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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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Aboveground Storage Tank Systems
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 § CFR 112.1-112.12
40 CFR § 112.20-112.21
Plan not developed
Inspections not conducted
Spill response equipment not maintained
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 proceduresNoncompliance Issues
The H & M Oil, Inc., Triangle site located in Pocatello, Idaho.
Not a recommended spill prevention measure
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
Ambulance and hospital numbers
Spill cleanup contractorsDisposal/Contact Numbers
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 facilityPE Certification
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 reviewSecurity/Plan Updates
Leaking Dispenser Piping
Factory Built Emergency Vents
Clock Face Gauge
Secondary Containment Valves
Conduct over water transfers of oil and have a capacity of 42,000 gallons or greater
Total oil storage capacity of one million gallons or more
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 years40 CFR § 112.20 Covers
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
For questions or clarifications on the SPCC or FRP Rules, call or email:
Christopher Jimenez, SPCC Coordinator
Arlene Anderson, FRP Coordinator
Region 9For questions or clarifications on the SPCC Rule, call or email:
Elizabeth M Cox
415-972-3044Region 2 and 9 EPA Contacts
Storm Water Pollution Prevention Plans (SWP3)
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
Certain small municipal separate storm sewer systems (MS4s)
Construction activity disturbing between 1 and 5 acresNPDES Storm Water Program
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?
Other informationSpill Notification
Contact the National Response Center (NRC),
at 1-800-424-8802 24 hours a day
See SWP3 for state and local contacts
Major components of the SWPPP are:
Pollution prevention team;
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