell: 920-420-6734

3. Alternate Emergency Coordinator: JoAnn Rife, Director of Planning and Construction Work: 920-424-3466 Cell: 920-420-0172

4. Available Emergency Spill Response Contractors:

Petroleum Response Primary Contractor: North Shore Environmental Construction, Inc. (Germantown, WI) 877-707-6732 Hazardous Materials Response Primary Contractor: North Shore Environmental Construction, Inc. (Germantown, WI) 877-707-6732

5. Location of SPCC Plan: A complete copy of this SPCC Plan is maintained in the University of Wisconsin-Oshkosh Campus Service Center, 800 Algoma Boulevard, Oshkosh, Wisconsin; and is available for on-site review by the USEPA Regional Administrator. This SPCC Plan is not filed with the USEPA.

6. Next Review Due: June 2023

Last Review Completed: June 2018

7. Facility Oil Sources: See Table 1 on the next page.

8. Other Oil Sources at Facility not managed under the SPCC Plan:

Utility-owned transformers servicing the campus facilities are not managed under this SPCC Plan.

9. Spill History: University of Wisconsin-Oshkosh has had no reportable oil spills to date.



10. Underground Oil Storage: University of Wisconsin-Oshkosh has approximately 29,000 gallons of underground storage capacity. According to facility personnel, all underground storage tanks (USTs), aboveground and underground piping, and ancillary equipment at the facility conform to the technical requirements of 40 CFR 280 and are therefore exempt from the requirements of the SPCC program. As required, the location and contents of these tanks are included on the Facility Site Plan-East, Figure 2, and Facility Site Plan-West, Figure 3. In addition, UW-Oshkosh has approximately 22,000 gallons of underground kitchen grease traps. These grease traps are eligible for the wastewater treatment exemption and are not included in the plan as oil sources. However, the transfer of oily wastewater is subject to the general containment requirements of §112.7(c). See the plan for more information.



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Storage Symbol

Oil Source Volume

(gal)Location Container

Construction Contents Transfer ActivitiesDistance and

Direction to Nearest Receptor

Spill Prevention and Leak Detection

Secondary Containment Overfill Protection

Spill Countermeasures

and Response Materials

Security Inspection and Integrity Testing Schedule

Aboveground Storage TanksAST1 660 South basement of

the Halsey Science Center (inside Room 12)

Double-walled steel emergency generator AST

Diesel fuel Direct filling at pipe located outside building by an outside vendor

Inside: Concrete floor in basement.

Outside during tank filing: East to nearby storm sewer inlet on Elmwood Ave.

Spill Prevention: Level gauge, 90% overfill alarm, rupture basin alarm, and prudent practices of oil transfer

Leak Detection: Rupture basin monitoring and visual observation during routine inspections

Double-walled tank Overfill alarm Spill response kits stored adjacent to AST in Halsey Science Center, Room 10B

Inside locked building and outside fill ports are locked

Inspections: Monthly and annual (see Attachments B and C).

Integrity Testing: No required integrity testing.

AST2 520 Outside Dempsey Hall Double-walled steel emergency generator AST

Diesel fuel Direct filling at fill port by an outside vendor

10 feet south to storm sewer, which flows to indoor lift station (lift station could be powered off in spill situation)



Double-walled tank Overfill alarm Spill response kit stored in the mechanical room of Dempsey Hall

Locked panel doors on emergency generator and locked fill port, sufficient lighting



AST3 600 Inside the Heating Plant


Diesel fuel Direct filling at pipe located outside building by an outside vendor

Inside: No nearby receptors (self-contained room)

Outside during tank filing: South/southeast to nearby storm sewer inlet on High Ave.


Leak Detection: Interstitial monitoring and visual observation during routine inspections

Double-walled tank Overfill alarm Spill response kit in the generator room of the Heating Plant

Inside locked building



AST4 185 Outside the Gruenhagen Conference Center & Dorms


Diesel fuel Filled by a tanker truck (third party vendor)

50 feet south to storm sewer inlet

Spill Prevention: Level gauge, rupture basin alarm, and prudent practices of oil transfer


Double-walled tank Level Gauge Spill response kits in Gruenhagen Conference Center Mechanical Rooms




AST5 185 Outside Scott Hall Double-walled steel emergency generator AST


20 feet to curb, then southwest along the east side of Osceola Street to the next storm drain inlet

Spill Prevention: Level gauge, rupture basin alarm, and prudent practices of oil transfer


Double-walled tank Level Gauge Spill response kits in Scott Hall Mechanical Rooms




AST6 183 Outside Sage Hall Double-walled steel emergency generator AST


130 feet to a bio-filter retention pond; Approximately 175 feet southwest to storm sewer curb inlets at intersection of Rockwell Ave. and Pearl Ave.

Spill Prevention: Level gauge, rupture basin alarm, high fuel alarm, and prudent practices of oil transfer


Double-walled tank Overfill alarm Spill response kit adjacent to tank




AST7 300 Outside Clow Hall Double-walled steel emergency generator AST


55 feet southwest to a storm drain inlet

Spill Prevention: Level gauge, rupture basin alarm, high fuel alarm, and prudent practices of oil transfer Leak Detection: Rupture basin monitoring and visual observation during routine inspections





AST8 275 Outside Reeve Memorial Union

Single-walled steel container

Used cooking oil and grease

Manually filled by pouring oil into the top of the AST. Emptied by an third party vendor.

20 feet west to a storm drain inlet

Spill Prevention: Prudent practices of oil transfer

Leak Detection: Impervious surface (concrete pad) beneath container. Routine inspections

None - Facility implementing an impracticability determination. See recommendations in cover letter

Procedure to follow: 1.) Verify container has sufficient free capacity for the transfer; 2.) Visually monitor the product level during transfer

Spill response kit adjacent to tank

Lighting Inspections: Monthly (see Attachment B).

Integrity Testing: External integrity testing every 10-years or documentation of a new container being provided by vendor to service this site at least every 10 years

AST9 319 Outside Fletcher Hall Double-walled steel emergency generator AST

Diesel Fuel Direct filling at fill port by an outside vendor

30 feet east to a storm drain inlet

Spill Prevention: Level gauge, rupture basin alarm, high fuel alarm and prudent practices of oil transfer Leak Detection:Rupture basin monitoring and visual observation during routine inspections.





Miscellaneous Drum StorageD1 55 total Inside of Vehicle

Maintenance Shop (663 3rd Street)

(1) 55-gallon steel drum

Used motor oil

Filled manually (place in D3 when full)

Typically less than 15 feet to floor drain (to sanitary sewer)


Leak Detection: Concrete floor and routine inspections

Portable overpack drum.

Procedure to follow: 1.) Verify container has sufficient free capacity for the transfer; 2.) Visually monitor the product level throughout the transfer operation

Spill response kit in Maintenance Shop


Inspections: Monthly (see Attachment B)

Integrity Testing: No required integrity testing

D2 55 total Inside of Vehicle Maintenance Shop (663 3rd Street)


Motor Oil Manual/hand pumped into smaller containers

35 feet to floor drain (to sanitary sewer)



None-see recommendations in cover letter






D3 330 total Outside of Vehicle Maintenance Shop (663 3rd Street)

(6) 55-gallon steel drums

Used Oil Filled manually when serving as D1 in the Maintenance Shop; drums removed from facility by a third party vendor

Infiltrate in low area immediately to the southeast of this storage area


Leak Detection: Overpack container and routine inspections

Outdoor drum overpack containment units






D4 220 total Inside of Grounds Facility Building

(4) 55-gallon steel drums

Motor Oil Manual/hand pumped into smaller containers

40 feet west to outside storm drain inlet





Spill response kit stored inside of Vehicle Maintenance Shop (663 3rd Street)




D5 55 total Inside of Campus Services Building


Compressor Oil

Manual/hand pumped into smaller containers

15 feet west to floor drain inlet (to sanitary sewer)


Leak Detection: Intersticial monitoring of spill pallet and routine inspections



Spill response kit stored inside this building




Hydraulic Elevator Reservoirs and Lift TanksE1 180 Reeve Memorial

Union, Mechanical Room 30A

Single-walled steel elevator (#27085) reservoir

Hydraulic oil Filled manually Concrete floor with no nearby floor drains

Spill Prevention: Prudent oil transfer practices

Leak Detection: Impervious surface (concrete floor) and routine inspections

Self-contained Room Not applicable (oil-filled equipment)

Spill response kit stored in Mechanical Room (adjacent to elevator reservoir)

