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 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
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 • 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
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 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
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 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 • 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
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 • PE Certification • Secondary Containment • Integrity testing • Inspections • Training • Security • Plan Updates
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 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 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
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 • 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
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 The Issues
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 Leaking Dispenser Piping Factory Built Emergency Vents Rubber Piping
Valving and Level Monitoring Clock Face Gauge Secondary Containment Valves
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)
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 40 CFR § 112.20 Covers
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. Regulatory Requirements at a Complex
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).