SPCC Plan 9.10 by suchenfz



      Morehead State University
     Office of Environmental Health &Safety
            Support Services Complex
           Morehead, Kentucky 40351
              Phone: (606) 783-9022


      Agnes R. Manley, Compliance Officer
                          SPCC COMPLIANCE CHECKLIST

The Morehead State University facility includes areas of oil storage, handling and usage where spill
containment structures and other spill prevention and control methods are not in place, or are
inadequate. It is MSU’s responsibility to implement quick and effective action to prevent adverse
effects on human health and the environment from any spill event and to install effective spill
containment structures where feasible.

The following checklist details actions that are required to be implemented to validate this SPCC
Plan. As each deficiency is satisfied, the date of completion and any pertinent comments should
be noted.

David A. Edward, PE, Micah Group

                                                                    Action Taken     Completion
       Required Action                       Location
                                                                      by MSU           Date
Spill kits made available        Rice Bldg, ETGC, DAC, TT
Rollover Berm
                                 Rice Bldg Fueling Station
Bollard Posts
Spill Pallet                     Rice Bldg Maintenance Garage
Rollover Berm (01 & 02)
Dedicated Spill Kit (01 & 02)    ADUC - ARWO01
Pipe Cap (01 & 02)               Alumni Tower – ARWO02
Emergency storm sewer drain
cover (01)
                                 Secondary Containment Tanks
Lock Draining Caps                                                                  DAC
                                 ETFT01 & 02
Closable Valves                                                                     10/22/10
                                 DACFT01, 02, & 03
Maintain Records Office of EHS                                     Integrated
                                 Downing Hall Room 110                              9/27/10
(Inspections, training, etc.)                                      into Plan
Fuel Management Storage Plan     SBGCFT01                          Integrated       9/27/10
25 Year 24 Hour Rainfall Event   DACFT01 & 02                      into Plan        Page 7; 5.0
                                 DAC & ETGC Employee, 8-hour
OSHA Emergency Responder
                                 EHS Personnel, 40-hour

All current and former checklists will be maintained for a period of three years at the MSU
Office of Environmental Health & Safety.

SPCC Plan/EHS                                    2                                  August 2010
SPCC Plan/EHS   3   August 2010
        3. A harmful quantity of oil is discharged into or upon US navigable waters, defined by
           40 CFR 110 as a quantity that:

                a) Violates applicable water quality standards, or
                b) Causes a film or sheen upon or discoloration of the surface of the water or
                   adjoining shorelines or causes a sludge or emulsion to be deposited beneath the
                   surface of the water or upon adjoining shorelines.

        Spill information will be reported to USEPA and KY Division of Waste Management
        within 60 days if the above thresholds are reached. The report will contain the following

                1.    Name of the facility;
                2.    Name(s) of the owner or operator of the facility;
                3.    Location of the facility;
                4.    Cause of the spill(s);
                5.    Corrective actions and/or countermeasures taken including adequate
                      description of equipment repairs and/or replacements;
                6.    Information the regional administrator may reasonably require pertinent to the
                      plan or spill event;
                7.    Date and year of initial facility operation;
                8.    Maximum storage or handling;
                9.    Description of the facility, including maps, flow diagrams, and topographical
                10.   Failure analysis of the system and sub-system in which the failure occurred;
                11.   A complete copy of the SPCC plan with any amendments; and
                12.   Additional measures taken (preventative) or contemplated to minimize the
                      possibility of recurrence.

The SPCC plan will be amended within six months whenever there is a change in facility design,
construction, operation, or maintenance that materially affects the facility's spill potential. The plan
will be reviewed once every five years and amended to include more effective prevention and
control technology, if such technology will significantly reduce the likelihood of a spill event and
has been proven in the field.

SPCC Plan/EHS                                      4                                   August 2010
                    2.0 SPCC Plan Review - 40 CFR 112.5(b)

Morehead State University will complete a review and evaluation of the SPCC plan at least once
every five years. The reviews will be documented below.

Signature                                       Date

__________________________________              __________________________________

__________________________________              __________________________________

__________________________________              __________________________________

__________________________________              __________________________________

__________________________________              __________________________________

                        3.0 Past Spill History - 40 CFR 112.7(a)

   Date              Description of Spill           Corrective Actions    Plan for Prevention
                                                         Taken                Recurrence
1974-2010 No known harmful quantities of oil
          have been discharged to navigable

SPCC Plan/EHS                                  5                                 August 2010
                        4.0 Facility Information – 40 CFR 112.7

The following is site-specific information employing the format in 40 CFR 112.7 for onshore non-
transportation facilities, which due to their location could reasonably be expected to discharge oil
in harmful quantities, as defined in 40 CFR 112.40 CFR 110, into or upon navigable waters of the
United States. Due to the University’s proximity to Triplett Creek on the main campus and
Brushy Creek at the University Farm and the oil products stored at both locations the University is
required to prepare a Spill Prevention Control and Countermeasure Plan (hereinafter “SPCC
Plan”) in writing and in accordance with 40 CFR 112.7.

