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ABOVE GROUND STORAGE TANKS. CUSTOMIZED ENVIRONMENTAL TRAINING. WELCOME. INSTRUCTOR. Insert Instructor Name Here. OBJECTIVES. Define Above Ground Storage Tanks (ASTs) Discuss the Components of Above Ground Storage Tank Management Plans. Discuss Field-Erected Tanks.

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slide1

ABOVE GROUND STORAGE TANKS

CUSTOMIZED ENVIRONMENTAL

TRAINING

WELCOME

slide2

INSTRUCTOR

Insert Instructor Name Here

slide3

OBJECTIVES

  • Define Above Ground Storage Tanks (ASTs)
  • Discuss the Components of Above Ground Storage Tank Management Plans.
  • Discuss Field-Erected Tanks.
  • Discuss Spill Prevention Control and Countermeasures.
  • Discuss Facility Response Plans.
  • Discuss What to do When a Spill Occurs.
  • Discuss Reports and Records.
  • Recommend Inspection Items.
  • Discuss Use of Contractors.
slide4

GOALS

  • Understand the Definition of ASTs.
  • Be Familiar With the Components of an Above Ground Storage Tank Management Plan.
  • Understand the Spill Prevention Control and Countermeasures Plans.
  • Understand Facility Response Plans.
  • Understand What to do When a Spill Occurs.
  • Be Familiar With Required Reports and Records.
slide5

BACKGROUND

  • EPA regulates under the Clean Water Act approximately 440, 000 facilities that have one or more above ground storage tanks.
  • Annually, 20,000 oil spills occur that are released to navigable waters.
  • On January 8, 2000 a one million-gallon bulk storage tank experienced a catastrophic structural failure releasing an estimated 882,000 gallons of fertilizer into the Ohio River.
slide6

LEARNERS

  • Supervisors
  • Facility Engineers
  • Maintenance Personnel
  • Department Managers
  • Building Occupants
  • Process Specialists
  • Environmental and Safety Committees
slide7

OVERVIEW

The goal of this course is to provide supervisors with the tools needed to manage above ground storage tanks from leaking. It recommends practical, actions that can be carried out by facility management, maintenance personnel and building occupants. The course will help you to integrate good AST management activities into your existing organization and identify which of your staff have the necessary skills to carry out those activities.

slide8

WHAT THIS COURSE DOES NOT DO

The course is not intended to provide information to install, repair, calibrate equipment or remove ASTs.

Nor is it intended to instruct how to write SPCC or FRP plans. These specialties required training beyond the intended scope of this course. Where this expertise is needed, outside assistance should be solicited.

governing acts for above ground storage tanks
Clean Water Act, Section 311

Resource Conservation Recovery Act (RCRA)

Superfund Amendments Reauthorization Act (SARA), Title III

Oil Pollution Act (OPA) of 1990

Clean Air Act of 1970.

GOVERNING ACTS FOR ABOVE GROUND STORAGE TANKS
fire departments
In many areas of the country, states delegate the regulation of above ground storage tanks to local fire departments.

In regulating ASTs, fire departments often use the Uniform Fire Code, Section 79 and the National Fire and Protection Association (NFPA) Sections 30 and 30A.

AST owners should find out the specific regulating guidance for their state.

FIRE DEPARTMENTS
what is an above ground storage tank
Above ground storage tanks have 90 percent or more of their volume above the surface of the ground. This includes the tank, all connected piping, ancillary equipment, and containment system.

Above ground storage tanks are 110 gallons or greater.

Regulated tanks are tanks that contain petroleum or hazardous substances. (Not water tanks etc.)

During this course, above ground storage tanks will refer to regulated above ground storage tanks.

