everything you wanted to know about tanks but were afraid to ask aboveground storage tank systems
TRANSCRIPT
Everything You Wanted to Know About Tanks
But Were Afraid to Ask
Aboveground Storage Tank Systems
Outline
• Introduction• Spill Prevention Control
and Countermeasure (SPCC) Plans
• Facility Response Plans (OPA-90)
• Stormwater Pollution Prevention Plans (SWP3)
Oil Pollution Prevention Regulatory History
• Promulgated by EPA in 1973• Revisions proposed in 1991,
1993, 1997• Final rule effective on August
16, 2002• Two amendments December
12, 2005– Streamlining– Extends Compliance
Dates
• One amendment effective December 26, 2006
2002 Rule Changes
• Exempts only completely buried storage tanks subject to all of the technical requirements of the UST regulations (40 CFR Parts 280 or 281)
• Exempts portions of certain facilities or any facility used exclusively for wastewater treatment
• Establishes a de minimis container size of 55 gallons • Establishes an aboveground storage capacity threshold of greater than
1,320 gallons and removes the 660 gallon threshold • Revises the trigger for submitting information on spills at SPCC
regulated facilities to EPA• Allows deviations from most rule provisions when equivalent
environmental protection is provided• Flexible plan format, but requires a cross-reference • Clarifies rule applicability to the storage and operational use of oil
Regulatory Overview40 CFR 112.7 requires • Facility Diagram -- 40 CFR 112.7(a)(3) • Trajectory Analysis -- 40 CFR 112.7(b) • Secondary Containment -- 40 CFR
112.7(c) • Contingency Plans -- 40 CFR 112.7(d) • Inspection, Tests, and Records -- 40
CFR 112.7(e) • Personnel Training and Discharge
Prevention Procedures -- 40 CFR 112.7(f)
• Security (excluding production facilities) -- 40 CFR 112.7(g)
• Facility Tank Car and Tank Truck Loading/Unloading Racks (excluding offshore facilities) -- 40 CFR 112.7(h)
• Field-constructed Aboveground Containers - Brittle Fracture Evaluation -- 40 CFR 112.7(i)
• 40 CFR 112.8 requires spill prevention and control measures specific to the different types of oil facilities or operations, including:
• Onshore Facility Drainage (excluding production facilities) -- 40 CFR 112.8(b)
• Facility Transfer Operations, Pumping, and Facility Process (excluding production facilities) -- 40 CFR 112.8(d)
• Onshore Bulk Storage Containers (excluding production facilities) -- 40 CFR 112.8(e)
40 C.F.R. § 112
• Spill Prevention Requirements 40 § CFR 112.1-112.12– Spill Prevention
Control and Countermeasure (SPCC) Plans
• Spill Response Requirements– Facility Response Plans
(FRP or OPA-90) 40 CFR § 112.20-112.21
40 C.F.R. § 112.7-112.12
• Spill Prevention Control and Countermeasure (SPCC) Plan – Facility Diagram– Inventory– Discharge Prevention
Measures– Discharge or Drainage
Controls– Countermeasures– Disposal for Recovered
Material– Contact Numbers
40 C.F.R. § 112.7-112.12
• SPCC Plan - Continued– PE Certification– Secondary
Containment– Integrity testing– Inspections– Training– Plan Updates
40CFR § 112.7-112.12 Covers
SPCC Plans• Any owner/operator of a non-
transportation onshore or offshore facility engaged in the following activities with oil which due to location could discharge to waters:
• Storing• Processing• Transferring• Distributing• Using• Consuming oil/oil products
40CFR § 112.2 Covers
• Facility:– Small as one tank– Large as a military
base– Boundaries of facility
depend on: Ownership Activities on site Responsibility for
response
40CFR§112.1-112.3 Doesn’t Cover
SPCC Plans • Facilities with USTs that contain 42,000 gallons or
less of oil• Facilities with aggregate AST storage capacity of
1,320 gallons or less of oil.• Any container with a storage capacity of less than 55
gallons• Underground storage tanks (USTs) subject to part 40
CFR 280 and 281 • Any facility which is used exclusively for wastewater
treatment
SPCC Flow Chart
Noncompliance Issues
OVERALL • Plan not developed• Inspections not conducted• Spill response equipment not
maintained• No training
FEDERAL FACILITIES• Tenants not covered• Maintenance &
housekeeping • No assigned responsibility
for inspections and testing• No controls on drain valves• Use of mobile/portable tanks• Lack of spill reporting
procedures
SPCC Violations – H&M Oil Site, 2001
The H & M Oil, Inc., Triangle site located in Pocatello, Idaho.