     Morehead State University

     State of Kentucky
     University President: Dr. Wayne Andrews

Facility Location
        Morehead, KY

Date/Year of Initial Operation

       For 120 years Morehead State University has operated in Morehead, KY where it began in
       October of 1887.

Facility Description

The Morehead State University main campus is a public educational and research institution
consisting of several buildings situated on approximately 325 acres within the city of Morehead in
Rowan County, Kentucky. The site is bordered by the City of Morehead on three sides and
backed by hills to the north. There are walkways connecting the buildings to each other, and a
large underground tunnel system for the distribution of utilities. The primary sources of power for
the main campus are electricity and steam. The University’s Heating Facility generates steam
utilizing two coal fired boilers and one natural gas boiler. Six emergency generators utilizing oil
and requiring oil tanks are located near buildings on the Main Campus (MC) to provide backup
power in case of a loss of electrical power from Kentucky Utilities.

In addition to the main campus (MC), there are other properties owned and utilized by Morehead
State University for research, academic, and agricultural purposes. These properties are also
located in Rowan County, KY. This SPCC Plan covers all above ground fuel tanks (FT) and ≥55
gallon drums, also tanks that supply emergency generators (G) and fire pumps (FP), waste oil
(WO) collection tanks, transformer (TR) and elevator (EL) oil, and gasoline and diesel fuel storage
tanks located on the main campus, at the Derrickson Agricultural Complex (DAC), Triangle
Tower (TT), ARAMARK Food Services (AR) and Eagle Trace and Sunny Brook Golf Courses
(ETGC & SBGC). See Appendix B, Facility Diagrams and Appendix C, Tank Photos.

SPCC Plan/EHS                                    6                                  August 2010
Fuel and Waste Oil Storage
MSU has 24 fuel and waste oil tanks, with above ground storage capacity of 10,950 gallons. The
daily throughput for MCFT01 and 02 is 135 gallons of gas and 68 gallons of diesel respectively.
ETFT 01 and 02 have an average throughput of 20 gallons per day. Daily average usage
(throughput) for tanks DACFT01, 02, and 03 run from 16.5 gallons per day for FT01, three
gallons per day (FT02), and twelve gallons per day for FT03. Fire pumps and generators are filled
as needed to maintain the required volume and daily throughput is considered negligible. See
Appendix D for a complete list of tanks, tank ID, tank capacity, oil type and tank location.

Electrical Transformer Oil Storage
MSU has 24 transformers with oil capacity of a total of 5,071gallons. See Appendix I for a
complete list of tanks, tank ID, tank capacity, type of oil contained and tank location.

Elevator - Hydraulic Tank Oil Storage
MSU has 19 oil tanks containing hydraulic oil with a total capacity of 1,305 gallons. See Appendix
J for a complete list of tanks, tank ID, tank capacity, type of oil contained and tank location.

In-Plant Treatment: None

5.0 Potential Spill Volumes and Rates, Trajectory Analysis – 40 CFR 112.7(b)

Morehead State University has identified twenty-one (21) fuel tanks, three waste oil tanks, twenty-
four (24) transformer tanks, and nineteen (19) elevator tanks which are being addressed under this
SPCC plan. The tanks vary from 55 gallon elevator tanks, 100-gallon tanks used to fuel fire
pumps and generators to a 3,000-gallon tank used for fueling vehicles. These tanks are widely
dispersed over the Main Campus, the Golf Course, and the Farm. Because of the diversity of the
sites where the tanks are located the overall potential spill volume and rate is very hard to evaluate,
see Appendix E, I, and J for tank locations. Therefore each tank has been evaluated individually
and assigned a ranking based on potential risk.

The risk rankings were determined based on the condition of each tank, the adequacy of
secondary containment, the potential for drainage to an unprotected drain or waterway, and
whether the University had the man power and equipment readily available to respond to a spill.
Also, utilizing 110% containment tank capacity criteria and the 25 year 24 hour precipitation event
for the area (4.8 inches) an oil storage management control approach has been implemented to
limit the fuel stored in SBFT01 and DACFT01 and 02 to approximately 80% capacity.