WHAT IS AN ABOVE GROUND STORAGE TANK?
components of an above ground storage tank management program
Tank and Piping Design and Construction

Spill and Overfill Control

Venting

Tank Location

Secondary Containment

Associated Electrical Equipment

Release Detection and Monitoring

Fire Control/Emergency Equipment

General Requirements

Reporting

Recordkeeping

Training

Inspections/Assessments

COMPONENTS OF AN ABOVE GROUND STORAGE TANK MANAGEMENT PROGRAM
materials
Tanks and piping shall be designed and built in accordance with recognized good engineering standards for the material of construction, and shall be of steel or other noncombustible material.

The material of tank and piping construction shall be compatible with the material to be stored. If an internal protective coating or lining is to be employed, it shall also be compatible with the material to be stored.

Each tank shall be labeled, built, installed, and used within the scope of a nationally recognized standard.

MATERIALS
corrosion protection
Corrosion protection can substantially increase the operating lifetime of the tank, as well as provide an additional level of safety and environmental protection against leaks.

In General

All tanks and piping subject to corrosion shall be properly protected to ensure leaks do not occur.

This includes tanks and piping placed upon the ground, a pad, or any steel, masonry, or concrete foundation or pipe/tank stand, as this is the location at which accelerated corrosion is most likely to occur.

CORROSION PROTECTION
corrosion protection15
Internal Corrosion Protection

If corrosion is anticipated beyond that provided for in the design, additional metal thickness or suitable protective coating or lining shall be provided to compensate for the corrosion loss expected during the design life of the tank and piping.

External Corrosion Protection

All tanks and piping subject to corrosion shall be, at a minimum, coated/painted to prevent corrosion

For bunkered (half-buried) tanks, or tanks and piping in contact with the ground, cathodic protection is required in addition to coating/painting

CORROSION PROTECTION
pumps
Liquid shall not be dispensed from a tank by pressurization of the tank or by gravity flow.

Suction pumps shall be located as close as possible to the operating equipment, since all piping downstream of the pump is considered pressure pumping.

Means shall be provided to prevent the release of liquid by siphon flow.

PUMPS
spill and overfill control
To protect from spills and overfills associated with product transfer to and from the AST system, the following protection methods shall be used:

In General

Tank filling shall not begin until the operator has determined tank ullage (available capacity) based on direct liquid level measurement converted to gallons (or some equivalent method). Tank ullage and the amount transferred to the tank shall be entered into the tank records.

The transfer operator shall be physically present to monitor the entire transfer process.

SPILL AND OVERFILL CONTROL
spill and overfill control18
Tanks 660 gallons or greater:

Fixed or movable equipment is required that will contain the release of product when

i. the transfer hose is detached from the fill pipe

ii. the tank is overfilled

If not equipped with a hand operated nozzle, a check valve and shut off valve must be equipped.

Tanks 660 gallons or greater & placed in service after 1994:

Equipment is required that will automatically shut off flow into the tank when the tank is no more than 95%

Equipment is required that will trigger an audible alarm when the tank is no more than 90% full.

SPILL AND OVERFILL CONTROL
venting
Atmospheric tanks shall be adequately vented to prevent the development of vacuum or pressure which exceeds the design pressure of the tank as a result of filling, emptying, or atmospheric temperature changes.

Normal Venting

Should be in accordance with the American Petroleum Institute Standard No. 2000, Venting Atmospheric and Low-Pressure Storage Tanks, or another accepted standard; OR

Shall be at least as large as the filling or withdrawal connections, whichever is larger, but in no case less than 1.25 inches.

VENTING
venting20
Vents shall be arranged to discharge in such a way as to prevent localized overheating of, or flame impingement on, any part of the tank, in the event vapors from the vents are ignited.

For liquids having a flash point below 73°F and a boiling point below 100°F, a venting device that is normally closed except when venting to pressure or vacuum shall be installed.

All vents shall have a spark arrestor cap.

All vents shall be located "in the clear" at least 12 feet above the ground.

VENTING
emergency relief venting
All tanks shall have some form of construction or device that will relieve excessive internal pressure caused by exposure to fires. The following methods are allowed:

Properly located valves, pipes, or blowout plugs

Weak roof-to-shell seam

Emergency relief venting capacity shall be in accordance with your state's storage tank regulations.