Inside locked room of building

Inspections: Elevator periodically inspected by a third party elevator contractor


E2 140 Reeve Memorial Union, Mechanical Room 25










Table 1. Oil Storage Capacity and Plan DetailsUniversity of Wisconsin-Oshkosh

Oshkosh, Wisconsin

SPCC Plan – UW-Oshkosh, Oshkosh, WIPage 5

www.scsengineers.com

Storage Symbol

Oil Source Volume










Oshkosh, Wisconsin

E3 180 Reeve Memorial Union, Mechanical Room 35A










E4 230 Clow Faculty, Mechanical Room 33










E5 200 Reeve Memorial Union, Mechanical Room 01










E6 220 Swart Hall, Mechanical Room 10F










E7 180 Student Success Center, mechanical room 112

Single-walled steel elevator #1266207 reservoir









E8 200 Dempsey Hall, Mechanical Room 02

Single-walled steel elevator #13743 reservoir









E9 100 Blackhawk Commons, Mechanical Room 24










E10 100 Polk Library, Mechanical Room 25










E11 100 Albee Hall and Pool, Mechanical Room 114A

Single-walled elevator (#17324) reservoir









E12 150 Clow Social Science Center, Mechanical Room 304










E13 150 Fredrich March Theatre, Mechanical Room W23

Single-walled steel passenger elevator (#23134) reservoir









E14 200 Fredrich March Theatre, Mechanical Room W97

Single-walled steel stage elevator (#16195) reservoir









E15 100 Harrington, Receiving Room 102










E16 75 Kolf, Mechanical Room 104A










E17 180 N. Polk, Mechanical Room 37










E18 180 S. Polk, Mechanical Room 26










E19 180 Radford, Mechanical Room 211A










E20 120 Blackhawk, Mechanical Room 20G










E21 100 Blackhawk, Mechanical Room 11H










E22 90 Blackhawk, Mechanical Room 11Q










E23 90 Blackhawk, Mechanical Room 11Q












Storage Symbol

Oil Source Volume










Oshkosh, Wisconsin

E24 150 S. Parking Ramp, Mechanical Room 1










E25 80 S. GCC, Mechanical Room 2

Single-walled steel freight elevator (#13144) reservoir









E26 80 N. GCC, Mechanical Room 42










E27 70 S. Scott, Mechanical Room 40










E28 70 N. Scott, Mechanical Room 2










E29 180 Taylor, Mechanical Room 40










E30 280 Titan Stadium, Mechanical Room 180

Single-walled steel press elevator (#1187700) reservoir









E31 125 Titan Stadium, Mechanical Room 154

Single-walled steel coaches' elevator (#1187699) reservoir









E32 90 Arts and Communication, Mechanical Room S16A.

Single-walled steel freight elevator reservoir









E33 70 Lincoln Hall, Mechanical Room 35A

Single-walled steel passenger elevator reservoir









E34 130 Student Recreation and Wellness Center Building, Mechanical Room 136

Single-walled steel elevator reservoir









TOTAL ABOVEGROUND OIL STORAGE (SPCC REGULATED): 8,712 GALLONS

NOTES:1. Campus-owned and maintained transformers are not included in the above ground oil storage aggregate total above. The Campus conducts a thorough in-house inspection and maintenance of all campus-owned and maintained transformers once per year. 2. If campus staff observe a spill from a campus transformer, contact the Campus Emergency Coordinator at 920-424-3466.

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SPCC Plan – University of Wisconsin-Oshkosh, Oshkosh, Wisconsin Page 8




ROLES AND RESPONSIBILITIES 2.0

University of Wisconsin-Oshkosh Personnel Responsibilities

The Director of Operations and Maintenance Facilities serves as the overall Campus Emergency Coordinator (CEC), and the Buildings and Grounds Superintendent will serve as the Alternate Campus Emergency Coordinator (Alternate CEC) for the facility. They are responsible for the following items:

Emergency Coordinators

General Implementation

• Obtain all applicable signatures for the SPCC Plan

• Distribute and post the most current versions of applicable materials from the SPCC Plan (e.g., Monthly and Annual Inspection Checklists, Notice to Petroleum Product Vendors, and the Fuel/Oil Transfer Checklist) as they are updated

• Execute or coordinate the routine monthly inspections (Attachment B) and annual inspections (Attachment C)

• Coordinate/provide and document annual SPCC training (Attachment D)

• Post the Notice to Petroleum Product Vendors (Attachment E) on site and provide a copy of the notice to the vendor

• Coordinate the completion of the fuel/oil transfer checklist - recommended (Attachment F)

• Maintain SPCC records for a minimum of 3 years

• Use the Annual SPCC Plan Review form (Attachment G) to help evaluate for SPCC compliance, notify the UW-System Environmental Health Specialist of any changes to the facility with regards to oil storage, which will require SPCC amendments

Spill Response

• Implement the appropriate spill response operations and ensure the use of appropriate personal protective equipment

• Lead/coordinate emergency oil/fuel spill response team efforts

• Perform spill reporting, as necessary, following the procedures provided in this SPCC Plan

• Ensure the proper disposal of contaminated material

• Provide the information for spill reporting (completion of a Spill Incident Report – Attachment H), as necessary, following the procedures provided in this SPCC Plan to UW-System Environmental Health Specialist



Oil-Handling Employees Oil-handling employees at the facility are responsible for operating and maintaining the oil storage containers at the facility. In relation to the SPCC regulation, these responsibilities include the following:

• Attend annual SPCC training (all oil-handling employees) • Execute routine monthly and annual inspections (as assigned) • Notify the Campus Emergency Coordinator of any observed oil spills in order to start the

emergency spill response procedure • Place initial spill countermeasure materials (from facility spill kit(s))

UW-System Environmental Health Specialist Responsibilities

The UW-System Environmental Health Specialist is responsible for the following items:

• Provide annual SPCC training resources (as requested) • Conduct periodic reviews of records required for SPCC compliance • Support spill reporting, as requested, following the procedures provided in this SPCC Plan • Support coordinating SPCC amendments or required 5-year reviews for the SPCC Plan



SPILL RESPONSE 3.0This portion of the SPCC Plan covers this facility’s countermeasures to a potential spill and includes actions such as spill notification requirements, spill contents recovery, response, and cleanup. All oil spills, regardless of size, must be contained and cleaned up in a safe and effective manner.

To determine the proper response procedures, this plan classifies spills as ‘incidental,’ ‘non-incidental,’ or ‘imminent danger,’ depending on the following characteristics:

Oil Spill Response Criteria

Incidental Spills Non-Incidental Spills Imminent Danger Spills • The spill is small, less than

1- gallon. • The spill can be easily

contained. • The spill is unlikely to reach

a navigable waterway, storm sewer, or sanitary drain.

• Cleanup procedures do not pose a health or safety hazard.

• Proper response equipment is available for a safe cleanup.

• Responding personnel have completed annual SPCC training.

• Responding personnel are comfortable with cleaning up the spill.

• The spill is large enough to spread beyond the immediate area (generally 1 to 20 gallons in size).

• Spill may reach a navigable waterway, storm sewer, or sanitary drain.

• Spill may require special equipment or training to clean up.

• Spill may be beyond the responding personnel’s comfort or spill training level.

• If facility personnel address the spill, responding personnel have completed annual SPCC training.

• If responding personnel are not comfortable cleaning up the spill, use a third party contractor

• Based on the assessment of the fuel delivery driver or trained UW-Oshkosh oil handling employee(s), the spill poses an immediate hazard to human health or the environment.

• There is danger of fire or explosion. (e.g. a spill of greater than 1-gallon of gasoline).

• Spill involves injury to personnel.

• The spill has reached a navigable waterway, storm sewer, or sanitary drain.

• The spill cannot be contained.

Response by facility personnel possible.

Response requires coordination with Campus Emergency Coordinator or Alternate

Requires response by the Oshkosh Fire Department –

Call 911

Notify the appropriate authority based on the classification of the spill. If unable to identify the appropriate level of spill classification, notify the Campus Emergency Coordinator immediately. See the flowchart in Attachment I for specific spill response steps. Post the provided Spill Response Flow Chart in close proximity to key oil storage areas (see cover letter for suggested locations). Details regarding the potential spill volumes, direction of flow, and spill receptors for individual tanks and containers at the facility are listed in Table 1.

A number of spill scenarios are possible. The severity of the spill is dependent on a number of factors, such as, the oil source, the spill flow rate, or secondary containment. The spill flow rate could potentially range from a gradual spill (i.e., drip) to an instantaneous spill (i.e., complete failure) for its oil sources. This plan relies on the Oil Spill Response Criteria (above) and the Spill Response Flow Chart (Attachment I) to determine how to most appropriately respond to each spill.