The following table outlines specific criteria used to assign tank ranking. A tank was considered
low risk if it met all low-risk criteria and high risk if it met any one or more of the high-risk
criteria. After evaluating each tank, it was determined that each tank has a low risk ranking.

SPCC Plan/EHS                                      7                                  August 2010
5.0 Potential Spill Volumes and Rates, Trajectory Analysis – 40 CFR 112.7(b)
Table. 1
                                              Drains to               Man Power and
  Risk            Tank        Secondary
                                           Unprotected Drain         Equipment Readily
 Ranking        Condition    Containment
                                             or Waterway                 Available
    Low          Good            Yes             No                        Yes
    High         Poor            No              Yes                       No

      6.0 Containment and Diversionary Structures – 40 CFR 112.7 (c) (1)

All fuel, waste oil, generator and fire pump tanks have secondary containment, either by double
walled tank system or holding reservoir capable of containing the required volume or overflow
from a leak or spill. Most transformer and elevator oil storage systems are housed within secured
areas and many have curbing that is capable of containment.

                 7.0 Demonstration of Practicability – 40 CFR 112.7(d)

The Morehead State University Office of Environmental Health and Safety has determined that
use of containment and/or readily available man power and equipment to prevent discharged oil
from reaching navigable waters is practical and effective at this facility.

                            8.0 Facility Drainage – 40 CFR 112.8(b)

   See the Storm Drainage System Map for Main Campus tank locations (Appendix B, I, and J).
   Drainage from the 3,000 and 2000 gallon fuel tanks is restrained by valves kept in the closed
    position to prevent a spill or other excessive leakage of oil into the campus’ drainage system.
   There are no diked areas or valves used for the drainage of diked areas at the main campus or
    outlying properties.
   There are no engineered plant drainage systems from undiked areas of the Facility.
   There are no in plant drainage ditches that can be equipped with a diversion system.
   The drainage waters from the facility are not treated by any means that require pumping

SPCC Plan/EHS                                    8                                  August 2010
                     8.0 Facility Drainage – 40 CFR 112.8(b) cont.

   In the event of a spill from a tank, the oil will be contained with secondary containment.
   If a spill occurs during transfer or in a manner that cannot be contained by secondary
    containment nearby drains will be protected.

                       9.0 Bulk Storage Tanks – 40 CFR 112.7(c)
   Bulk storage tanks are compatible with the oil contained and conditions of storage.
   Bulk storage tanks (FT, WO, G, and FP) have secondary containment in place.
   Each bulk tank, excepting generator tanks, is equipped with level gauges to prevent tank
   All above ground storage tanks are inspected on a monthly basis (see Appendix F - Facility
    Monthly Spill Source Check List).
   All outfalls from campus are monitored monthly.
   Oil leaks which could result in a loss of oil from tank seams, gaskets, rivets, and bolts are
    promptly corrected and any materials contaminated from such leaks are promptly removed.
   There are no partially buried tanks at the University and none will be installed in the future.

    10.0 Transfer Operations, Pumping and In-Plant Processes and General
                   Requirements– 40 CFR 112.8(d) & 112.7(i)
   There is no buried piping installed at Morehead State University and no future buried piping is
   All aboveground valves, piping, and appurtenances are inspected regularly. The general
    condition of items, such as flange joints, expansion joints, valves, catch pans, pipeline
    supports, locking valves and metal surfaces is assessed.
   Future pipe supports will be properly designed to minimize abrasion and corrosion and allow
    for expansion and contraction.
   If a field-constructed aboveground container undergoes a repair, alteration, reconstruction, or
    a change in service that might affect the risk of a discharge or failure due to brittle fracture or
    other catastrophe, or has discharged oil or failed due to brittle fracture failure or other
    catastrophe, the container will be evaluated for risk of discharge or failure due to brittle
    fracture or other catastrophe, and as necessary, appropriate action will be taken.

SPCC Plan/EHS                                      9                                   August 2010
11.0 Tank Car and Tank Truck Loading/Unloading Rack – 40 CFR 112.7 (h)

All oil is delivered to the point of storage by tank trucks. The tank trucks are contracted and
operated by independent vendors who are responsible for ensuring their operations are performed
in accordance with applicable local, state and federal regulations. Oil vendors are responsible for
cleaning up any spills caused by their delivery operations. See Appendix G for Tank Truck
Delivery guidelines.

                   12.0 Inspections and Records – 40 CFR 112.7 (e)

   Inspections consist of a complete walk through of the tank area to check for security
    problems, tank damage or leakage and stained or discolored ground surfaces.
   All bulk storage tanks are inspected monthly. Generator and fire pump tanks are inspected
    and tank information recorded as they are exercised weekly.
   Annual inspections of all tanks are performed by Environmental Health and Safety personnel
    using the check list in Appendix D. These inspections are signed by the inspector and
    maintained in the Office of Environmental Health and Safety, 212 Downing Hall, for three
   All records relevant to this SPCC plan (including training records) are to be submitted to and
    maintained in the Office of Environmental Health and Safety.

