This presentation does not claim or imply that it addresses all
environmental and safety-related issues - if any - associated
with its use. Manufacturing concrete products may involve
the use of hazardous materials, operations and equipment.
It is the user’s responsibility to determine appropriate safety,
health and environmental practices and applicable regulatory
requirements associated with the use of this presentation
and the manufacture of concrete products.
Use of this presentation does not guarantee compliance with
regulatory agency requirements. For further information on
specific rules pertaining to tanks, totes, and drums - as well
as containment requirements at your facility - check with your
local, regional or state agencies.
Storage Tanks and Precast Facilities
West Virginia
Last year, a chemical storage tank leaked into the Elk River. This spill of
approximately 10,000 gallons left hundreds of thousands of people without access
to tap water.
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Could this happen at your facility?
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What is a Storage Tank?
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What is a Stormwater Pollution Prevention Plan?
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Training of employees, spill prevention and conducting inspections.
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Does my facility need a Spill Control and Countermeasures Plan?
Storage Tanks and Precast Facilities
Could this happen at my facility?
Although a precast facility may not have a single 10,000 gallon storage tank, many
facilities have a multitude of chemicals in bulk storage containers. Examples of these
chemicals include admixtures, curing agents, diesel fuel, kerosene, gasoline, form
releases and oils. A discharge of a harmful quantity from one of these storage tanks
could significantly impact the environment, particularly if the discharge reaches a river
or waterway. A harmful quantity could be any quantity that violates state water quality
standards, causes a film or sheen on the water’s surface, or leaves sludge or
emulsion beneath the surface.
Storage Tanks and Precast Facilities
What is a Storage Tank?
Storage tanks come in a variety of shapes and sizes. The EPA does not use the
term "storage tank.“ Instead, the term "bulk storage container" is used. A bulk
storage container is 55 gallons or larger, so everything from a drum to the 10,000
gallon or larger diesel Aboveground Storage Tank (AST) at your facility is a Bulk
Storage Container.
Storage Tanks and Precast Facilities
Example Storage Tanks (Containers)
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Single-wall Aboveground Storage Tank (AST)
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Double-wall AST
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The primary tank is wrapped by an exterior tank that may be in contact with the primary tank (a tank within
a tank). The outer tank has the capacity to capture the inner tank contents should a leak develop. This
interstitial space between the tanks can be checked for signs of leakage during regular inspections.
Industrial Bulk Containers (IBC) Totes
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Has one wall to contain the contents of the tank, typically older fuel and oil tanks were single-wall
construction. Some form of containment is required when storing oil.
Typically admixture tanks are single-wall polyethylene tanks.
Industrial Bulk Containers (IBC) totes and drums are typically single-wall.
Typically these totes are single-wall and range in size from 275 to 330 gallons. Many chemicals such as
admixtures and form oils are shipped in totes. Containment would also be required if storing oil.
Drums
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55 gallon Drums are an industry favorite for a variety of chemicals at a precast facility. They come in a
multitude of materials and sizes ranging from 10 gallons all the way to 95 gallons. Some form of
containment is required when storing oil.
Note: For further information on specific rules pertaining to tanks, totes, and drums, as well as containment
requirements at your facility, check with your local, regional or state regulatory agencies. Additional precautions may
be needed.
Storage Tanks and Precast Facilities
Example Storage Tanks (Containers)
Single-Wall Steel AST in Plastic Containment
55 Gallon “Oil” or Larger Drums
Steel Oil ASTs not in Containment
Plastic Admix Tanks in Containment
10,000 Gallon Diesel Double-Wall Steel AST
Industrial Bulk Containers (IBC Totes)
Storage Tanks and Precast Facilities
What is a Stormwater Pollution Prevention Plan?
As a precaster, your facility falls under your local or state’s National Pollutant
Discharge Elimination System (NPDES) program or the EPA’s Multi-Sector General
Permit for Industrial Activities. Both of these programs require a Stormwater
Pollution Prevention Plan (SWPPP). The plan is a written document that identifies
the industrial activities conducted at the site – including any structural control
practices – which the facility will implement to prevent pollutants from making their
way into stormwater runoff. The SWPPP also must include descriptions of relevant
information, such as the physical features of the facility, best management practices,
training of employees, procedures for spill prevention and conducting inspections.
Storage Tanks and Precast Facilities
Employee Training
So why do my employees and I need to be trained?
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Training is required for all employees who work in areas where industrial materials or activities are
exposed to stormwater, or who are responsible for implementing activities necessary to meet the
conditions of the permit. (SWPPP)
To recognize potential pollution sources and identify pollution prevention techniques.
