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 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)

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 nontransportation 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

40CFR112.1-112.3 Doesnt 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

Not a recommended spill prevention measure

Discharge Prevention Measures

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

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 agents work PE Certification statement more specific PE not required for nontechnical 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

Complying with SPCC regulations

Reduces number of spills, spill volume, and amount of oil migrating offsite

= Higher Risk of Spills

Whats Aboveground?

Industry Standards
SHOP 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 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)

C-I Attachment FRP Flow Chart

F lo w c h a r t o f C r ite r ia fo r S u b s ta n tia l H a r m
D w t h c o e s t h e f a c ilit y t r a n s f e r a te r to o r fr o m v e s s e ls a e f a c ilit y h a v e a t o t a l o il a p a c ity g r e a te r th a n o r e 4 2 ,0 0 0 g a llo n s ? N o o il n d s t q u o v e r d o e s o r a g e a l t o Y e s

S u b m it R e s p o n s e P la n

D o e s t h e f a c ilit y h a v e a t o t a l o il s to r a g e c a p a c ity g r e a te r th a n o r e q u a l t o 1 m illio n g a llo n s ?

Y e s

W it h in a n y a b o v e g r o d o e s t h e fa c ilit y la c k t h a t is s u f f ic ie n t ly c a p a c it y o f t h e la r g e s t t a n k p lu s s u ff ic ie n p r e c ip

u n d s to r a g e ta n k a r e a , s e c o n d a r y c o n t a in m e n t la r g e t o c o n ta in th e a b o v e g r o u n d o il s t o r a g e t f r e e b o a r d t o a ll f o r it a t io n ?

Y e s

N o I s t h e s u c h f a c ili a f a c ilit y lo c a t e d a t a d is t a n c e t h a t t h e d is c h a r g e fr o m th e t y c o u ld c a u s e in ju r y t o f is h n d w ild lif e a n d s e n s it iv e e n v ir o n m e n ts ? N o

Y e s

N o

I s t h e f a c ilit y lo c a t e d a d is t a n c e s u c h th a t a d is c h a r g e fr o m th e f a c ilit y w o u ld s h u t d o w n a p u b lic d r in k in g w a t e r in t a k e ?

Y e s

N o

H a s t h e f a c ilit y e x p e r ie n c e d a r e p o r ta b le o il s p ill in a n a m o u n t g r e a t e r th a n o r e q u a l to 1 0 ,0 0 0 g a llo n s w it h in t h e la s t 5 y e a r s ?

Y e s

N o

N o S u b m itta l o f R e s p o n s e P la n E x c e p t a t R A D is c r e tio n

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.
C a s eS tu d yo nM u ltip le A g e n c yR e s p o n s ib ility
O P S ju r is d i c t i o n e x t e n d s t o p r e s s u r e in flu e n c in g d e v ic e w h ic h a ff e c ts o p e r a tin g p r e s s u r e o f t h e m a i n p ip e li n e .

P ro d u c t Tank2
Pum p V a lv e

(S to ra g e ) & (B r e a k o u t)

Who is Responsible for Regulating? EPA is responsible for nontransportation- related facilities located landward of the The Minerals Management Service of the Department of the Interior handles offshore nontransportation-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.

M A R IN E L O A D IN G D O C K

T h e t a n k d e p ic t e d is u s e d f o r s t o r a g e a s s o c ia t e d w it h t h e M T R fa c ilit y a n d is u n d e r E P A j u r i s d i c t io n . If t a n k i s a ls o u s e d a s a b r e a k o u t t a n k i t is s u b je c t t o b o t h O P S a n d E P A j u r i s d i c t io n .

M a ri n e T r a n s p o r ta tio n R e la t e d F a c i l it y ( M T R ) i s d e f i n e d in 3 3 C F R 1 5 4 .1 0 2 0 . T h is s e g m e n t o f a c o m p le x is u n d e r C G j u r is d ic t io n fo r t h e p u r p o s e s o f C W A S e c t i o n 3 1 1 ( j) .

C G J u r is d ic tio n D O T / O P S J u r i s d i c t io n
3E 3

P A J u ris d ic tio n
3

J o in t E P A - O P S J u r is d ic tio n

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 110.6 Spill 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 Hotlines

800-424-8802

National Response Center (NRC): 800-424-8802 NCP Product Schedule Information: 202-260-2342

www.epa. gov/oilspill

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

www.epa.gov/oilspill oilinfo@epamail.epa.gov

Region 2 and 9 EPA Contacts

Region 2 For questions or clarifications on the SPCC or FRP Rules, call or email: Christopher Jimenez, SPCC Coordinator 732-906-6847 Jimenez.christopher@epa.gov Arlene Anderson, FRP Coordinator 732-906-6803 Anderson.arlene@epa.gov Region 9 For questions or clarifications on the SPCC Rule, call or email: Pete Reich 415-972-3052 Reich.peter@epa.gov Or Mark Calhoon 415-972-3090 Calhoon.mark@epa.gov Or Elizabeth M Cox 415-972-3044 Cox.elizabethm@epa.gov

Storm StormWater WaterPollution Pollution Prevention PreventionPlans Plans(SWP3) (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

Demonstration

SWP3 Elements
Descriptions of Oil Storage Maps Stormwater BMPs Employee Training Inspections Certifications /Amendments Monitoring Requirements Annual Compliance Report Spill Response/ Procedures

P2 Team/Training
Pollution Prevention Team
Environmental Manager Maintenance Technicians/ Operators

Employee Training
Demonstration

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 facilitys operations/activities Data comparison New BMPs/corrective measures Previous years 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.

Best Judgment Required!

Must be updated when facility operations/activities change

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 > 40, 00 gallons Vapor Pressure 68 mm Hg 570 mm Hg >570 mm Hg 10.3 kPA 76.7 kPA Requirements Floating Roof Vapor Recovery System External Floating Roof OR Fixed Roof With Internal Floating Type Cover OR Vapor Recovery System Keep records only

10,566 19,813 gallons

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