                            13.0 Security – 40 CFR 112.7 (e)(9)

   Master flow control valves are locked in the closed position when in non-operating or non-
    standby status.
   Transformer and elevator tanks housed indoors are located in secured areas.
   Facility lighting is commensurate with the type and location of each storage tank. Tank
    locations have sufficient lighting to enable the discovery of spills during hours of darkness by
    operating personnel and by non-operating personnel, and to prevent spills occurring through
    acts of vandalism.
   The Morehead State University Police perform regular patrols on the Main Campus.

SPCC Plan/EHS                                    10                                  August 2010
    14.0 Personnel, Training, and Spill Prevention Procedures – 40 CFR 112.7

   Facility personnel are instructed by management in the operation and maintenance of oil
    pollution prevention equipment and pollution control laws and regulations.
   Agnes Manley, Compliance Officer is accountable for oil spill prevention at Morehead State
   Annual spill prevention briefings are provided by the Office of Environmental Health and
    Safety for operating personnel to ensure adequate understanding of the SPCC plan. These
    briefings highlight any past spill events or failures and recently developed precautionary
   Training is held on oil spill prevention, containment, and retrieval methods. Records of these
    briefings and spill prevention training are kept on file at the Office of Environmental Health
    and Safety (See Appendix K).
   Instructions and phone numbers regarding the reporting of a spill to the National Response
    Center and the KY Division of Water are listed in Section 15.0 and are posted in the Rice
    Building, Facilities Management, Derrickson Agricultural Complex Shop/Maintenance
    Building, and Eagle Trace Golf Course Maintenance Building.
   Signs are required to be posted at all tanks listing emergency contacts in the event of an oil
    release. See Appendix H for response, cleanup and disposal procedures.

                15.0 Waste Disposal Procedures – 40 CFR 112.7 (a)(3)(v)

   Wastes resulting from minor spill response will be containerized in impervious bags, drums or
    buckets. The waste will be removed from the site by a licensed waste hauler.

   Wastes resulting from a major spill response will be removed and disposed of by Micah Group,
    Environmental Contracting, 746 Westland Drive, Suite 110, Lexington, KY 40504.

SPCC Plan/EHS                                   11                                 August 2010
         16.0 Oil Spill Emergency Contact List – 40 CFR 112.7 (a)(3)(vi)
University Police:
(606) 783-2035

Office of Environmental Health & Safety
Harry Gunn (606) 783-2179, Alternate No. (606) 783-2018, After Hours (606) 207-0629
Jeff Barker (606) 783-2584, After Hours (606) 776-3669
Agnes Manley (606) 783-9022

Facilities Management
Main Number (606) 783-2066
Director: Gene Caudill
        Office (606) 783-5264
        Home (606) 784-7437
        Cell (606) 776-3665
Alternate: Todd Thacker
        Office (606) 783-5277
        Home (606) 784-3812
        Cell (606) 776-3666

Derrickson Agricultural Complex
Farm Manager: Joseph Fraley
       Office (606) 783-2802
       Cell (606) 356-5025
Alternate: Michael Padula
       Cell (606) 783-2326

Eagle Trace Golf Course
Superintendent: Rian Brown
       Office (606) 784-8591
       Cell (606) 776-6682
Alternate: Justin Brown, Business Manager
       Office (606) 783-9973
       Cell (606) 776-6495

Kentucky Division of Water
(859) 564-3410 (within 2 hours of oil entering surface water and if 10 gallons or more spilled on

Kentucky Division of Waste Management Phone: (502) 564-6716

National Response Center (NRC)
(800) 424-8802 (within 2 hours of oil entering surface water, including wetlands, storm
water and sanitary sewers)

SPCC Plan/EHS                                   12                                  August 2010
                            PLAN DISTRIBUTION LIST

Office of Environmental Health & Safety
       606 West Main Street
       Morehead, KY 40351

Facilities Management
        Rice Building, UPO 0831
        Morehead State University
        Morehead, KY 40351

Morehead State University Police
     Laughlin Health Building 100
     Morehead, KY 40351

University Farm
      DAC UPO 0995
      Morehead State University
      Morehead, KY 40351

Eagle Trace Golf Course
      1275 Eagle Drive
      Morehead, KY 40351

SPCC Plan/EHS                             13         August 2010
                MSU SPCC Plan-Regulation Cross Reference Table

In accordance with the revised SPCC Rule, the following cross-reference table is provided to
identify the location of each element for compliance with the revised standard.