VERBAL OIL SPILL NOTIFICATION REQUIREMENTS 3.1Depending on the nature and quantity of the oil spill, several individuals and organizations must be contacted by the Campus Emergency Coordinator or designee in the event of a spill. Circumstances, instructions, and phone numbers for reporting a spill to federal, state, and local agencies, and to other affected parties are provided below. It is preferred that the UW-System Environmental Health Specialist conducts this coordination; however, if the Environmental Health Specialist is not readily available the CEC or designee will complete the required notifications.

Oil Spill Notification Procedures

Agency/ Organization Contact Circumstances When to Notify

State Agencies Wisconsin Department of Natural Resources (WDNR) WDNR Spill Reporting Hotline

1-800-943-0003 Spill that threatens public health, welfare or the environment, or

Spill that produces a sheen on water and/or threatens navigable waters, or

One gallon or more of flammable liquid (e.g., gasoline) onto unpaved ground, or

Five gallons or more of combustible liquid (e.g., diesel) onto unpaved ground.

Immediately (verbal)

Federal Agencies National Response Center (NRC)

1-800-424-8802 www.nrc.uscg.mil

Discharge reaching navigable waters.


USEPA Region 5 (hotline)

1-800-621-8431 Discharge reaching navigable waters.


USEPA Region 5 Regional Administrator

USEPA Region 5 77 W. Jackson Blvd. Chicago, IL 60604

Discharge of 1,000 gallons or more; or second discharge of 42 gallons or more over a 12-month period.

Written notification within 60 days (see Section 3.3)

Local Agencies Oshkosh Fire Department

911 Spill that poses emergency conditions, regardless of the volume discharged.


City of Oshkosh Wastewater Utility

920-236-5000 Spill that enters the sanitary sewer system, regardless of the volume discharged.


For local agencies, a spill posing emergency conditions or imminent danger requires “immediate” notification to those authorities without other actions.



For state and federal agency verbal notifications, a spill that has occurred and meets reporting thresholds stated above requires “immediate” notification. In the case of state and federal verbal notifications, the facility can respond to spills that don’t pose imminent danger and collect all the information needed to complete the Spill Incident Report (Attachment H) prior to making these verbal notifications to agencies, but they should be made as soon as reasonably possible.

Under the SPCC rule, a reportable spill refers to any amount of oil that reaches a navigable waterway. Use Attachment J in this plan to document notifications.

USEPA WRITTEN SPILL NOTIFICATION REQUIREMENTS 3.2A written notification to the USEPA Regional Administrator is required for any single discharge of oil to a navigable waterway or adjoining shoreline waterway, for any discharge greater than 1,000 gallons, or for two discharges of 42 gallons or more of oil to navigable waters in any 12-month period. This report must be made within 60 days of the discharge and must include the following information:

1. Name of the facility.

2. Name of the individual submitting the information.

3. Location of the facility.

4. Maximum storage or handling capacity of the facility and normal daily throughput.

5. The corrective actions and/or countermeasures taken, including adequate description of equipment repairs and/or replacements.

6. An adequate description of the facility, including maps, flow diagrams, and topographical maps.

7. A complete copy of the SPCC Plan with any amendments.

8. The cause(s) of such discharge(s), including a failure analysis of the system or subsystem in which the failure(s) occurred.

9. Additional preventative measures taken or contemplated to minimize the possibility of recurrence.

SPILL RESPONSE MATERIALS AND WASTE DISPOSAL 3.3

Spill Response Materials

Location: The spill response material storage locations are shown on Figures 2 and 3. Spill kit storage locations for the campus are also listed in Table 1.

Approach: Place at locations central to the oil storage containers and near fuel/oil transfer areas.

Use: Control, contain, and clean up an oil release.

Response Materials Needed: Materials to contain/absorb incidental spills (typically up to 20 gallons of oil).

Maintaining Response Materials: Inspect the spill response kits at least annually to ensure sufficient supply.



Disposal of Used Sorbents and Contaminated Soil

• Record used sorbents and contaminated soil reclaimed after a spill in the Oil Spill Disposal Record (Attachment K).

• Store and dispose used sorbents and contaminated soil in a manner consistent with local, state, and federal regulations, as well as University of Wisconsin-Oshkosh policy.

• Contain absorbent materials separately from contaminated soil/granular clay (Oil-Dri) in drums or non-leaking containers.

• Work with your regulated waste vendor to determine if the spilled product may be considered a hazardous waste.

Notes: Oil absorbents that are not hazardous waste may be placed in the trash if there is no free-flowing oil remaining in the absorbents. A licensed waste disposal company can help with removal and treatment of hazardous wastes and absorbents with free-flowing oil.

SPILL PREVENTION AND CONTROLS 4.0This section of the SPCC Plan covers this facility’s prevention and control measures in place to help this facility limit its potential for spills.

POTENTIAL OIL SPILL SOURCES 4.1For the oil sources at this facility, the maximum spill volumes, direction of flow, and potential spill receptors for individual tanks and containers are listed in Table 1. Oil source locations are shown on Figures 2 and 3. An oil release could occur due to the following situations:

During loading/unloading activities, such as:

• Overflow or spillage during tank or container filling – Potential rate of flow is dependent on fill rate of mobile tanker truck (typically ranges

between 60 gallons per minute (gpm) and 300 gpm) – Total volume released is dependent on how quickly the filling technician or facility

representative (if observing transfer process) is able to press the emergency shutoff button on the tanker truck and size/remaining product in the mobile tanker truck (typically ranges from nil to hundreds of gallons).

• Spillage during tank or container emptying – Potential rate of flow is dependent on the empty rate of the mobile tanker truck or

pump (typically ranges from 5 to 10 gpm for pumps and 60 to 300 gpm for mobile tanker trucks)

– Total volume released dependent on how quickly the filling technician or facility representative (if observing transfer process) is able to turn off/unplug the pump or press the emergency shutoff button on the truck and size/remaining product in the mobile tanker truck (typically ranges from nil to hundreds of gallons).



Due to equipment failure, such as:

• Tank rupture as a result of nature, human error, or vandalism – Potential release rate is instantaneous (entire container contents released

immediately) and total volume released is equal to the volume of the container (see Table 1)

• Leaks due to corrosion or partial failure of tank or container seams, pipes, valves, or connections – Potential release rate is approximately nil to 10 gallons per minute and total volume

released is equal to the volume of the container (see Table 1)

GENERAL SPILL PREVENTION MEASURES 4.2Implement the following measures to prevent or limit an oil spill at the facility:

• Verify that tanks and containers are constructed of material compatible with the oil being stored (Section 4.8).

• Provide a functioning liquid level sensing device for bulk storage containers, such as a visual gauge, an electronic high level alarm, or automatic pump cutoff (Section 4.4.3).

• Practice good housekeeping to ensure that oil storage areas are kept clear of debris. • Promptly correct all visible spills (Section 3.0). • Provide appropriate secondary containment (Section 4.3). • Practice proper unloading/loading procedures during oil transfer activities

(Section 4.4/Attachment E). • Conduct monthly and annual inspections on all SPCC-applicable tanks and containers

(Section 4.5.1). • Conduct integrity testing, or a practice that is environmentally equivalent, on tanks and

containers as required (Section 4.5.2). • Store sufficient spill response materials near oil sources (Section 3.3). • Train personnel at least annually in proper oil-handling procedures (Section 4.6). • Provide adequate security measures on and around all oil sources (Section 4.7). • Maintain inspection and maintenance records for 3 years (Section 4.5.1/Section 7.0).

SECONDARY CONTAINMENT 4.3All oil source areas listed in Table 1 at this facility are required to be designed with appropriate containment and/or diversionary structures. Common examples of secondary containment include double-wall tank construction, concrete containment berms, spill pallets for portable drums, nearby sorbent materials, oil/water separators, and self-contained concrete-floored rooms. Specific information regarding secondary containment measures provided for each tank and container is included in Table 1.

The oil storage containers at the facility have sufficient secondary containment except as noted in the paragraphs below. Bulk storage containers (tanks) meet the requirements for sized containment in 40 CFR 112.8(c)(2). Oil-filled equipment meets the general secondary containment requirements in 40 CFR 112.7(c).

