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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).

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Everything you wanted to know about tanks but were afraid to ask

Everything You Wanted to Know About Tanks But Were Afraid to Ask

Aboveground Storage Tank Systems


Outline
Outline

  • Introduction

  • Spill Prevention Control and Countermeasure (SPCC) Plans

  • Facility Response Plans (OPA-90)

  • Stormwater Pollution Prevention Plans (SWP3)


Oil pollution prevention regulatory history
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
2002 Rule Changes

  • Exempts onlycompletely 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 overview

40 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)

Regulatory Overview


40 c f r 112
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
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 7 112 121
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
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
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
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



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

Noncompliance Issues


Spcc violations h m oil site 2001
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
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



Inventory
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
Discharge Prevention Measures

Not a recommended spill prevention measure

  • Provide Employee Training! #1

  • Describe spill prevention equipment (i.e., leak detection systems, secondary containment)

  • Describe plans for inspection and maintenance


Discharge or drainage controls
Discharge or Drainage Controls

  • Includes:

    • Oil water separators

    • Ditches

    • Levies

    • Berms

    • Retention Ponds

    • Curbs


Spill countermeasures
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

Disposal/Contact Numbers


Spcc plan elements part 2
SPCC Plan Elements Part 2 the Plan

  • PE Certification

  • Secondary Containment

  • Integrity testing

  • Inspections

  • Training

  • Security

  • Plan Updates


Pe certification

PE may use an agent the Plan

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

Familiar with requirements of SPCC rule

He or his agent have visited and examined the facility.

The Plan has been prepared in accordance with good engineering practice including consideration of applicable industry standards.

Procedures for required inspections and testing have been established.

The Plan is adequate for the facility

PE Certification


Secondary containment
Secondary Containment the Plan

  • 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
Environmental Equivalence the Plan

  • 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
Impracticability Determinations the Plan

  • 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
Tank Integrity Testing the Plan

  • 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
Training the Plan

  • 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

Security/Plan Updates


Summary
Summary facilities

  • 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 facilities


The issues

Converting USTs to ASTs facilities

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

The Issues



Industry standards
Industry Standards facilities


Corrosion
Corrosion facilities

  • Uniform

  • Localized

  • Microbial Influenced

  • Galvanic

  • Erosion

  • Environmentally Assisted Cracking


Tank testing
Tank Testing facilities

  • Hydrostatic

  • Radiographic

  • Ultrasonic Thickness

  • Acoustic

  • For Large ASTs

    • Robotic applications

    • Vacuum

    • Magnetic Flux


Vents and piping
Vents and Piping facilities

Good Condition

Leaking Dispenser Piping

Factory Built Emergency Vents

Rubber Piping


Valving and level monitoring
Valving and Level Monitoring facilities

Clock Face Gauge

Secondary Containment Valves


Top causes of overfills
Top Causes of Overfills facilities

  • 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
Key Concepts facilities

  • Checking, testing and maintaining Equipment.

  • Doing routine preventative Actions.

  • Keeping good Records.

  • Training for proper Response.


40 c f r 112 20 112 21
40 C.F.R. § 112.20-112.21 facilities

  • 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
C-I Attachment facilitiesFRP Flow Chart


40 cfr 112 20 covers

FRP (OPA-90) facilities

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

40 CFR § 112.20 Covers


Regulatory requirements at a complex

What is a Complex? facilities

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.

Regulatory Requirements at a Complex


40 c f r 112 20
40 C.F.R. § 112.20 facilities

  • 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 112 201
40 C.F.R. § 112.20 facilities

  • Facility Response Plan (FRP)

    • Plans for containment and disposal

    • Facility Inspection Plan

    • Training

    • Facility Diagrams of facility

    • Security Measures


Critical regulatory aspects
Critical Regulatory Aspects facilities

  • 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
FRP Requirements facilities

  • 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
Things To Know facilities

  • 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 6 spill reporting requirements
40 CFR 110.6 facilitiesSpill 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


800-424-8802 facilities

www.epa.gov/oilspill

EPA Information and Hotlines

  • National ResponseCenter (NRC): 800-424-8802

  • NCP Product Schedule Information: 202-260-2342

  • For SPCC, FRP, & OPA Information: 800-424-9346

www.epa.gov/oilspill

[email protected]


Region 2 and 9 epa contacts

Region 2 facilities

For questions or clarifications on the SPCC or FRP Rules, call or email:

Christopher Jimenez, SPCC Coordinator

732-906-6847

[email protected]

Arlene Anderson, FRP Coordinator

732-906-6803

[email protected]

Region 9For questions or clarifications on the SPCC Rule, call or email:

Pete Reich

415-972-3052

[email protected]

Or

Mark Calhoon

415-972-3090

[email protected]

Or

Elizabeth M Cox

415-972-3044

[email protected]

Region 2 and 9 EPA Contacts


Storm water pollution prevention plans swp3

Storm Water Pollution Prevention Plans (SWP3) facilities

Storm Water Pollution Prevention Plans (SWP3)


Clean water act regulatory history
Clean Water Act facilities 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 facilities

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

NPDES Storm Water Program


Federal facilities
Federal Facilities facilities

  • Vehicle Maintenance Facilities!!!

  • Fueling

  • Loading/Unloading to USTs or ASTs

  • Vehicle/Equipment Washing

  • Handling fuels, oils or chemicals

Demonstration


Swp3 elements
SWP3 Elements facilities

  • Descriptions of Oil

  • Storage

  • Maps

  • Stormwater BMPs

  • Employee Training

  • Inspections

  • Certifications

  • /Amendments

  • Monitoring

  • Requirements

  • Annual Compliance

  • Report

  • Spill Response/

  • Procedures


P2 team training
P2 Team/Training facilities

  • Pollution Prevention Team

    • Environmental Manager

    • Maintenance Technicians/

      Operators

  • Employee Training

Demonstration


Stormwater bmps
Stormwater BMPs facilities

  • Structural BMPs

  • Non Structural BMPs

  • Procedural BMPs

    http://www.bmpdatabase.org/


Inspections
Inspections facilities

  • Exteriors of ASTs and oil storage containers

  • Spill response equipment

  • Secondary containment

  • Transfer areas


Comprehensive site compliance evaluation
Comprehensive Site Compliance Evaluation facilities

  • Annual Compliance Inspection

    • Inspection results

    • Changes to facility’s operations/activities

    • Data comparison

    • New BMPs/corrective measures

    • Previous year’s information


Spill response
Spill Response facilities

  • 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 facilities

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


Spill notification1
Spill Notification facilities

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 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!

SWP3 Summary


Key concepts1
Key Concepts facilities

  • Develop SWP3

  • Conduct inspections

  • Implement BMPs

  • Train annually

  • Update annually



Other federal ast regulations
Other Federal AST Regulations facilities

  • New Source Performance Standards (NSPS)

  • Resource Conservation and Recovery Act (RCRA), Subpart J

  • RCRA Subparts AA, BB, CC

  • Clean Air Act – Highway Rule


NSPS facilities


Rcra 264 265 subpart j
RCRA 264/265, Subpart J facilities

  • 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
Subpart J Additional Elements facilities

  • 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
RCRA, Subparts AA, BB, CC facilities

  • 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
Diesel Fuel Content facilities

  • 15 ppm sulfur required – June 2006

  • 2007 Heavy Duty Diesel exhaust standards


Summary1
Summary facilities

  • Limit VOLs emissions from ASTs

  • Specific Regulations for Hazardous Waste Tanks and Their Emissions

  • Diesel Fuel Sulfur Content Reduced


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