• Three vertical above ground storage tanks (ASTs), drums, and a portable storage container containing waste oil, water, and sludge. The AST capacity ranges from 8,000 to 12,000 gallons.
• Located 200 yards from Portneuf River. Feeds directly to a reservoir.
• Drinking water intakes approximately 1 mile from site.
• No AST maintenance and inspection.
• Soil staining• Unrestricted access • No secondary containment • Spills to gravel and dirt
SPCC Plan Elements Part 1
• Facility Diagram• Inventory of Oil Types and Capacity• Discharge Prevention Measures• Discharge or Drainage Controls• Spill Countermeasures • Disposal of Recovered Material• Contact Numbers
Facility Diagram
Inventory
• Include all oil storage at facility in storage containers of 55 gallons and greater
• Record the amount stored, the storage capacity, and its location
• Update the inventory as changes occur and have a PE recertify the plan
Discharge Prevention Measures
• Provide Employee Training! #1
• Describe spill prevention equipment (i.e., leak detection systems, secondary containment)
• Describe plans for inspection and maintenance
Not a recommended spill prevention measure
Discharge or Drainage Controls
• Includes:– Oil water separators– Ditches– Levies– Berms– Retention Ponds– Curbs
Spill Countermeasures
• Describe the equipment at your facility such as:– Industrial absorbent– Pigs– Oil booms– Plugs– Pans
• Describe the steps in the spill response procedure
Disposal/Contact Numbers
• Outline the plan for disposal of used absorbent material in the Plan
• Identify the contractor (s) who will be disposing of material
• Determine Federal, State, and local requirements for disposal (if any)
• Federal, State, and Local emergency numbers (National Response Center
1- 800-424-8802)• Ambulance and hospital
numbers• Spill cleanup
contractors
SPCC Plan Elements Part 2
• PE Certification
• Secondary Containment
• Integrity testing
• Inspections
• Training
• Security
• Plan Updates
PE Certification
• PE may use an agent• PE must review the agent’s
work• PE Certification statement
more specific• PE not required for non-
technical amendments• State laws may preclude a
PE not registered in the state from certifying
1. Familiar with requirements of SPCC rule
2. He or his agent have visited and examined the facility.
3. The Plan has been prepared in accordance with good engineering practice including consideration of applicable industry standards.
4. Procedures for required inspections and testing have been established.
5. The Plan is adequate for the facility
Secondary Containment
• Secondary containment must hold contents of largest single container in containment unit plus allowance for accumulated precipitation, if applicable.
• 55 gallon drums must have secondary containment.
• Double walled ASTs with interstitial monitoring systems are considered acceptable secondary containment.
Environmental Equivalence• Allows facilities to implement alternate measures based on
site-specific considerations:– Security
– Facility drainage
– Corrosion protection and leak testing of completely buried metallic storage tanks
– Overfill prevention
– Piping
– Evaluation, inspection, and testing
• Measures must provide equivalent environmental protection, in accordance with good engineering practice and as determined by a Professional Engineer.
Impracticability Determinations
• Documentation needed
• Detail on impracticability determinations for certain areas:
– Piping and flowlines
– Transfer areas
– Oil-filled Equipment
– Loading/unloading racks
– Onshore bulk storage containers
– Mobile/portable containers
Tank Integrity Testing
• ASTs require:– Integrity testing on a regular schedule– Integrity testing when material repairs are done– Visual inspection must be combined with another
testing technique such as: ultrasonic, radiographic, acoustic emissions, hydrostatic, or other nondestructive testing method.
– Integrity testing may include leak testing
• Type of integrity testing and inspections must consider applicable industry standards.
Training
• Required for Oil-handling employees only• Conducted annually• Training includes:
– Spill control equipment– Emergency procedures– Laws, rules, regulations– General facility operations– The plan
Security/Plan Updates
• Requires fencing and locks or guard entrances for unattended facilities
• If fencing is impractical, explain. Provide equivalent environmental protection
• Plan must be reviewed at least once every 5 years
• Upon review if changes have occurred which effect plan, plan must be amended within 6 months of review
Summary
• Determine whether you are required to have a plan
• If so, prepare one• Conduct training
annually• Maintain adequate spill
response materials on site
• Update the Plan• Inspect equipment and
your facility regularly
Problems Today
The Issues
• Converting USTs to ASTs– Greater oil storage
capacity– Greater number of
ASTs– Greater annual
throughput
= Higher Risk of Spills
• Complying with SPCC regulations– Reduces number of
spills, spill volume, and amount of oil migrating offsite
What’s Aboveground?