EMERGENCY RELIEF VENTING
tank location
Tanks shall rest on foundations made of concrete, masonry, or steel.

The foundations shall be designed to minimize the possibility of uneven settling of the tank, and to minimize corrosion to any part of the tank resting on the foundation.

TANK LOCATION
tank location23
Tanks and vents shall be located in such a way as to minimize the danger of fire from the following ignition sources:

Open flames

Smoking

Hot surfaces, radiant heat

Cutting and welding

Frictional heat or sparks

Lightning

Static electricity, electrical sparks

Stray currents

TANK LOCATION
tank location24
Tanks shall be located in such a way as to minimize the hazards associated with venting, releases, and fire to:

Buildings and their occupants (minimum distances required)

Other tanks (minimum distances required)

Roadways

Pedestrian walkways

Adjoining property (minimum distances required)

Congested areas

Waterways, streams, and ditches

Tanks shall be anchored, as necessary for stability.

TANK LOCATION
secondary containment
Should there be a catastrophic or undetected AST leak, secondary containment provides added health and environmental protection.

1. Required for all ASTs larger than 110 gallons

2. All secondary containment areas or systems shall be maintained free of accumulations of water, leaves, weeds, flammable materials, tanks or drums, or anything else that may interfere with the containment purpose or visual detection of leaks or spills.

SECONDARY CONTAINMENT
secondary containment26
3. All secondary containment systems shall be:

Impervious to the tank contents for at least 72 hours.

Compatible with the tank contents

Resistant to normal environmental conditions.

Of sufficient strength and durability to resist tearing, cracking, collapsing, etc. for the tank’s lifetime.

Easily maintainable

Can contain 110% of the volume of the tank.

Of sufficient size to contain all critical piping, fittings, and valves.

SECONDARY CONTAINMENT
secondary containment27
4.The following permanent or temporary containment systems are allowed, unless otherwise noted:

Steel catchment basins or spill skids

Masonry or concrete berms

Earthen berms, only when used in conjunction with an appropriate liner or coating

‘Visqueen' or other non-reinforced plastic sheeting with a thickness of 40 mils (0.75mm) or less is NOT appropriate

Secondary containment tanks (i.e. double-walled tanks or concrete encased tanks). These tanks (including associated piping and pumps) are exempt from containing 110% and containing piping and equipment.

SECONDARY CONTAINMENT
associated electrical equipment
All electrical equipment shall be located to minimize the possibility of initiating a fire or electrocution hazard.

All electrical equipment and wiring shall be in accordance with NFPA 70 (National Electrical Code).

An Emergency Power Off (EPO) switch, or other suitable disconnect switch, shall be located near the electrical equipment, and this switch shall be labeled.

All maintenance of the electrical equipment shall be conducted in accordance with the Lockout/Tagout Program.

Provisions shall be made for the control of static electricity at installations where flammable or combustible liquids are transferred or dispensed.

ASSOCIATED ELECTRICAL EQUIPMENT
release detection and monitoring
All tanks shall have a system that provides a method or combination of methods that can detect a release for any portion of the tank. This can be accomplished by the methods listed below:

a. ASTs that are not in contact with the ground or any electrolyte shall be visually inspected at least once per month;

b. For ASTs or their supporting structure in contact with the soil or an electrolyte, a biennial (every two years) leakage test and internal or external visual inspection of the bottom of the tank shall be completed in addition to the monthly inspection noted in (a) above.