The drum storage areas in the Auto Shop (D2), the Grounds Facility Building (D4), and the Campus Services Building (D5) did not have secondary containment during the SCS Engineers (SCS) site



visit - see the SPCC Plan requirements in the cover letter attached to this plan. Active containment measures (nearby spill response materials) will be used to control spills in the interim.

The bulk storage associated with the 275-gallon used cooking oil and grease container (AST8) does not currently meet the secondary containment requirements for animal fats and vegetable oils in 40 CFR 112.12(c)(2). The facility is applying an impracticability determination to AST8 – see more discussion in Section 4.3.1.

Impracticability Determination 4.3.1

This facility is applying an impracticability determination in lieu of secondary containment for AST8. Secondary containment is required for AST8 per 40 CFR 112.12(c)(2). Secondary containment is impractical for the following reasons:

1. Constructing a diked containment around the container will increase the potential for incidental spills because it increases the difficulty in filling and emptying the container.

2. Available space around the containers is limited as the respective areas are in close proximity to student walkways through this campus.

3. AST8 is a vendor-supplied container. The vendor does not have an alternative container that is double-walled or has built-in secondary containment.

In lieu of secondary containment, the facility performs the following:

• Replace AST8 with new containers or inspected, used containers every 10 years. Alternatively, to continue use of the existing container (AST8), conduct external integrity testing and leak detection testing every 10 years – Refer to Table 1.

• Develop an oil spill contingency plan per 40 CFR 109.5 – Refer to the below cross reference table which summarized how the requirements of 40 CFR 109.5 are incorporated into this SPCC Plan.

• Provide a written commitment of resources to control and remove any oil that would be discharged – Refer to page iii for the written commitment of resources.

Table 2. Cross-Reference with Spill Contingency Rules

Provision Rule Coverage Plan Section 109.5(a) Definition of the authorities, responsibilities, and duties of all

persons Sections 1.2 and 2.0

109.5(b) Establishment of notification procedures Section 3 and Attachment I 109.5(b)(1) Identification of critical water use areas Section 1.2(1)

109.5(b)(2) Current list of names, telephone numbers, and addresses Section 1.2(2) and (3), Section 3.1

109.5(b)(3) Provisions for access to a reliable communications systems Section 1.2(2) and (3) 109.5(b)(4) An established, prearranged procedure for requesting

assistance Section 3 and Attachment I

109.5(c)(1-3) Provisions to assure that full resource capability is known Section 3.3, Section 1.2 (4)

109.5(d)(1-5) Provisions for well-defined and specific actions to be taken Section 3, Attachment I



OIL TRANSFER ACTIVITIES 4.4

Transfer Procedures 4.4.1

Oil transfer at the facility may include the filling and emptying of tanks by a tanker truck, the dispensing of oil from tanks into smaller containers or vehicles, or the transfer of used oil into tanks or containers. Specific oil transfer activities related to individual oil sources for this facility are included in Table 1. Fill port covers prevent water from entering tanks and are kept closed except when transfers are occurring. All petroleum product vendors and University of Wisconsin-Oshkosh employees who deliver, load, unload, or pick up petroleum products must review and comply with the requirements set forth in Attachment E, the Notice to Petroleum Product Vendors. Provide a copy of the notice to the vendor prior to each fuel/oil transfer. During oil transfer activities, follow these measures to prevent a spill:

• Temporarily cover or block nearby storm or sanitary sewer drains.

• Know the location of the closest spill kit containing oil absorbent materials in case of a spill.

• Check to make sure the drivers understand the amount of product to be transferred and they are constantly monitoring for potential oil storage container overfills.

• Ensure drivers are monitoring the transfer of oil full-time while the product is being transferred.

• Use wheel chocks or other similar barriers to prevent premature movement of transfer vehicles.

• Inspect around and below oil transfer vehicles for leaks before and after loading or unloading.

• For transfers not involving filling and emptying of tanks by a tanker truck, use a funnel or pump when adding or removing smaller quantities of oil to tanks, containers, or filling oil-filled electrical equipment reservoirs.

The Fuel/Oil Transfer Checklist (Attachment F) is recommended as a best management practice (BMP) for completion for each oil transfer conducted by a third party vendor for tanks listed within this SPCC Plan. To ensure these practices are followed by vendors and oil-handling employees, either review the Notice to Petroleum Product Vendors (Attachment E) with vendors each transfer or post the notice prominently in key oil transfer areas.

General Secondary Containment in Transfer Areas 4.4.2

Since other fuel/oil transfers at the campus are conducted on impervious surfaces and have nearby spill kits or drain covers readily available for use if needed, they meet general secondary containment requirements in 40 CFR 112.7(c). See recommendation for drain covers in the cover letter.

Vendors are to follow Attachment E and Attachment F. This practice is in place to contain a potential spill to the oil transfer area.



Overfill Protection 4.4.3

The facility aboveground storage tanks (ASTs) have sufficient overfill protection in the form of either high liquid level alarms (40 CFR 112.8(c)(8)(i)) or direct vision level gauges (40 CFR 112.8(c)(8)(iv)). To use the alternative of “direct vision gauges,” a person must be present to monitor gauges and the overall filling of bulk storage containers (ASTs). For overfill protection associated with individual oil sources, see Table 1.

For the facility’s drum storage (D1 through D5), and the bulk storage associated with the used/new cooking oil and grease containers (AST8), the facility is following the environmentally equivalent procedure below in lieu of the 40 CFR 112.8 (C)(8) and 40 CFR 112.12(c)(8) for the drum storage and used cooking oil storage, respectively.

1.) Verify container has sufficient free capacity for the transfer 2.) Visually monitor the product level during transfer

Elevators and campus-owned transformers are oil-filled operational equipment, and are not considered bulk storage containers. Oil-filled operational equipment does not require overfill protection. For overfill protection associated with individual oil sources, see Table 1.

INSPECTIONS AND INTEGRITY TESTING 4.5

Periodic Visual Inspections 4.5.1

The purpose of visual inspections is to determine if an oil spill has occurred, assess the general condition of tanks, containers, and piping, and determine the suitability for continued oil storage until the next inspection. The inspection program for the facility includes informal observations for leakage from equipment as it is used, as well as monthly and annual scheduled inspections. Checklists used to document the inspections are included as Attachments B and C and must be kept for a minimum of 3 years. The visual inspections do not require a Certified Inspector. Table 1 lists the required inspection frequency for individual tanks and containers. Inspection criteria and schedules outlined in this plan are based upon the following accepted industry standards:

Industry Standard Title General Applicability Steel Tank Institute (STI) SP-001-18

Standard for the Inspection of Aboveground Storage Tanks (2018, 6th ed.)

Smaller shop-fabricated tanks and portable containers

Conduct monthly inspections by checking:

• Storage areas for signs of debris that may block access • Storage areas for unlabeled or outdated containers • Tanks, containers, and associated piping for evidence of leakage or spillage • Tanks and containers for water or oil in the tank, interstice, or secondary containment

Conduct annual inspections on ASTs by checking:

• Secondary containment structures for evidence of damage • Tank foundation and support structures for signs of settlement, corrosion, or damage • Tank or container exterior coatings for needed cleaning or maintenance



• Tank normal and emergency vents for needed cleaning or maintenance • Tank or container liquid level and overfill prevention sensing devices • Spill response materials for replacement or replenishment of spill response materials

Conduct annual inspections on transformers by checking:

• Transformer areas for signs of failure/damage • Transformer level gauge functionality • Transformer exterior or surrounding area for signs of leakage • Transformer valves/fittings for signs of leakage • Transformers for water or oil in the tank, interstice, or secondary containment

Additional inspection items may be warranted if the facility incurs damaging severe weather events (e.g., lightning strikes, wind damage, flooding). The inspection frequency for the oil/fuel storage containers at this facility is summarized in the table below.

Tank or Container Type Guidance Visual Inspection Frequency Aboveground storage tanks STI SP-001-18 Monthly and Annually Used cooking oil and grease tanks STI SP-001-18 Monthly Portable Drums STI SP-001-18 Monthly Elevators Manufacturer

Recommendations Follow manufacturer Recommendations

Transformers Manufacturer recommendations Annually

The facility personnel performing these inspections are knowledgeable of the facility operations, characteristics of the oil stored, the type of container, and its associated components. The scope of inspections and procedures are covered in the training provided to employees involved in handling oil at the facility. The routine inspections focus specifically on detecting changes in conditions or evidence of oil leakage from the container, piping system, or appurtenances.

If non-conforming items important to the tank or containment integrity are identified, an evaluation by an engineer experienced in AST design, a certified inspector, or a tank manufacturer is required to determine the appropriate corrective action. As an alternative, the facility owner may replace the tank/container with a new tank/container.

