Outline
Introduction Spill Prevention Control and Countermeasure (SPCC) Plans Facility Response Plans (OPA-90) Stormwater Pollution Prevention Plans (SWP3)
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
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
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
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
Spill Countermeasures
Describe the equipment at your facility such as:
Industrial absorbent Pigs Oil booms Plugs Pans
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
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
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
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
Rubber Piping
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
S u b m it R e s p o n s e P la n
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
Y e s
N o
Y e s
N o
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
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
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).
800-424-8802
National Response Center (NRC): 800-424-8802 NCP Product Schedule Information: 202-260-2342
www.epa. gov/oilspill
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
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.
Key Concepts
Develop SWP3 Conduct inspections Implement BMPs Train annually Update annually
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
Summary
Limit VOLs emissions from ASTs Specific Regulations for Hazardous Waste Tanks and Their Emissions Diesel Fuel Sulfur Content Reduced