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
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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)
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Contingency Plans -- 40 CFR 112.7(d)
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Inspection, Tests, and Records -- 40 CFR
112.7(e)
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Personnel Training and Discharge
Prevention Procedures -- 40 CFR 112.7(f)
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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)
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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:
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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
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
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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
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:
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Oil water separators
Ditches
Levies
Berms
Retention Ponds
Curbs
Spill Countermeasures
• Describe the equipment
at your facility such as:
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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
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PE Certification
Secondary Containment
Integrity testing
Inspections
Training
Security
Plan Updates
PE Certification
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PE may use an agent
PE must review the agent’s
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:
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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
= Higher Risk of Spills
• Complying with
SPCC regulations
– Reduces number of
spills, spill volume,
and amount of oil
migrating offsite
What’s 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
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Uniform
Localized
Microbial Influenced
Galvanic
Erosion
Environmentally
Assisted Cracking
Tank Testing
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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
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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
Flowchart of Criteria for Substantial Harm
Does the facility transfer oil over
water to or from vessels and does
the facility have a total oil storage
capacity greater than or equal to
42,000 gallons?
Yes
Submit Response Plan
No
Does the facility have a total
oil storage capacity greater
than or equal to 1 million
gallons?
Yes
Within any aboveground storage tank area,
does the facility lack secondary containment
that is sufficiently large to contain the
capacity of the largest aboveground oil storage
tank plus sufficient freeboard to all for
precipitation?
Yes
No
Is the facility located at a distance
such that the discharge from the
facility could cause injury to fish
and wildlife and sensitive
environments?
Yes
No
No
Is the facility located a distance
such that a discharge from the
facility would shut down a public
drink ing water intak e?
Yes
No
Has the facility experienced a
reportable oil spill in an amount
greater than or equal to 10,000
gallons within the last 5 years?
No
No Submittal of Response Plan
Except at RA Discretion
Yes
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.
Case Study on Multiple Agency Responsibility
OPS jurisdiction extends to pressure
influencing device which affects
operating pressure of the main pipeline.
Product
Tank2
Pump
Valve
(Storage)
&
(Breakout)
MARINE LOADING DOCK 1
2
The tank depicted is used for
storage associated with the MTR
facility and is under EPA
jurisdiction. If tank is also
usedas a breakout tank it is
subject to both OPS and EPA
jurisdiction.
Marine Transportation—Related
Facility (MTR) is defined in 33 CFR
154.1020. This segment of a complex
is under CG jurisdiction for the
purposes of CWA Section 311(j).
CG Jurisdiction
DOT/OPS Jurisdiction3
3
EPA Jurisdiction
Joint EPA-OPS Jurisdiction3
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.
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
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–
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 facility’s
operations/activities
– Data comparison
– New BMPs/corrective
measures
– Previous year’s
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.
•
Must be updated when facility
operations/activities change
• Best Judgment
Required!
Key Concepts
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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
Vapor Pressure
Requirements
Floating Roof
> 40, 00 gallons
68 mm Hg – 570 mm
Hg
>570 mm Hg
Vapor Recovery
System
10.3 kPA – 76.7 kPA
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