RELEASE DETECTION AND MONITORING
release detection and monitoring30
Secondary containment tanks (i.e. double-walled tanks or concrete encased tanks) shall have an interstitial liquid detector (or other positive means of leak detection). The operation of the interstitial leak detector shall be verified at least monthly. Pop-up-type monitors are not subject to the monthly verification.RELEASE DETECTION AND MONITORING
fire control emergency equipment
Permanent Tanks

a. at least one portable standard NREL dry chemical fire extinguisher (minimum 4A60B:C rating) shall be within 25 feet of any tank containing a flammable or combustible liquid

Portable tanks

a. at least one portable fire extinguisher with a minimum 4A60B:C rating shall be within 25 feet of any tank containing a flammable or combustible liquid

b. emergency information (location of nearest telephone, dialing instructions, who to contact, equipment owner/area landlord etc.) shall be placed between 10 and 50 feet from the tank

FIRE CONTROL/EMERGENCY EQUIPMENT
field erected tanks
Tanks that are constructed on-site are considered "field-erected tanks." Regulated field-erected tanks must be internally and externally inspected according to American Petroleum Institute (API) standard 653. These inspections must be performed by a certified API 653 inspector. Most field-erected tanks must be externally inspected every five years and internally inspected every ten years. This inspection cycle may vary depending upon the condition of the AST. FIELD-ERECTED TANKS
spill prevention control and countermeasures
Facilities that meet both of the following conditions must have an SPCC Plan:

1. Own or operate a non-transportation related fixed facility that could be reasonably be expected to discharge oil into or upon navigable waters of the United States and

2. The facility has an above ground storage capability of

More than 660 gallons in a single container, or

A total above ground oil storage capacity of 1,320 gallons, or

A total underground buried storage capacity of more than 42,000 gallons.

SPILL PREVENTION CONTROL AND COUNTERMEASURES
spill prevention control and countermeasures34
SPCC Plans must:

Be kept onsite.

Be certified by a Registered Professional Engineer (PE)

Have full management approval.

Conform with all SPCC requirements in 40 CFR Part 112

Discuss the facility’s spill history.

Discuss spill prediction – (i.e. the direction of flow)

Be reviewed every three years by management.

Be amended when you change the facility and re-certified by a PE.

SPILL PREVENTION CONTROL AND COUNTERMEASURES
facility response plans
Under the Clean Water Act, all owners/operators of oil storage facilities are required to prepare a facility-specific response plan.

This plan, to the maximum extent possible, is for responding to a "worst case discharge" of oil and to the substantial threat of such a discharge to the surrounding environment.

Oil is defined as an oil of any kind or in any form, including, but not limited to, petroleum, fuel oil, sludge, oil refuse, oil mixed with wastes other than dredged spoil.

FACILITY RESPONSE PLANS
facility response plans36
Substantial harm is determined by the amount of storage, type of activities, location and spill history of the facility. If any of the following applies to a facility, then they would be considered to pose substantial harm to the environment.

A facility with a maximum oil storage capacity greater than or equal to 42,000 gallons and operations include over-water transfers of oil to or from vessels.

A facility with a maximum oil storage capacity greater than or equal to one million gallons.

A facility without secondary containment for each above ground storage tank large enough to contain the capacity of the largest above ground storage tank within that storage area.

FACILITY RESPONSE PLANS
facility response plans37
A facility located at a distance such that a discharge from the facility could cause injury to fish, wildlife or the environment.

A facility located at a distance such that a discharge from the facility would shut down a drinking water intake.

A facility that has experienced a reportable spill in the past five years that was greater than or equal to 10,000 gallons.

The U.S. EPA Regional Administrator has discretion to require an FRP from any facility.

FACILITY RESPONSE PLANS
elements of a facility response plan
Cover Sheet

Emergency Response Action Plan

Facility Information

Emergency Response Information

Hazard evaluation

Spill scenario discussion

Discharge detection systems information

Plan implementation information

Facility self-inspection checklists

Diagrams for the site plan and the drainage plan

Security systems description

ELEMENTS OF A FACILITY RESPONSE PLAN
facility response plans39
Facility Response Plans are to be submitted to your area’s EPA Facility Response Plan coordinator.

Each time there is a material change at an FRP facility, the facility must resubmit their plan for approval within 60 days.

