Tyler Jones

321000444
Texas A&M Storage Tanks and Stormwater

Introduction
Last week a group of thirteen EHSC students along with Dr. Wilkinson toured
the Texas A&M Fleet Services Building as well as part of the Whites Creek Tributary
on campus lead by Toni Eubanks. At each of these sites, the group discussed the
different rules and regulations of their programs. I have separated the report into
two sections dealing with our discussions and the different features of the two sites.
The Texas A&M Fleet Service Building deals with the storage and delivery of
petroleum products to the University and some outside groups. This site offers
fueling services for all agencies under the University system in the area and also has
a partnership with the City of College Station allowing them to fuel there as well.
Whites Creek is a great example of how Texas A&M deals with their Phase II
Municipal Separate Storm Sewer System. The group toured here to show how the
creek is used to regulate storm water flow through a rapidly developing area while
maintaining their compliance under the specified regulations.
Below I will expand on these sites and the different regulations and
guidelines used for them. This will be done by a superscript relating it the guideline
or regulation that pertains to it.

Site Features
Petroleum Storage Tanks
The Fleet Services Building is located at 388 Agronomy Rd, Building 958. It is
responsible for servicing 556 vehicles within Texas A&Ms fleet along with the extra
flow of the City of College Stations fleet. It currently averages distributing 1,000
gallons of unleaded fuel per day, 650 gallons of diesel per day and 750 gallons of
biodiesel per day (Figure 1).

Most of this is done through USTs (Underground Storage Tanks). These

include all equipment including the main tank such as
piping, vents, connectors, valves, fittings, submersible
pumps, release detection equipment, spill/overfill
prevention equipment and corrosion prevention
equipment. All of these tanks require some sort of the
following that will be discussed below: Corrosion
protection, release detection, spill and overfill
prevention and Stage 1 and 2 Vapor recovery systems.
For corrosion protection, the University sues a
sacrificial anode in their tanks. These
Figure 1: Texas A&M Fleet Service Pumping
Station
anodes corrode faster than their tanks and
therefore corrode before and ideally in
place of the tanks outer shell.
The University uses an Automatic Tank Gauging and Inventory Control
system (Figure 2). This system records any fuel
entering
and exiting the tank and will detect any differences
in those
amounts. This detection helps promote quick
responses to any possible releases and minimizes
any loss
of fuel in addition to minimizing environmental
threats
and the liability of the University in the event of a
cleanup.
They also have an Automatic line leak detector that
can
detect the loss of 3 gallons per hour or greater.
Records
of this must be kept for five years.
The Spill/Overfill Prevention is a set of
Figure 2: Automatic Tank Gauging
guidelines to help prevent any unwarranted spills. and Inventory Control System
Equipment used for this are tight-fill fittings, spill
containment (sump), automatic flow restrictor and audible and visible alarms.
Record of this plan and spills must be kept for five years unless you spill less than 25
gallons or TCEQ writes an exemption.
The University also maintains a few ASTs( Aboveground Storage Tanks).
A&M contains all of the major types of oil storage containers. These container must
be 55g or larger containers to apply and include: tanks, containers, drums,
transformers, oil-filled electrical equipment and mobile or portable totes. All of
these ASTs must have secondary
containment features and sufficient
freeboard to contain precipitation1.
Storm Water
Texas A&Ms campus covers
multiple tributaries of Whites Creek
(Figure 4). With this, Storm Water
management is crucial for both the
controlled outflow of storm water and the

Figure 3: Map of Tributaries of Whites Creek on

Texas A&Ms Campus

protection of those waterways. A&M is a continually growing

campus with many ongoing construction projects that
require monitoring for unwanted discharge into these
waterways. This is especially evident on West Campus near
the Penberthy Complex where most of the new construction
Figure 4: Whites Creek on Texas A&M Campus
is happening and where a big part of Whites Creek
flows through (Figure 3). A few examples are the
problems associated with the George H.W. Bush Library, where the sides of the
creek are not properly upheld due to recent construction, and with the construction
of the Agriculture and Life Sciences Building so close to Whites Creek.
Regulatory Requirements
Petroleum Storage Tanks
All facilities containing storage tanks must have a Spill Prevention and
Counter measure Plan (SPCC) which is required by the EPA under 40 CFR 1121. The
plan can be put together by either the facilities owner/operator or be done by a
Professional Engineer if the facility stores more than 10,000 gallons of oil. In Texas
A&Ms case, they have a Professional Engineer make it.
40 CFR 1121 also demands that all tanks have a Secondary Containment
system to prevent any spills.
Under Regulation 33 CFR 329.42 the facility must determine if it could
reasonably discharge oil into navigable waters. This is to prevent potential spill
hazards on vital waterways. The definition of navigable waterways is still under
debate as the regulations do not have strict guidelines.
The State of Texas goes further to define and put restrictions on both USTs
and ASTs with 30 TAC 3343. This regulation requires that any new instillation
construction be reported to TCEQ and that the tank must be registered with the
State within 30 days of any petroleum products entering it. This regulation also
provides a list of those exempt under its rule but Texas A&Ms facilities do not apply
to these. In addition, it also puts in regulation about the different types of operators
and what kind of training they require. A facility must have a Class A, B and C
Operator that each have different responsibilities for the facility.
The State of Texas has a regulation guideline on how to report and
investigate releases from petroleum storage tanks(PSTs). RG-4114 is meant to help
facilities that have spill respond in the best manner and on how and when to report
these spills.
Storm Water
EPA requires small municipalities within urbanized areas to register as a
MS4(Municipal Separate Storm Sewer System)5 under a NPDES (National Pollution
Discharge Elimination System) permit. Texas takes care of these by having MS4s to
get a TPDES(Texas Pollution Discharge Elimination System).