Maintain copies of tank permits, licenses, records of inspections, and integrity tests.

Integrity Testing 4.5.2

The purpose of integrity testing is to measure the tank or container’s structural imperviousness and its soundness in containing oil, ensuring its suitability for continued use under current and anticipated operating conditions. Integrity testing may also help a facility determine whether corrosion has reached a point where repairs or replacement of the container is needed, and thus avoid unplanned interruptions in facility operations.

Compliance recommendations for the SPCC rule’s integrity testing requirements are based on the STI Standard for the Inspection of Aboveground Storage Tanks (SP-001-18). The following table summarizes general integrity testing requirements.



Tank Type Tank

Volume (gallons)

Secondary Containment Guidance Integrity Testing

Frequency Shop-built aboveground storage tanks

0 – 1,100 Spill control1 with or without a continuous release detection method2

STI SP-001-18 Not required

Portable Containers

Drums/Totes Spill control1 with or without continuous release detection method2

STI SP-001-18 Not required

1 Spill control is a means of preventing a release of liquid to the environment (e.g., secondary containment berm, dual-walled AST, or other secondary containment system).

2 Continuous release detection method (CRDM) refers to a means of detecting a release of liquid where releases are visually detectable by facility operators (e.g., dual-walled AST with interstitial monitoring port, elevated AST, AST on a concrete floor).

At University of Wisconsin-Oshkosh, there are eight shop-fabricated ASTs that are less than 1,100 gallons in capacity. The following ASTs have intact spill control in place being double-walled:

• AST1 • AST2 • AST3 • AST4 • AST5 • AST6 • AST7 • AST9

Additionally, each of these tanks also has continuous release detection method because they are located above impervious surfaces and routinely inspected. Therefore, AST1 through AST7 and AST9 do not require formal integrity testing by a certified third party inspector.

AST8 does not have spill control in place, therefore, it requires formal integrity testing be a certified inspector every 10 years or documentation of a new container being provided by the vendor to service this facility at least every 10 years.

Formal integrity testing is not required for the steel drums in drum storage areas (D1 through D5).

Hydraulic elevator reservoirs and transformers are oil-filled operational equipment, and are not considered bulk storage containers. Oil-filled operational equipment does not require formal integrity testing by a certified inspector.

PERSONNEL TRAINING 4.6All oil-handling personnel must receive at least annual training to properly respond to spills in their work areas. UW-System provides materials and guidance to satisfy this training requirement. The Campus Emergency Coordinator determines who is considered an oil-handling employee at the facility, and the content and training method (e.g., hands-on, classroom, computer-based of the training provided). A training documentation form is provided as Attachment D. Update the form each time the on-site staff receive training. Or, alternatively, training records can be retrieved from the electronic filing associated with the campus’s online learning system. Training needs to cover the following information:



• The contents of the facility SPCC Plan, including the specific locations of oil tanks and containers

• The frequency and procedures of inspections and record keeping • The operation and maintenance of equipment to prevent spills • Spill response procedures • Applicable oil pollution prevention laws, rules, and regulations • General facility operations • Discharge prevention briefings highlighting and describing discharges or failures,

malfunctioning components, and any recently developed precautionary measures

SECURITY 4.7In order to ensure the safety of the facility personnel and to minimize the potential for releases of oil, various security measures are in place. Campus buildings are locked when not occupied to prevent unauthorized entry. Exterior lighting is provided and the campus is routinely patrolled by campus police. Some oil sources are fully fenced with a secured gate. All exterior loading/unloading connections are securely capped or blank-flanged when not in use or in standby mode. Specific security information related to individual tanks and containers is listed in Table 1.

TANK CONSTRUCTION MATERIAL 4.8All tanks are constructed with material that is compatible with the contents stored in them.

CONFORMANCE WITH APPLICABLE STATE REQUIREMENTS 5.0This SPCC Plan was prepared and is implemented consistent with the current version of 40 CFR 112. The State of Wisconsin regulates AST storage through the Department of Agriculture, Trade and Consumer Protection utilizing Wisconsin Administrative Code (WAC) Agriculture, Trade and Consumer Protection 93 (ATCP 93) regulations, specifically Subchapter IV. Refer to Attachment A for a summary of how this Plan complies with applicable portions of ATCP 93.

The State of Wisconsin has a requirement for spill reporting. Under WAC NR 706.05, persons who cause a spill of any hazardous substance (e.g., oil) or who possess or control a hazardous substance which is discharged to the environment shall immediately report the spill to the WDNR if one of the following conditions exists:

1. The oil spill threatens public health, welfare, or the environment;

2. The oil spill produces a sheen on water and/or threatens navigable waters;

3. The oil spill is 1 gallon or more of flammable liquid (e.g., gasoline) onto unpaved ground;

4. The oil spill is 5 gallons or more of combustible liquid (e.g., diesel) onto unpaved ground.

Report spills to the WDNR, and include information on the spill containment procedures undertaken, and a proposed procedure for cleanup and disposal.

CERTIFICATION REQUIREMENTS 6.0The facility has approximately 8,712 gallons of aboveground oil storage capacity in containers 55 gallons or greater. This total does not include campus owned and maintained transformers.



The University of Wisconsin-Oshkosh is considered to be a “qualified facility” because it has less than 10,000 gallons in aggregate aboveground oil storage and this facility has not had a single discharge of oil to navigable waters exceeding 1,000 gallons, or two discharges of oil into navigable waters each exceeding 42 gallons within any 12-month period in the 3 years prior to the SPCC Plan certification date. Therefore, if an amendment, as described in Attachment M, is made to the facility and the facility continues to meet the qualifying criteria mentioned in this paragraph, University of Wisconsin-Oshkosh could choose to self-certify rather than having a Professional Engineer certify the mandatory 5-year review or any future amendments to this SPCC Plan.

Even though the University of Wisconsin-Oshkosh could self-certify this SPCC Plan, a third-party Professional Engineer conducts the 5-year review per the UW-System’s current policy.

RECORDS 7.0Maintain inspection checklists, training record, notice to petroleum vendors, fuel/oil transfer checklist, annual SPCC Plan review, spill incident reports (if needed), spill reporting log (if needed), oil spill disposal record (if needed), and amendment log/certification (if needed) in Attachments A through M for a minimum of 3 years.


SPCC Plan – University of Wisconsin-Oshkosh, Oshkosh, Wisconsin www.scsengineers.com

Figures 1 Site Location Map 2 Facility Site Plan – East 3 Facility Site Plan – West


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LEGEND CAMPUS/FACILITY BOUNDARY ABOVEGROUND STORAGE TANK (AST) ELEVATOR RESERVOIR (E) STORM SEWER CURB INLET STORM SEWER INLET MOBILE TANKER LOADING/UNLOADING LOCATION UNDERGROUND GREASE TRAP (UGT) - EXEMPT UNDERGROUND STORAGE TANK (UST) - EXEMPT SPILL KIT SURFACE FLOW DIRECTION

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NOTES: 1. SIZE AND CONTENTS OF EACH ELEVATOR OIL SOURCE ARE SIZE AND CONTENTS OF EACH ELEVATOR OIL SOURCE ARE AVAILABLE IN TABLE 1 OF THE SPCC PLAN. 2. CAD BACKGROUND DRAWING "FRAMED CAMPUS MAP 2018.DWG" CAD BACKGROUND DRAWING "FRAMED CAMPUS MAP 2018.DWG" (JUNE 2018) PROVIDED BY UW-OSHKOSH. 3. IF CAMPUS STAFF OBSERVE A SPILL FROM A TRANSFORMER, IF CAMPUS STAFF OBSERVE A SPILL FROM A TRANSFORMER, CONTACT THE CAMPUS EMERGENCY COORDINATOR. 4. UW-OSHKOSH PLANS TO ADD (2) 15,000-GALLON ABOVEGROUND UW-OSHKOSH PLANS TO ADD (2) 15,000-GALLON ABOVEGROUND FUEL OIL TANKS IN 2020 AT THE HEATING PLANT.

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SCOTT HALL AST5 185-GALLON DIESEL FUEL

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NOTES: 1. SIZE AND CONTENTS OF EACH ELEVATOR OIL SOURCE ARE SIZE AND CONTENTS OF EACH ELEVATOR OIL SOURCE ARE AVAILABLE IN TABLE 1 OF THE SPCC PLAN. 2. CAD BACKGROUND DRAWING "FRAMED CAMPUS MAP 2018.DWG" CAD BACKGROUND DRAWING "FRAMED CAMPUS MAP 2018.DWG" (JUNE 2018) PROVIDED BY UW-OSHKOSH.