Examples of material changes include:

- A significant change in facility capacity, configuration or type of oil handled;

- A change in the capacity or availability of response contractors; or

- A change in spill prevention equipment or response procedures that may affect the potential for a discharge.

FACILITY RESPONSE PLANS
general requirements
1. All tanks shall have a sign stating the tank contents and shall be marked in accordance with NFPA 704, Identification of Fire Hazards of Materials (commonly referred to as the "Diamond Hazard Rating" or "Hazardous Materials Classification Diamond")

2. Access to tank interiors are subject to the facility’s Confined Space Entry Program

3. Safe Operating Procedures or other written operating procedures shall be developed for all permanent tank operations.

GENERAL REQUIREMENTS
general requirements41
4. During tank filling activities, the delivery vehicle shall be separated from the tank by at least 15 feet.

5. All tanks, machinery, and piping shall be grounded.

6. Means shall be provided to protect tank systems from vandalism to the greatest extent practicable (i.e. all fill and withdrawal openings that can be opened without hand tools shall be locked).

7. Spill control equipment such as booms, pads, and absorbents shall be provided by the tank operator, located near the tank, and available at all times.

GENERAL REQUIREMENTS
if a spill occurs
Be sure to record the following about the incident:

Date, time, location and type of an incident;

Name, quantity and source of material involved;

Cause of an incident and name of the party involved with the incident;

Measures taken to contain and cleanup the spill;

Quantity and disposition of material resulting from cleanup;

Measures taken to prevent recurrence.

Severity and geographic area affected;

IF A SPILL OCCURS
spill information to report to epa
Name of the facility;

Name(s) of the owner or operator of the facility;

Location of the facility;

Date and year of initial facility operation;

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

Description of the facility, including maps, flow diagrams and topographical maps;

The cause(s) of such spill(s), including a failure analysis of the system or subsystem in which the failure occurred;

Corrective actions and/or countermeasures taken,

A copy of the SPCC Plan and any other information pertinent to the Plan or the spill(s).

SPILL INFORMATION TO REPORT TO EPA
reporting
1. Releases

The National Response Center is the sole federal point of contact for reporting oil and chemical spills.

If you have a spill to report, contact them at 1-800-424-8802or for those without 800 access, contact them at (202) 267-2675.

REPORTING
reporting45
2. New Tanks

An application shall be submitted to and approved by the regulatory agency prior to construction or operation of tanks over 110 gallons.

3. Existing Tanks

Modifications to tanks greater than 110 gallons which alter their type, location, capacity, or contents shall be registered with the regulatory agency.

REPORTING
reporting46
4. Change in Service Type

The following service types are designated for all AST's.

i. In Service—currently in use, all recordkeeping requirements apply

ii. Out-of-Service—less than 90 days, tank shall be empty, all recordkeeping requirements apply.

iii. Out-of-Service—more than 90 days but less than 12 months.

iv. Temporary Closure—less than 24 months, tank must be empty, additional requirements apply.

v. Permanent Closure—tank will no longer be used, tank must be empty.

vi. Change-in-Service

REPORTING
recordkeeping
Recordkeeping

1. Permits/Registrations/Plans

a. A Spill Prevention Control and Countermeasure Plan (SPCC) shall be prepared and implemented when the total storage capacity of the site exceeds 1320 gallons, or when any single tank exceeds 660 gallons. This Program shall be written and implemented in accordance with 40 CFR 112.

b. Tank registration records issued by the regulatory agency shall be retained until tank closure.

c. A copy of all As-Built drawings and schematics for all tanks. These drawing should be retained for five years or the life of the tank, whichever is longer.

RECORDKEEPING
recordkeeping48
Recordkeeping

2. Monthly Monitoring/Inspection

A monthly monitoring record shall be maintained for each AST. This record shall be completed and maintained by the facility responsible for the tank, and retained for a minimum of one year.

RECORDKEEPING
recordkeeping49
Recordkeeping

3. Modifications/Repairs

Amended tank drawings or a synopsis of modifications or repairs to tanks and their associated equipment shall be retained by the facility. These documents should be retained for five years or the life of the tank, whichever is longer.