Final SPCC Rule                          Description of Section                             Page
                    General requirements for SPCC Plans for all facilities and all oil
§ 112.7                                                                                      1-10
                    General requirements; discussion of facility’s conformance with
                    rule requirements; deviations from Plan requirements; facility
§ 112.7(a)                                                                                   1-10
                    characteristics that must be described in the Plan; spill reporting
                    information in the Plan; emergency procedures.
§ 112.7(b)          Fault analysis.                                                            6
§ 112.7(c)          Secondary containment.                                                     8
§ 112.7(d)          Contingency planning.                                                      7
§ 112.7(e)          Inspections, tests, and records.                                           9
§ 112.7(f)          Employee training and discharge prevention. 112.7(e)(10)                  10
§ 112.7(g)          Security (excluding oil production facilities).112.7(e)(9)                 9
§ 112.7(h)          Loading/unloading (excluding offshore facilities).                         9
§ 112.7(i)          Brittle fracture evaluation requirements.                                  8
§ 112.7(j)          Conformance with State requirements.                                       2
§ 112.8             Requirements for onshore facilities (excluding production
§ 112.12            facilities).
§ 112.8(a)
                    General and specific requirements.                                       1-10
§ 112.12(a)
§ 112.8(b)
                    Facility drainage.                                                         7
§ 112.12(b)
§ 112.8(c)
                    Bulk storage containers.                                                   8
§ 112.12(c)
§ 112.8(d)
                    Facility transfer operations, pumping, and facility process.               8
§ 112.12(d)
§ 112.9
                    Requirement for onshore production facilities.                           N/A
§ 112.13
§ 112.9(a)
                    General and specific requirements.                                       N/A
§ 112.13(a)
§ 112.9(b)
                    Oil production facility drainage.                                        N/A
§ 112.13(b)
§ 112.9(c)
                    Oil production facility bulk storage containers.                         N/A
§ 112.13(c)
§ 112.9(d)
                    Facility transfer operations, oil production facility.                   N/A
§ 112.13(d)
§ 112.10
                    Requirements for onshore oil drilling and workover facilities.           N/A
§ 112.14
§ 112.10(a)
                    General and specific requirements.                                        2-3
§ 112.14(a)

SPCC Plan/EHS                                        14                                   August 2010
                    SPCC Rule Cross Reference - continued

Final SPCC Rule                        Description of Section                           Page
§ 112.10(b)
                  Mobile facilities.                                                     N/A
§ 112.14(b)
§ 112.10(c)
                  Secondary containment – catchment basins or diversion structures.      N/A
§ 112.14(c)
§ 112.10(d)
                  Blowout prevention (BOP).                                              N/A
§ 112.14(d)
§ 112.11          Requirement for offshore oil drilling, production, or workover
§ 112.15          facilities.
§ 112.11(a)
                  General and specific requirements.                                     N/A
§ 112.15(a)
§ 112.11(b)
                  Facility drainage.                                                     N/A
§ 112.15(b)
§ 112.11(c)
                  Sump systems.                                                          N/A
§ 112.15(c)
§ 112.11(d)
                  Discharge prevention systems for separators and treaters.              N/A
§ 112.15(d)
§ 112.11(e)
                  Atmospheric storage or surge containers; alarms.                       N/A
§ 112.15(e)
§ 112.11(f)
                  Pressure containers; alarm systems.                                    N/A
§ 112.15(f)
§ 112.11(g)
                  Corrosion protection.                                                  N/A
§ 112.15(g)
§ 112.11(h)
                  Pollution prevention system procedures.                                N/A
§ 112.15(h)
§ 112.11(i)
                  Pollution prevention systems; testing and inspection.                  N/A
§ 112.15(i)
§ 112.11(j)
                  Surface and subsurface well shut-in valves and devices.                N/A
§ 112.15(j)
§ 112.11(k)
                  Blowout prevention.                                                    N/A
§ 112.15(k)
§ 112.11(l)
                  Manifolds                                                              N/A
§ 112.15(l)
§ 112.11(m)
                  Flowlines, pressure sensing devices.                                   N/A
§ 112.15(m)
§ 112.11(n)
                  Piping; corrosion protection.                                          N/A
§ 112.15(n)
§ 112.11(o)
                  Sub-marine piping’s environmental stresses.                            N/A
§ 112.15(o)
§ 112.11(p)
                  Inspections of sub-marine piping.                                      N/A
§ 112.15(p)

SPCC Plan/EHS                                     15                                  August 2010

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