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LEGEND CAMPUS/FACILITY BOUNDARY ELEVATOR RESERVOIR (E) DRUM STORAGE AREA (D) STORM SEWER INLET FLOOR DRAIN TO SANITARY SEWER UNDERGROUND STORAGE TANK (UST) - EXEMPT SPILL KIT SURFACE FLOW DIRECTION

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SPCC Plan – University of Wisconsin-Oshkosh, Oshkosh, Wisconsin www.scsengineers.com

Attachments

A Cross-Reference with the SPCC Rule B Monthly Inspection Checklist C Annual Inspection Checklist D SPCC Training Record E Notice to Petroleum Product Vendors F Fuel/Oil Transfer Checklist G Annual SPCC Plan Review H Spill Incident Report I Spill Response Flow Chart J Spill Reporting Compliance Documentation Log K Oil Spill Disposal Record L Amendment Log M Plan Amendment Certification


ATTACHMENT A

Cross-Reference with the SPCC Rule University of Wisconsin-Oshkosh

40 CFR Part 112 Description SPCC Plan Location

Subpart A: Applicability, Definitions, and General Requirements for All Facilities and All Types of Oils

§ 112.1 General applicability Section 1.1 § 112.2 Definitions See 40 CFR 112 § 112.3(d) Professional Engineer Review &

Certification Section 6.0 and Page v

§ 112.3(e) Plan location and availability Section 1.2 § 112.4 Regional Administrator Submittal Section 3.2 § 112.5 Amendment of SPCC Plan by owners or

operators Cover letter, Section 6.0, and Attachments L and M

§ 112.6(a)(1) Qualified Facilities Plan requirements Section 6.0 § 112.6(a)(2) Technical Amendments Attachments L and M § 112.7 General requirements for SPCC Plans

§ 112.7(a)(1) Conformance with applicable parts of § 112.7

Sections 1.0 and 5.0

§ 112.7(a)(2) Compliance with applicable parts of § 112.7

See the other cross-references in this table

§ 112.7(a)(3) Physical layout and facility diagram Figures 2 and 3 (a)(3)(i) Oil storage type and capacity Table 1 (a)(3)(ii) Discharge prevention measures Section 4.0 and Table 1 (a)(3)(iii) Discharge or drainage controls Section 4.2 and Table 1 (a)(3)(iv) Countermeasures for discharge

discovery, response, and cleanup Section 3.0

(a)(3)(v) Recovered material disposal Section 3.3 (a)(3)(vi) Contact list Attachment I

§ 112.7(a)(4) Response plan or spill reporting procedures

Section 3.0, and Attachments H, I, J, and K

§ 112.7(a)(5) Discharge procedures to use in emergency

Section 3.0, and Attachment I

§ 112.7(b) Spill direction, rate of flow, and total quantity of oil during failures

Table 1, Figure 2, Figure 3, and Section 3.0

§ 112.7(c) General Secondary Containment Section 4.4.2 § 112.7(d)(1) Secondary containment impracticability

determination Section 4.3.1

§ 112.7(d)(2) Written commitment of manpower, equipment, and materials

Page iii

§ 112.7(e) Inspections, tests, and records Sections 4.5 and 7.0, and Attachments B and C

§ 112.7(f)(1) Train the facility’s oil-handling personnel Section 4.6, Attachment D § 112.7(f)(2) Designated accountable person for

discharge prevention Section 1.2, Attachment I

§ 112.7(f)(3) Conduct annual discharge prevention briefings

Section 4.6

ATTACHMENT A



§ 112.7(g) Security Section 4.7 and Table 1 § 112.7(h) Facility tank car and tank truck loading/

unloading rack Not applicable

§ 112.7(i) Field Constructed Tanks Not applicable § 112.7(j) State-level requirements Section 5.0 and Attachment

A § 112.7(k) Oil-filled operational equipment Table 1 and Section 4.5.2

Subpart B: Requirements for Petroleum Oils and Non-petroleum Oils, Except Animal Fats and Oils and Greases, and Fish and Marine Mammal Oils; and Vegetable Oils (Including Oils from Seeds, Nuts, Fruits, and Kernels)

§ 112.8 SPCC Plan Requirements for onshore facilities (excluding production facilities).

§ 112.8(a) Compliance with § 112.7 See above § 112.8(b)(1) Restrain drainage from diked storage

areas Not applicable

§ 112.8(b)(2) Valve use from diked storage areas Not applicable § 112.8(b)(3) Facility drainage systems from undiked

areas Not applicable

§ 112.8(b)(4) Facility drainage diversion systems Not applicable § 112.8(b)(5) Facility drainage treatment systems Not applicable § 112.8(c)(1) Tank Material Compatibility Section 4.8 and Table 1 § 112.8(c)(2) Secondary containment – bulk storage

containers Section 4.3 and Table 1

§ 112.8(c)(3) Storm water drainage from diked areas Not applicable § 112.8(c)(4) Buried metal tank corrosion prevention Not applicable § 112.8(c)(5) Partially buried or bunkered metal tanks Not applicable § 112.8(c)(6) Integrity Testing Section 4.5.2 § 112.8(c)(7) Internal heating coils Not applicable § 112.8(c)(8) (i)-(v) Overfill Protection (Liquid-level sensing

devices) Section 4.4.3 and Table 1

§ 112.8(c)(9) Observation of effluent treatment facilities

Not applicable

§ 112.8(c)(10) Promptly correct visible discharges of oil Section 3.0, and Attachments H, I, J, and K

§ 112.8(c)(11) Secondary containment for mobile or portable containers

Table 1, Section 4.5.2

§ 112.8(d)(1) Buried piping corrosion protection Not applicable § 112.8(d)(2) Cap or blank-flange the terminal

connection on transfers Not applicable

§ 112.8(d)(3) Design pipe supports to minimize corrosion

Not applicable

§ 112.8(d)(4) Routine inspection of all aboveground valves, piping, and appurtenances

Section 4.5.1, Attachments B and C

ATTACHMENT A



§ 112.8(d)(5) Vehicular traffic near tank systems Section 4.4.1, Table 1, and Attachments E and F

§ 112.9 SPCC Plan requirements for onshore oil production facilities (excluding drilling and workover facilities)

Not applicable

§ 112.10 SPCC Plan requirements for onshore oil drilling and workover facilities

Not applicable

§ 112.11 SPCC Plan requirements for offshore oil drilling, production, or workover facilities

Not applicable

Subpart C: Requirements for Animal Fats and Oils and Greases, and Fish and Marine Mammal Oils; and Vegetable Oils, Including Oils from Seeds, Nuts, Fruits, and Kernels)

§ 112.12 SPCC Plan requirements Section 4.3, Section 4.3.1, and Section 4.4.3

Subpart D: Response Requirements § 112.20 Facility response plan Not applicable § 112.21 Facility response training and

drills/exercises Not applicable

ATCP 93 Description SPCC Plan Location

Subchapter III – Specific Tank Storage Applications (related to spill prevention, control, and countermeasure)

§ 93.300 Tanks storing used oil § 93.300(2)(f) The fill opening shall be closed except

when a transfer is actually taking place Not applicable

§ 93.300(3)(a) The fill opening shall be provided with spill containment

Not applicable

§ 93.300(3)(b) If the fill opening is located outdoors, the opening shall be located in a watertight enclosure of noncombustible construction

Not applicable

§ 93.300(3)(c)(1) If fill point is remote from tank or delivery person cannot readily observe the tank gauge, an overfill alarm shall be provided at the fill point

Not applicable

§ 93.300(3)(c)(2) The alarm shall be readily audible or visible at the fill point and shall alert the delivery person when the tank is 90 percent full

Not applicable

Subchapter III – Specific Tank Storage Applications (related to spill prevention, control, and countermeasure) § 93.400 General Requirements

§ 93.400(2)(a) Corrosion protection through paint and protective coatings

Table 1/Attachment C

§ 93.400(2)(b) Sufficient corrosion protection for tanks in contact with the ground

Table 1/Attachment C

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ATTACHMENT B – MONTHLY INSPECTION CHECKLIST

University of Wisconsin-Oshkosh – Year: ___________

Complete this inspection checklist each month for all tanks and containers listed on page 2. Check boxes ONLY if the statement is true. If the statement is true for any of the sources, provide further description and comments on the page 2 of this form, and address immediately.