RECORDKEEPING
recordkeeping50
Recordkeeping

4. Ullage Records

Records to document that tank ullage (available capacity) was properly checked prior to filling tanks shall be maintained. These records shall be completed and maintained by the owning organization responsible for the tank, and retained for a minimum of six months.

RECORDKEEPING
recordkeeping51
Recordkeeping

5. Change-in-Service Records

Records showing the history of each AST (indicating class (based on flash point of the material) and type of product stored) and all changes-in-service shall be maintained by the facility and retained for a minimum of two years.

RECORDKEEPING
training
All persons supervising and operating tank system equipment must receive appropriate training in the following areas:

1. product transfer operations

2. emergency response procedures

3. release detection equipment

4. safety mechanisms

5. fire control equipment

6. normal and emergency operating procedures

7. inspection procedures

TRAINING
recommended inspection items
The following are recommended checklist items for your AST’s monthy inspection:

Corrrosion Protection controls present and in good operating condition (e.g. paint, cathodic protection).

Tank, piping, pumps, and valves inspected for signs of corrosion, damage, and failure (e.g. leaks). Inspect fill area, dispensing area, and under tank.

Spill and Overfill Protection controls present and in good operating condition (e.g. reservoirs, catchment basins for use during tank filling).

RECOMMENDED INSPECTION ITEMS
recommended inspection items54
4. Overfill Prevention equipment present and in good operating condition (e.g. automatic alarms or shutoff equipment).

5. Normal vent present and in good operating condition.

6. Vapor Recovery equipment present and in good operating condition.

7. Secondary Containment system present and in good operating condition.

RECOMMENDED INSPECTION ITEMS
recommended inspection items55
8. Secondary Containment system free of tank product or other liquids/debris (e.g. rainwater, snowmelt, dirt, leaves, trash, stored materials)

9. Electrical equipment and static controls present and in good operating condition

10. Has interstitial monitor been tested within the last month?

RECOMMENDED INSPECTION ITEMS
recommended inspection items56
11. Release Detection and Monitoring equipment present and in good operating condition. Has interstitial monitor been tested within the last month.

12. Fire Control and Emergency equipment present and in good operating condition (e.g. fire extinguisher, phone, fire alarm, spill control equipment).

13. Tank Operation and Security: have all appropriate tank valves and equipment been properly configured, secured, and/or locked.

RECOMMENDED INSPECTION ITEMS
recommended inspection items57
14. Signage present.

15. Concrete surfaces and ground free from any evidence of leakage or spillage.

16. Written operating instructions present.

RECOMMENDED INSPECTION ITEMS
slide58

TIPS FOR USING CONTRACTORS

  • Remember, You Control Your Facility or Area!
  • Review Procedures With Them Before Starting the Job!
  • Ensure They Are Properly Trained!
  • Determine Their Environmental Compliance Record!
  • Determine Who Is in Charge of Their People!
  • Determine How They Will Affect Your Facility’s Environmental Compliance!
slide59

ELEMENTS OF A SUCCESSFUL

AST PROGRAM

  • DETAILED WRITTEN AST INSPECTION GUIDELINES.
  • 2. DETAILED WRITTEN AST BEST MANAGEMENT PRACTICES.
  • 3. EXTENSIVE EMPLOYEE TRAINING PROGRAMS
  • 4. PERIODIC REINFORCEMENT OF TRAINING
  • 5. SUFFICIENT DISCIPLINE REGARDING IMPLEMENTATION
  • 6. PERIODIC FOLLOW-UP
slide60

THE IMPORTANCE OF A

CLEAN ENVIRONMENT

“I would ask all of us to remember that protecting our environment is about protecting where we live and how we live. Let us join together to protect our health, our economy, and our communities -- so all of us and our children and our grandchildren can enjoy a healthy and a prosperous life.”

Carol Browner Former EPA Administrator