(SWPPP & SPCC)
Identify Spill Pathways. (SWPPP & SPCC)
To use Best Management Practices, Spill Response and Cleanup Procedures. (SWPPP & SPCC)
To inform employees of SWPPP and SPCC requirements. (SWPPP & SPCC)
Training is to be provided at least annually. (SWPPP & SPCC)
Training is required to inform personnel involved in oil storage or maintenance of tanks about
proper actions to take in the event of a spill. (SPCC)
Training updates will be conducted whenever a significant change has been made to any oil
storage or use (e.g., new tank installation or process). (SPCC)
Training will also be conducted whenever a new employee is assigned to oil handling, maintenance
duties or spill response. (SPCC)
Without documentation, the training didn’t happen.
Storage Tanks and Precast Facilities
Spill Prevention
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Establish procedures for training, spill prevention and cleanup.
Locate potential pollutants and storage tanks so that leaks/spills cannot reach a storm drain or waterway.
Create a Pollution Prevention Team to implement and maintain Best Management Practices (BMPs).
Designate a person at your facility who is accountable for spill prevention and who reports to facility
management.
Spill response can be proactive (engineering-based control such as containment) or reactive (contain spill with
absorbent materials). Proactive measures are generally preferred.
Spill cleanup supplies such as absorbent pads, oil-dry, brooms and shovels, and empty drums should be staged in
areas accessible to employees in case of a spill.
In the case of large spills, sand could be used to prevent liquids from entering stormwater systems or other
environmentally sensitive areas.
Review your SWPPP as it will outline BMPs that will help reduce the pollutants in stormwater discharges from the
facility to ensure compliance.
All spills should be cleaned up immediately!
Storage Tanks and Precast Facilities
Conducting Inspections (Not Just Storage Tanks)
Conducting regular visual inspections of designated equipment, activities, material
handling areas, storage tanks, chemical and waste storage areas, material hoppers
and silos, dust collection systems, wash down and cleaning areas, and best
management practices shall be conducted and documented as designated in your
SWPPP.
The inspections shall occur when the facility is generally in operation and the
equipment, system and/or area can safely be inspected. Tracking or follow-up
procedures shall be used to ensure that appropriate corrective actions are taken,
where identified. The completed, signed and dated inspection form along with
documentation of corrective actions should be filed and retained within the SWPPP.
Without documentation, the inspection didn’t count.
Storage Tanks and Precast Facilities
Storage Container (Tank) Inspection Basics:
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Perform the inspection only when the tank or tank area can safely be inspected.
Conduct the inspection during use (off-loading of new material or while in use).
Inspect the exterior of the tank. (Is the exterior in good condition? Is the tank showing signs of wetting,
discoloration, blistering, bowing, corrosion, cracks or leaks?)
Inspect the tank foundation. (Is the foundation cracked, rusted or showing signs of failure?)
Inspect the containment area (or interstice of double-wall tanks, if applicable) and verify it is dry, with no
accumulation of trash or other debris.
Inspect the vents, gauges, pumps, hoses, dispensers and alarms for leaks and proper operation where applicable.
Is the tank construction compatible with the material stored?
Verify the bungs, fill ports and valves are capped, closed and locked when not in use.
Are labels and placards appropriate and legible for the contents of the container?
Are spill kits or supplies located near or at the tanks?
If applicable, are emergency shutoffs labeled and operating?
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Document, maintain records of inspections and complete corrective actions.
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Storage Tanks and Precast Facilities
Double-Wall Fuel Tank Inspection Example:
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Stand back from your fuel tank and look at it as a whole.
Look at the placards, labels, condition of the paint, corrosion, legs,
saddles, level gauge, overfill alarms, spill buckets, interstitial monitor
(gauge), vents, emergency vents and electrical service.
Example 1000 Gallon
Double-Wall Off-Road
Diesel Tank
Spill Kit Present
(Good BMP)
Fuel Tank Protection
(Barrier Wall)
Trash Receptacle
Present (Good BMP)
Concrete
Slab/Foundation
in good shape, under the
AST as well.
Is the tank grounded?
Storage Tanks and Precast Facilities
Double-Wall Fuel Tank Inspection Example:
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Open the fill bucket and check for leaks. Is there any residual fuel? If
equipped, is the drain plunger operational?
Drain (plunger)
Cam-Lock Cap
Fill Bucket Dry?
Fill Bucket locked when
not in use?
Does your fuel supplier
use the fill port?
Storage Tanks and Precast Facilities
Double-Wall Fuel Tank Inspection Example:
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Does your gauge operate?
Do you know the full and empty measurements?
When is the last time you tested the overfill alarm?
Level Gauge
Overfill Alarm
Storage Tanks and Precast Facilities
Double-Wall Fuel Tank Inspection Example:
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Example Overfill Alarm
Alarm sounds when
TEST switch is
depressed and when the
float is activated.
Low Battery indicator
blinks when TEST switch
is depressed if new
battery is needed.
Overfill Alarm indicator
blinks when TEST switch
is depressed and when
float is activated.