AST1- AST9, Tank Areas and Piping Month

1 2 3 4 5 6 7 8 9 10 11 12 Tank and Piping

Tank exterior and area around the tank show signs of leakage. Tank level gauge is unreadable or not functional. There is water in the primary tank. Interstitial monitoring equipment is not functional. There is oil/water in the interstice. Piping connections to the tank (valves, fittings, pumps, etc.) have visible leaks.

Equipment on Tank Overfill equipment: Test button doesn’t activate an audible horn or light to confirm operation. Overfill equipment: Test button requires a new battery. Overfill equipment: If overfill valve is equipped with a mechanical test mechanism, actuating the mechanism shows it to be not functional.

Spill bucket at fill port has water/oil in it, shows visible leaks, or is not functioning properly. Other Conditions

There are other site conditions that need to be addressed at this time for continued safe operation or that may affect this SPCC Plan.

D1 – D5 Portable Container Containment/Storage Areas Month

1 2 3 4 5 6 7 8 9 10 11 12 Containers or drums are not within designated storage area(s). Containers or drums show signs of leakage on their tops, sides, or surrounding ground. Containers or drums show signs of distortions, buckling, denting, or bulging. The containment and storage area has excess liquid, debris, cracks or fire hazards. The containment drain valves are open or in poor working condition. Egress pathways are blocked or gates/doors are not operable.

of 2

ATTACHMENT B – MONTHLY INSPECTION CHECKLIST (CONTINUED)

University of Wisconsin-Oshkosh – Year: ___________

Notes: Month Source/Area Notes

Check off under each source name after it has been inspected for the current month. After you complete your inspection of the oil sources each month, sign and date the table below.

Month AST1 AST2 AST3 AST4 AST5 AST6 AST7 AST8 AST9 D1 D2 D3 D4 D5 Signature Date January

February

March

April

May

June

July

August

September

October

November

December

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ATTACHMENT C – ANNUAL INSPECTION CHECKLIST

University of Wisconsin-Oshkosh - Year: ___________

Complete this checklist on an annual basis supplemental to the monthly-performed checklists. This inspection record will be completed each year for all tanks/containers and campus-owned transformers indicated below. Check boxes ONLY if the statement is true. Provide further description and comments, as needed.

AST1 – AST7, and AST9, Tank Areas and Piping Notes Tank Foundation and Supports

There are signs of tank settling or foundation washout. There are signs of cracking or spalling of the concrete pad or floor beneath the tank. Tank supports are in unsatisfactory condition. Water is not draining away from the tank if tank is resting on a foundation. Tank grounding strap is not secured or in poor condition.

Tank Shell There are signs of coating failure on the tank shell. The tank’s steel shell has dents, buckling, bulging, corrosion, or cracking. Labels/tags are not intact or not legible.

Tank Manways, Piping, and Equipment Flanged connection bolts loose or not fully engaged showing signs of wear or corrosion.

Tank Vents Normal and emergency vents have obstructions. The emergency vent components are not moving freely (also evaluate long-bolt manways). The emergency vent is in poor working condition or not functional. Consult manufacturer’s requirements as needed.

Tank Equipment Interstitial leak detection equipment is in poor condition. Windows on sight gauges are dirty. Wire connections are exposed or frayed. Equipment with test function does not activate to confirm operation.

Tank Valves Tank valves have either leaks, corrosion, or other damage. Valve routine maintenance is not following manufacturers’ instructions. (Valves to check include any anti-siphon valve, check valve, gate valve, pressure regulator valve, expansion release valve, solenoid valve, fire valve, and shear valve).

Tank/Piping Release Detection Inventory control is not being performed and documented (as required). Release detection is not being performed and documented (as required).

Miscellaneous Tank System Items The electrical wiring and box associated with the tank system are in poor condition.

ATTACHMENT C – ANNUAL INSPECTION CHECKLIST (CONTINUED)

University of Wisconsin-Oshkosh - Year: ___________

Page 2 of 2

AST1 – AST7, and AST9, Tank Areas and Piping Notes Cathodic protection system on the tank has not been tested as required by the designing engineer.

Transformers (Campus Owned and Maintained) Notes Transformer shows obvious signs of failure/damage. Transformer level gauge is not functional. Transformer exterior and surrounding area show signs of leakage. Transformer valves/fittings show signs of leakage. There is oil/water in the concrete secondary containment area (if applicable)

Spill Response Materials Notes Spill response materials require replenishment.

Source/Area Notes

Check off under each source name after it has been inspected. After you complete your inspection for the specified oil sources, sign and date the table below.

Month/Year AST1 AST2 AST3 AST4 AST5 AST6 AST7 AST9

Month/Year T_ T_ T_ T_ T_ T_ T_ T_

Date: Signature:

ATTACHMENT D

SPCC Training Record University of Wisconsin-Oshkosh

Training records can also be retrieved from the electronic filing associated with the campus’s online learning system.

Date of Training

Name of Trainee (Please Print)

Type of Training Signature of Trainee

Signature of Trainer Initial Refresher

ATTACHMENT E

NOTICE TO PETROLEUM PRODUCT VENDORS April 2019 To: All Bulk Petroleum Product Vendors From: University of Wisconsin-Oshkosh ● Phone: 920-424-3466

Petroleum product vendors who deliver, load, unload, or pick up petroleum/oil-based products or used oil to or from our facility are required to comply with the following:

Exercise caution when maneuvering vehicles to avoid damage to secondary containment structures.

Drivers are to be present and alert while monitoring the transfer of petroleum product full time while product is being transferred to or from on-site storage containers.

Chock the tank truck wheels while loading or unloading tanks and do not remove the wheel chocks until after the transfer is complete and the transfer hose is disconnected to prevent an accidental drive-off without removing the transfer hose.

Prior to filling and departure, closely inspect for discharges at the lowermost drain and all outlets of the tank truck, and if necessary, ensure that they are tightened, adjusted, or replaced to prevent liquid discharge while in transit.

Continuously monitor for potential tank overfills while loading or unloading storage containers. Check the freeboard capacity of containers prior to filling to estimate the volume to fill the tank and visually monitor the filling process to ensure the tank does not overfill. For tanks with audible air vent alarms, continuously listen for the audible air vent overfill warning whistle.

Promptly stop and clean up any petroleum product leaks or spills that occur while loading or unloading containers.

Immediately report leakage or spillage requiring assistance of site personnel to clean up to University of Wisconsin-Oshkosh site management.

Prior to loading/unloading, place an empty container under the hose end to be disconnected first with enough capacity to catch the remaining liquid in the transfer hose. Verify that appropriate valves are closed before disconnecting loading/unloading lines. Prior to disconnecting the transfer hose, gravity drain remaining product in the hose to the lowest container.

This notice is provided for your information to make you aware of these requirements to help us limit the potential for spills at this facility during transfer operations.

ATTACHMENT F

Fuel/Oil Transfer Checklist University of Wisconsin-Oshkosh

The completion of this form is not an SPCC requirement, but rather a best management practice recommended by the UW System.

On-site personnel, that have received the SPCC training, are responsible for overseeing fuel/oil transfer activities. Complete this form prior to commencing fuel/oil transfer activities.

Date: Location:

Notice to Petroleum Product Vendors provided to delivery driver prior to transfer activities? Yes No

Tank operator present during fueling? Yes No

Tank filling is monitored constantly? Yes No

Tank level before loading (1) ___________ (inches) _________ (gallons)

Tank level after loading (2) ___________ (inches) _________ (gallons)

Total loaded (3 = 2 - 1) (3) ___________ (inches) _________ (gallons)

Storage tank and related piping inspected? Yes No

5-gallon drip bucket under discharge hose? Yes No (Where needed to prevent spills.)

Storm drains covered? Yes No

Absorbent materials available? Yes No

Any leaks or spills? Yes No

Wheels chocked? Yes No

Comments:

Acknowledgment of Receipt of Materials and Proper Procedures Followed:

Facility Personnel Signature Printed Name/Date

Acknowledgment of Transfer of Materials and Proper Procedures Followed:

Fuel Delivery Driver Signature Printed Name/Date

ATTACHMENT G

Annual SPCC Plan Review for University of Wisconsin-Oshkosh Review this plan annually. Provide further description and comments, if necessary, on a separate sheet of paper and attach to this sheet. Any item receiving a "no" will be described and addressed immediately.

Review the following: Yes No If no, describe the action to be taken and note the date that the issue was corrected.

The plan has been certified either by a Professional Engineer or has been self-certified1 within the past 5 years.