Industry StandardsSHOP BUILT TANKS
Steel Tank Institute SP-001 Standard for Inspection of Aboveground Storage Tanks
Underwriters Laboratory (UL) Standard 142 Steel Aboveground Tanks for Flammable and Combustible Liquids
National Fire Protection Association (NFPA) Code 30A Automotive and Marine Service Station Code, Chapters 1 and 2
National Fire Protection Association (NFPA) Code 30 Flammable and Combustible Liquids Code, Chapter Two
FIELD ERECTED TANKS
American Petroleum Institute (API) Standard 620 Design and Construction of Large, Welded, Low-Pressure Storage Tanks
API Standard 650 Welded Steel Tanks for Oil Storage
API Recommended Practice 651 Cathodic Protection of ASTs
API Recommended Practice 652 Lining AST Tank Bottoms
API Standard 653 Tank Inspection, Repair, Alteration, and Reconstruction
API Recommended Practice 920 Prevention of Brittle Fracture
API Standard 2015 Safe Entry and Cleaning of Tank
API Recommended Practice 2350 Overfill Protection for Petroleum Tanks
API Standard 2610 Design, Construction, Operation and Maintenance and Inspection of Terminal and Tank Facilities
Corrosion
• Uniform• Localized• Microbial Influenced• Galvanic• Erosion• Environmentally
Assisted Cracking
Tank Testing
• Hydrostatic• Radiographic• Ultrasonic Thickness• Acoustic• For Large ASTs
– Robotic applications– Vacuum– Magnetic Flux
Vents and Piping
Good Condition
Factory Built Emergency Vents
Leaking Dispenser Piping
Rubber Piping
Valving and Level Monitoring
Secondary Containment Valves
Clock Face Gauge
Top Causes of Overfills
• Training• Tank size restrictions• Inaudible alarm• Incompatible equipment • Dependent alarms• Lines improperly marked• Multiple tanks on common
fill port• Poor inventory
reconciliation• Not familiar with location• Filling entire tank
Operator Inattention!
Key Concepts
• Checking, testing and maintaining Equipment.
• Doing routine preventative Actions.
• Keeping good Records.• Training for proper
Response.
40 C.F.R. § 112.20-112.21
• Spill Prevention Requirements– Spill Prevention Control
and Countermeasure (SPCC) Plans
• Spill Response Requirements– Facility Response
Plans (FRP or OPA-90)
C-I Attachment FRP Flow Chart
D o e s th e fa cility t ra n s fe r o il o v e rwa te r to o r f ro m v e s s e ls a n d do e sth e fa cility h a v e a to ta l o il s to ra g eca pa city g re a te r th a n o r e qu a l to
4 2 ,0 0 0 g a llo n s ?
S u b m it R es p on s e P lan
D o e s th e fa cility h a v e a to ta lo il s to ra g e ca pa city g re a te rth a n o r e qu a l to 1 m illio n
g a llo n s ?
N o S u b m ittal of R es p on s e P lanE x cep t at R A D is cretion
W ith in a n y a bo v e g ro u n d s to ra g e ta n k a re a ,do e s th e fa cility la ck s e co n da ry co n ta in m e n t
th a t is s u f f icie n t ly la rg e to co n ta in th eca pa city o f th e la rg e s t a bo v e g ro u n d o il s to ra g e
ta n k plu s s u f f ic ie n t f re e bo a rd to a ll fo rpre cipita t io n ?
I s th e fa cility lo ca te d a t a dis ta n ces u ch th a t th e dis ch a rg e fro m th efa cility co u ld ca u s e in ju ry to f is h
a n d wildlif e a n d s e n s it iv ee n v iro n m e n ts ?
I s th e fa cility lo ca te d a dis ta n ces u ch th a t a dis ch a rg e fro m th e
fa cility wo u ld s h u t do wn a pu blicdrin k in g wa te r in ta k e ?
H a s th e fa cility e x pe rie n ce d are po rta ble o il s pill in a n a m o u n tg re a te r th a n o r e qu a l to 1 0 ,0 0 0g a llo n s with in th e la s t 5 y e a rs ?