SILENCE/TEST switch.
Storage Tanks and Precast Facilities
Double-Wall Fuel Tank Inspection Example:
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Are your emergency vents operating? (Will they open and close?)
Are all bungs/caps properly secured?
Can they be easily opened to remove fuel?
4 in. Steel Bung/Plug
Primary Tank
Emergency Vent
(Do not use a hammer
to loosen on flammable
or combustible
liquids.)
Interstitial
Emergency Vent
(Do not use a hammer
to loosen on flammable
or combustible
liquids.)
Storage Tanks and Precast Facilities
Double-Wall Fuel Tank Inspection Example:
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Do you have a primary vent?
Is it open? Is anything blocking it? (Bird/Wasp Nest)
Can water enter the
tank?
Storage Tanks and Precast Facilities
Double-Wall Fuel Tank Inspection Example:
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Is the dispenser operating properly? Are there any leaks?
Is the electrical properly installed?
Is the dispenser handle
operating properly?
Can you lock the
dispenser handle?
Is the hose in good
shape? Any cracks? Has
it been run over?
When was the filter last
changed?
Electrical conduit in good
shape? (It should be
rigid, explosion-proof
when a gasoline tank is
present?)
Is the interstitial (leak)
gauge operating?
Storage Tanks and Precast Facilities
Does my facility need a Spill Control and Countermeasures Plan (SPCC)?
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I have a Stormwater Pollution Prevention Plan (SWPPP). Why do I need an SPCC
Plan?
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If you have a total aboveground oil storage capacity greater than 1,320 gallons or a
completely buried storage capacity greater than 42,000 gallons?
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Most precasters will not have 42,000 gallons of buried storage, but could have 1,320 gallons of
aboveground oil storage containers. These containers or tanks are portable or fixed with the capacity of 55
gallons or more.
55 Gallons, are drums included?
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Although the SWPPP covers the potential pollutants at your facility, if you store any type of petroleumbased products (diesel, gasoline, kerosene, motor oil, hydraulic oil, transmission fluid, greases, form
release agents, form release oil, biodegradable releases or oils, petroleum-based paints) at your facility,
you may need an SPCC.
Yes any “oil” drums of 55 gallons or greater are included in the SPCC regulation.
What about admixtures?
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More than likely not. Most admixtures are not petroleum-based. Verify the MSDS, SDS or check with the
manufacturer for the presence of petroleum.
Storage Tanks and Precast Facilities
Does my facility need a Spill Control and Countermeasures Plan (SPCC)?
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I have one 500-gallon diesel AST, two 225-gallon oil ASTs, one 275-gallon tote of
biodegradable form release and a few 55-gallon drums of grease. Do I need an
SPCC?
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We never fill the diesel or oil tanks full. Do we still need an SPCC?
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Yes, your aboveground storage is 1,335 gallons. You would be regulated under the EPA SPCC rules.
The capacity to store is independent of the actual amount stored. If you have storage for 1,320 gallons of
“oil” but never fill it, you are still regulated by SPCC.
Can I write my own SPCC Plan?
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Maybe. Facilities that have no greater than 10,000 gallons of storage, no individual aboveground oil
storage containers greater than 5,000 gallons and no discharges (spills) in the past three years may
qualify to use the EPA’s Tier I Qualified Facility SPCC Plan Template. However, some states do not allow
self-certification.
Your best bet is to contact your environmental professional or consultant for further guidance.
Storage Tanks and Precast Facilities
Where can I get further information?
Stormwater Pollution Prevention Plans
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EPA’s Proposed 2013 Multi-Sector General Permit
http://cfpub.epa.gov/npdes/stormwater/msgp.cfm
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EPA’s Developing Your Stormwater Pollution Prevention Plan:
A Guide for Industrial Operators
http://www.epa.gov/npdes/pubs/industrial_swppp_guide.pdf
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EPA’s Ready Mixed Concrete, Crushed Stone, and Sand and Gravel Industrial
Stormwater Compliance Resources
http://www.epa.gov/compliance/assistance/sectors/readymix-aggregate.html
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NPDES Permit Program – State Contacts
http://cfpub.epa.gov/npdes/contacts.cfm?program_id=45&type=STATE
Spill Prevention Control & Countermeasure (Oil)
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EPA Region 8 “Do I Need to Have a SPCC Plan?”
http://www2.epa.gov/region8/do-i-need-have-spill-prevention-control-and-countermeasure-plan
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EPA Oil Spills (SPCC Guidance)
http://www.epa.gov/emergencies/content/spcc/index.htm
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EPA Tier I Qualified Facility SPCC Plan Template
http://www.epa.gov/oem/content/spcc/tier1temp.htm
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EPA SPCC Guidance for Regional Inspectors
http://www.epa.gov/emergencies/content/spcc/spcc_guidance.htm