The TXR0400006 is the general permit that Texas A&M operates under for
their MS4. TXR040000 is required to be updated every 5 years and A&Ms expired in
August 2012 and has been operating under the since December 2013.
Under TXR040000, MS4s are required to submit a Notice of Intent7 and a
Storm Water Management Program8 (Figure 5). These must be submitted within
180 days of creation of the MS4.
Texas A&M has a level two Phase II MS4 which
include 6 Minimum Control Measures (MCMs). A&M
operates under 5 of these and is exempt from the last
one. I will go over these MCMs below.
MCM19 includes Public Outreach and
involvement. This requires all permitees to develop and
Figure 5: Storm Water Management Program
implement a public outreach program to
Guide
inform and involve the public in their Storm
Water programs. Texas A&M does this
through a Campus Sustainability Day, Earth Day, Texas Recycles and Protecting Our
Waters, an educational program.
MCM210 includes the Illicit Discharge Detection and Elimination. This
requires there to be programs that detect, investigate and eliminate illicit discharges
into the small MS4. A&M does this by regular storm sewer outfall inspections along
with a public hotline.
MCM311: Construction Site Stormwater Runoff Control requires A&M to have
a program that requires operators of small and large construction activities to
select, install, implement, and maintain stormwater control measures that prevent
illicit discharge. TAMU EHS reviews all plans for construction sites on campus and
makes recommendations accordingly. For Construction sites, EHS has to inspect
each site every two weeks and immediately following major weather events.
MCM412 is a Post-Construction Stormwater Management in New
Development and Redevelopment program that includes controlling stormwater
discharges from newly developed and redeveloped sites.
MCM513 is for Pollution Prevenetion and Good Housekeeping for Municipal
Operations. It requires an operation and maintenance program including an
employee training component that has the ultimate goal of preventing or reducing
pollutant runoff from municipal operations.
Lastly, MCM714 includes the Authorization for Municipal Construction
Activities. This requires contractors to submit their own SWP3s for each project
that requires a permit. A&M opts out of this one as it is not required for the kind of
projects A&M partakes in.
Comparisons
Petroleum Storage Tanks
The Texas A&M petroleum storage system is considered to be and industrial
facility in that it houses enough oil to be labeled so. To compare it to a Municipal

facility, we can directly compare it to both the City of College Station and the City of
Bryan, both having reasonably similar facilities. This drives the point that while
Texas A&Ms population is dramatically smaller than these cities, it still operates on
a similar capacity.
Storm Water
Texas A&M operates very much like a City under their MS4. What makes it
unique is that it operates in two other MS4s, the City of College Stations and the City
of Bryans. Another difference is that, while the other Cities population remain
constant, A&M deal and plan around their fluctuating population size. This
translates into being prepared for major construction plans outside of the semester
and possible spills during the semester.

References

1. Agency, Us Environmental Protection. "40 CFR 112." Code of

Federal Regulations: Chapter 40, Part 112 -- Oil Pollution
Prevention (n.d.): n. pag. Epa.org. EPA. Web. 22 Oct. 2014.
2. Some Areas To Become Waters Of The, United States While Siltation
Or A, Change In Drainage May Remove An, and Area From Waters
Of The United States. PART 329DEFINITION OF NAVI- GABLE
WATERS OF THE UNITED STATES (n.d.): n. pag. GPO.gov. GPO.
Web. 23 Oct. 2014.
3. Agency, Us Environmental Protection. "40 CFR 112." Code of
Federal Regulations: Chapter 40, Part 112 -- Oil Pollution
Prevention (n.d.): n. pag. Epa.org. EPA. Web. 22 Oct. 2014.
4. "RG- 411." TCEQ.Texas.Gov. TCEQ, n.d. Web. 23 Oct. 2014.
5. "Municipal Separate Storm Sewer System (MS4) Main Page."
Municipal Separate Storm Sewer System (MS4) Main Page. EPA, n.d.
Web. 22 Oct. 2014.
6. "General Permit TXR040000 for Phase II (Small) MS4s." General
Permit TXR040000 for Phase II (Small) MS4s. TCEQ, n.d. Web. 23
Oct. 2014.
7. "Notice of Intent (NOI) for Stormwater Discharges from Small
Municipal Separate Storm Sewer Systems (MS4) under the TPDES
Phase II MS4 General Permit." Notice of Intent (NOI) for Stormwater
Discharges from Small Municipal Separate Storm Sewer Systems
(MS4) under the TPDES Phase II MS4 General Permit (TXR040000)
(2013): n. pag. TCEQ.State.tx.us. TCEQ. Web. 23 Oct. 2014.
8. Storm Water Permitting Requirements for Phase II (Small) MS4s."
Storm Water Permitting Requirements for Phase II (Small) MS4s.
SWMP, n.d. Web. 23 Oct. 2014.
9. TXR04000 MCM1
10.TXR04000 MCM2
11.TXR04000 MCM3
12.TXR04000 MCM4
13.TXR04000 MCM5
14.TXR04000 MCM7