Y e s
Y e sY e s
Y e s
Y e s
Y e s
No
No
No
No
No
No
F lo w ch a rt o f C riteria fo r S u b sta n tia l H a rm
40 CFR § 112.20 Covers
FRP (OPA-90)• Conduct over water transfers
of oil and have a capacity of 42,000 gallons or greater
OR
• Total oil storage capacity of one million gallons or more
AND• Inadequate secondary
containment• Could impact fish, wildlife or
sensitive environments• Could shut down drinking
water intakes• Reportable spill greater than
10,000 gallons within the past 5 years
Regulatory Requirements at a Complex
What is a Complex?• Some facilities must meet the
requirements of two or more federal agencies, because they engage in activities that fall under the jurisdiction of those agencies.
Who is Responsible for Regulating?• EPA is responsible for non-
transportation- related facilities located landward of the
• The Minerals Management Service of the Department of the Interior handles offshore non-transportation-related facilities located seaward of the coastline, including certain pipelines.
• The USCG under DOT is responsible for deepwater ports and transportation-related facilities located landward of the coastline.
Case Study on Multiple Agency Responsibility
O P S jurisd iction extends to pressure influencing device w hich affects operating pressure of the m ain p ipeline.
Pum p Valve
Product
Tank 2
(Storage) &
(Breakout)
M ARINE LO ADING DO CK 1 2T he tank depicted is used for
storage associated w ith the MT R facility and is under EP A jurisd iction. If tank is also usedas a breakout tank it is subject to both O P S and E P A jurisd iction.
Marine T ransportatio n— R elated Facility (MT R) is defined in 33 CFR 154.1020. T his segm ent of a com plex is under CG jurisd ictio n for the purposes of C W A Section 311(j).
CG Jurisd ictio n
DO T /O PS Jurisd iction 3
3E P A Jurisd iction
Joint E PA-O P S Jurisd ictio n3
40 C.F.R. § 112.20
• Facility Response Plan (FRP) – Emergency Response
Action Plan– Facility name, type,
location, owner– Emergency notification
information– Potential Discharges – Discharge detection
procedures
40 C.F.R. § 112.20
• Facility Response Plan (FRP) – Plans for containment
and disposal – Facility Inspection Plan– Training– Facility Diagrams of
facility – Security Measures
Critical Regulatory Aspects
• Emergency Response Action Plan
– Hazard identification
– Vulnerability analysis
– Planning distance calculation
– Worst case discharge scenario
– Equipment deployment and
– NOAA environmentally sensitive environment maps
http://response.restoration.noaa.gov/esi/esiintro.html
FRP Requirements
• Maintain copy of plan at facility and revisions
• Log response training drills and exercises 40 CFR § 112.21
• Record inspections• Review annually• Make changes, submit revisions within
60 days to EPA
Things To Know
• SPCC plans and FRP are federal programs.• Additional federal oil spill plans are Vessel
Response Plans and Shipboard Oil Pollution Emergency Plans .
• States may have their own versions of these regulations and plans but do not enforce the federal programs.
• State and federal plans can be combined as an Integrated Contingency Plan (ICP).
40 CFR 110.6Spill Reporting Requirements
• Any person in charge of a vessel or of an onshore facility shall as soon as he or she has knowledge of any discharge of oil … IMMEDIATELY notify the National Response Center (40 CFR 110.6)
800-424-8802
EPA Information and EPA Information and HotlinesHotlines
National ResponseNational ResponseCenter (NRC): 800-424-8802Center (NRC): 800-424-8802
NCP Product Schedule NCP Product Schedule Information: 202-260-2342Information: 202-260-2342
For SPCC, FRP, & OPA For SPCC, FRP, & OPA Information: 800-424-9346Information: 800-424-9346
800-424-8802
www.epa.www.epa.gov/oilspillgov/oilspill
www.epa.gov/oilspillwww.epa.gov/oilspill
Region 2 and 9 EPA ContactsRegion 2
For questions or clarifications on the SPCC or FRP Rules, call or
email:
Christopher Jimenez, SPCC Coordinator
Arlene Anderson, FRP Coordinator732-906-6803
Region 9For questions or clarifications on
the SPCC Rule, call or email:Pete Reich
OrMark Calhoon415-972-3090
Elizabeth M Cox415-972-3044
Storm Water Pollution Prevention Plans (SWP3)
Storm Water Pollution Prevention Plans (SWP3)
Clean Water Act Regulatory History
• Amended 1987 • National Pollution
Discharge System (NPDES) established November 6, 1990.