Sources at the facility are identical to those listed in Table 1 in quantity, description, and contents.

All source locations on the plan figures are still accurate compared to what is at the facility (no sources have been added, moved or removed)2.

Inspection forms have been completed at the appropriate interval for all sources as required by the plan, and completed inspection forms are kept going back a minimum of 3 years.

Elevators are being inspected routinely by a third party contractor

Campus-owned transformers have had their annual inspection and maintenance

All oil-handling personnel have received annual SPCC training, and there is documentation of the training on file.

1. University of Wisconsin-Oshkosh is a qualified facility, which allows them to have the option to self-certify the SPCC Plan.

2. The facility’s SPCC Plan must be amended when there is a change in the facility design, construction, operation, or maintenance that materially affects its potential for discharge as described in 40 CFR 112.1(b). Examples of changes that may require amendment of the SPCC Plan include, but are not limited to: commissioning or decommissioning containers; replacement, reconstruction, or movement of containers; reconstruction, replacement, or installation of piping systems; construction or demolition that might alter secondary containment structures; changes of product or service; or revision of standard operation or maintenance procedures at a facility.

Reviewer Name: Date Reviewed:

ATTACHMENT H Spill Incident Report

Spill/Discovery Date: Time:

Facility Name: University of Wisconsin-Oshkosh

Facility Location: 800 Algoma Boulevard, Oshkosh, Wisconsin 54901

Name of Reporting Individual: Telephone #:

Spill Location/Area Description:

Type of Material Spilled: Estimated total quantity discharged:

Gallons/Barrels

Source of the Spill: Media Affected:

Soil

Water (specify)

Other (specify)

Actions Taken:

Damage or Injuries? Evacuation Needed?

No Yes (specify) No Yes (specify)

Organizations and Individuals Contacted:

For imminent danger spills (Fire Dept./911) Time:

UW-System Environmental Health Specialist (Needed for non-incidental and imminent danger spills)

Time:

City of Oshkosh Wastewater Utility Time:

Cleanup contractor (specify) Time:

State Agency (specify) Time:

Other (specify) Time: *Upon filing this report, include any supporting documentation (photos, sketches, other field notes)

Campus Emergency Coordinator (CEC): Chuck Hermes, Director of Operations and Maintenance Facilities Work: 920-424-3466 / Cell: 920-420-6734

Alternate CEC: JoAnn Rife, Grounds Supervisor Work: 920-424-3466 / Cell: 920-420-0172

Marisa Trapp, UW-System Environmental Health Specialist Work: 608-262-5656 / Cell: 608-354-8575

Other Phone Numbers for Emergency Coordinator Use Only: Wisconsin State Spill Reporting Hotline 800-943-0003 EPA Region 5 Hotline 800-621-8431 National Response Center 800-424-8802 City of Oshkosh Wastewater Utility 920-236-5000

Other Phone Numbers: Chem-Tel 800-255-3924 RCRA Hotline 800-424-9346

Cleanup Contractor-Petroleum and Hazardous Materials: North Shore Environmental Construction, Inc. (Germantown, WI) 877-707-6732

SPILL

Take safety precautions to stop,

stabilize, and contain the spill

DONE

What level is the spill?

Secure the site

Select appropriate PPE based on SDS

Does the spill involve a release to the environment?*

Notify CEC or Alt. CEC (CEC/Alt. CEC to notify UW-System EH&S)

Notify appropriate agencies (for oil-related spills - see

Sections 3.1/3.2 of SPCC Plan)**

YES NO

*For oil spills only, the following conditions are considered releases to the environment: • The oil spill threatens public health, welfare or

the environment. • The oil spill produces a sheen on water and/or

threatens navigable waters. • The oil spill is 1 gallon or more of flammable

liquid (e.g., gasoline) onto unpaved ground. • The oil spill is 5 gallons or more of combustible

liquid (e.g., diesel) onto unpaved ground.

** Note: It is preferred that UW-System EH&S conducts this coordination; however, if EH&S is not readily available, the CEC or designee will complete the required notifications.

Call 911

Incidental (typically <1 gallon)

Non-Incidental (typically 1-20 gallons) Imminent Danger

Clean up spill and properly dispose of cleanup materials

Select appropriate PPE based on SDS. Take safety precautions to stop, stabilize, and contain the spill.

DONE

Clean up spill and properly dispose of cleanup materials

During cleanup activities, collect info to complete Spill Incident Report. ● Photographs ● Sketches ● Times ● Actions taken

Contact spill contractor to help respond to the spill

Does Spill Responder in consultation with CEC determine the spill

scenario is within available cleanup capabilities and is SAFE to respond?

ATTACHMENT I

Spill Response Flow Chart University of Wisconsin-Oshkosh

Complete all required internal documentation (for oil-related spills – Attachments H, J, and K of SPCC Plan)

YES

NO

Spill Response Criteria Incidental Spills Non-Incidental Spills Imminent Danger Spills

• The spill is small, less than 1 gallon.

• The spill can be easily contained. • The spill is unlikely to reach a

navigable waterway, storm sewer, or sanitary drain.

• Cleanup procedures do not pose a health or safety hazard.

• Proper response equipment is available for a safe cleanup.

• Responding personnel have completed annual spill training.

• Responding personnel are comfortable with cleaning up the spill.

• The spill is large enough to spread beyond the immediate area (generally 1 to 20 gallons in size).

• Spill may reach a navigable waterway, storm sewer, or sanitary drain.

• Spill may require special equipment or training to clean up.

• If facility personnel address the spill, responding personnel have completed annual SPCC training.

• If responding personnel are not comfortable cleaning up the spill, use a third party contractor.

• Based on the assessment of the fuel delivery driver or trained UW-Oshkosh oil handling employee(s), the spill poses an immediate hazard to human health or the environment.

• There is danger of fire or explosion (e.g. a spill of greater than one-gallon of gasoline).

• Spill involves injury to personnel. • The spill has reached a navigable

waterway, storm sewer, or sanitary drain.

• The spill cannot be contained.

Response by facility personnel possible Response requires coordination with CEC or Alternate CEC

Requires response by the Oshkosh Fire Department –

Call 911

ATTACHMENT J

Spill Reporting Compliance Documentation Log University of Wisconsin-Oshkosh

Spill Date: Description:

Immediate (Oral) Notification

Agency Phone Number

Time/Date Contacted

Incident No.

Person Contacted/Title

CEC Initials

WDNR Spill Reporting Hotline

800-943-0003

Environmental Protection Agency Region 5

800-621-8431

National Response Center

800-424-8802

City of Oshkosh Wastewater Utility

920-236-5000

Follow-Up (Written) Notification

Agency Date Report Mailed

Incident No.

CEC Initials Notes

Environmental Protection Agency Region 5

WDNR (as needed)

National Response Center (as needed)

CEC – Campus Emergency Coordinator

ATTACHMENT K

Oil Spill Disposal Record University of Wisconsin-Oshkosh

Date Volume of Oil Recovered

Recovered Oil Disposal Method* Signature

*Indicate whether oil was recycled, returned to stock, or shipped off site for disposal. If shipped off site for disposal, indicate to what site the recovered oil was shipped.

ATTACHMENT M

Plan Amendment Certification University of Wisconsin-Oshkosh

If major changes to the facility have occurred since the last review, the SPCC Plan is to be updated and amended. Examples of changes that may require amendment of the SPCC Plan include, but are not limited to: commissioning or decommissioning containers; replacement, reconstruction, or movement of containers; reconstruction, replacement, or installation of piping systems; construction or demolition that might alter secondary containment structures; changes of product or service; or revision of standard operation or maintenance procedures at a facility.

For this facility, the plan amendment will be completed by:

• Professional Engineer for non-“qualified facilities” (see page v)

I am familiar with the Spill Prevention, Control, and Countermeasures provisions and I have visited and examined the facility. I attest and certify the technical amendments to the plan were prepared in accordance with good engineering practices, in consideration of industry standards, that procedures for required inspections and testing have been established, and that the amendments are adequate for the facility.

Review Date

Description of Technical

Amendment

Name and Signature of Person Certifying this

Amendment

PE Registration Stamp (if applicable)

MANAGEMENT APPROVAL This SPCC Plan amendment is fully approved by the director and has been implemented as described herein.

Name (please type or print)

Signature

Title Date

Environmental Consulting & Contracting · 2019-12-06 · Environmental Consulting & Contracting...

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Transcript of Environmental Consulting & Contracting · 2019-12-06 · Environmental Consulting & Contracting...