• NPDES consists of Phase I and II regulations
NPDES Storm Water Program
• Phase I – Medium and Large
municipal separate storm water
– Sewer systems (MS4s) in communities with populations greater then 100,000
– Construction activities disturbing greater then 5 acres
– Certain SIC codes
• Phase II– Certain small municipal
separate storm sewer systems (MS4s)
– Construction activity disturbing between 1 and 5 acres
Federal Facilities
Vehicle Maintenance Facilities!!!
Fueling Loading/Unloading to
USTs or ASTs Vehicle/Equipment
Washing Handling fuels, oils or
chemicals DemonstrationDemonstration
SWP3 Elements
•Annual Compliance Report•Spill Response/ Procedures
•Descriptions of Oil Storage •Maps•Stormwater BMPs•Employee Training•Inspections•Certifications /Amendments•Monitoring Requirements
P2 Team/Training
• Pollution Prevention Team – Environmental
Manager– Maintenance
Technicians/Operators
• Employee Training
DemonstrationDemonstration
Stormwater BMPs
• Structural BMPs• Non Structural
BMPs• Procedural BMPs
http://www.bmpdatabase.org/
Inspections
• Exteriors of ASTs and oil storage containers
• Spill response equipment
• Secondary containment
• Transfer areas
Comprehensive Site Compliance Evaluation
• Annual Compliance Inspection– Inspection results– Changes to facility’s
operations/activities– Data comparison– New BMPs/corrective
measures– Previous year’s
information
Spill Response
• Identify source• Take Action! Stop the spill• Immediately secure the spill
area • If the material is flammable,
remove all sources of ignition
• Collect used spill material in a covered DOT approved container
• Date, label, and staged in a secure area
• Determine appropriate disposal method and contact waste hauler
Spill Notification
• Name, location, organization, and telephone number
• Name and address of responsible party
• Date and time of incident
• Location of the incident
• Source/cause of release
• What was spilled and the quantity?
• Danger or toxicity posed by the release/spill?
• Any injuries? How many?
• Weather conditions• Other information
Spill Notification
Contact the National Response Center (NRC),
at 1-800-424-8802 24 hours a day
See SWP3 for state and local contacts
SWP3 Summary
• Applies to federal facility vehicle maintenance facilities
• Major components of the SWPPP are:
– Pollution prevention team; – Site map; – Description of potential
pollutant sources; – Measures and controls for
stormwater management; and – Comprehensive site compliance
evaluation. • Must be updated when facility
operations/activities change
• Best Judgment Required!
Key Concepts
• Develop SWP3• Conduct inspections• Implement BMPs• Train annually• Update annually
Other Federal AST Regulations
Other Federal AST Regulations
• New Source Performance Standards (NSPS)
• Resource Conservation and Recovery Act (RCRA), Subpart J
• RCRA Subparts AA, BB, CC
• Clean Air Act – Highway Rule
NSPS
Tank Capacity Vapor Pressure Requirements
> 40, 00 gallons
68 mm Hg – 570 mm Hg
Floating Roof
>570 mm Hg Vapor Recovery System
10.3 kPA – 76.7 kPA External Floating Roof OR Fixed Roof With Internal Floating Type Cover OR Vapor Recovery System
10,566 – 19,813 gallons
- Keep records only
RCRA 264/265, Subpart J
• Hazardous Waste Tanks– Proper installation,
operation and inspection
– Integrity of primary containment system
– Monitoring for leaks– Response to releases– Proper closure and
post-closure
Subpart J Additional Elements
• Corrosion Protection• Vaults• Secondary containment for ancillary
equipment• Spill control equipment (e.g., check
valves, freeboard)• Inspections• Waste analysis and trial tests
RCRA, Subparts AA, BB, CC
• AA, BB – Emissions from Process Vents Associated with Hazardous Waste
• CC – Organic Air Emission from Large Quantity Generators and Treatment, Storage and Disposal Facilities
Diesel Fuel Content
• 15 ppm sulfur required – June 2006
• 2007 Heavy Duty Diesel exhaust standards
Summary
• Limit VOLs emissions from ASTs
• Specific Regulations for Hazardous Waste Tanks and Their Emissions
• Diesel Fuel Sulfur Content Reduced