Spurlin spc cshortversfinal mb
Upcoming SlideShare
Loading in...5
×
 

Spurlin spc cshortversfinal mb

on

  • 296 views

 

Statistics

Views

Total Views
296
Views on SlideShare
296
Embed Views
0

Actions

Likes
0
Downloads
7
Comments
0

0 Embeds 0

No embeds

Accessibility

Categories

Upload Details

Uploaded via as Microsoft PowerPoint

Usage Rights

© All Rights Reserved

Report content

Flagged as inappropriate Flag as inappropriate
Flag as inappropriate

Select your reason for flagging this presentation as inappropriate.

Cancel
  • Full Name Full Name Comment goes here.
    Are you sure you want to
    Your message goes here
    Processing…
Post Comment
Edit your comment
  • Supplemental Information: Basically, the prevention requirements instruct owners and operators to prepare and implement a site-specific SPCC Plan to address three areas: Operating procedures to prevent an oil discharge; Control measures to prevent a discharge from entering navigable waters; and Countermeasures to contain, clean up, and mitigate the effects of any oil discharge that affects navigable waters. The owner or operator of a mobile or portable facility such as a drilling or workover rig, may prepare a general — not a site-specific — SPCC Plan. The Plan must satisfy all other requirements of 40 CFR part 112. An owner or operator must install appropriate containment or diversionary structures, unless the owner or operator can demonstrate that installing such structures is “impracticable.” Then, there must be a strong oil spill contingency Plan following 40 CFR part 109.
  • Supplemental Information: The Facility Response Plan (FRP) requirements apply to a subset of SPCC-regulated facilities - those that could cause substantial harm to the environment . Provisions require the owner or operator of such a facility to prepare and submit to EPA a plan for responding, to the maximum extent practicable, to a small, medium, and worst case discharge, or substantial threat of such a discharge , of oil. Source: 40 CFR part 112.20 - 21
  • Example of poor implementation of an SPCC plan and example to use for “reasonable expectation of Discharge in quantities that may be harmful ”.
  • Spill that an EPA OSC responded to in 2004. Bottom of tank leaked due to CORROSION.
  • Approximate Duration: 4 hours Presentation Materials: PowerPoint slides 35mm slides Region VI video ( “SPCC Training Series Highlights” - 30 minutes) Reference Materials: Title 40 CFR part 112 (Tab 11) References to Good Engineering Practices (Tabs 19-27) Summary of DOT Requirements for Vehicles (Tab 14) Outline: This lesson is designed to introduce students to the SPCC regulation outlined in 40 CFR part 112. The lesson addresses the requirements for preparing and implementing SPCC Plans and inspecting facilities for which SPCC Plans are required.
  • Supplemental Information: The regulation applies to departments, agencies, and instrumentalities of the Federal Government. Examples of non-transportation related facilities are storage and refining facilities; electrical substations; industrial, commercial and agricultural facilities that store oil; and fixed and mobile onshore and offshore oil well drilling facilities. Part 112 also covers support equipment, but excludes any terminal unit or process associated with the handling or transferring of oil in bulk to or from a vessel.
  • Experts note that any liquid with relatively high viscosity and a slippery feel may be called an oil. The American Society for Testing and Materials (ASTM) defines an “ oil matter ” as a hydrocarbon, hydrocarbon derivative, and any liquid or unctuous substance that has a boiling point of 90 degrees Celsius or above, and is extractable from water at pH levels of 5.0 or lower using benzene (chloroform or carbon tetrachloride) as a solvent. The recognized categories of oil are petroleum, mineral, or hydrocarbon oils derived from crude petroleum; fatty oils that are glycerol esters derived from vegetable or animal fats or similar materials; and essential oils derived from plants, usually not esters, but terpene hydrocarbons. EPA HQ has convened an Oil Characterization Workgroup to develop guidance on the characteristics of oil subject to the CWA, OPA, and CERCLA. The workgroup is researching technical, scientific, regulatory, and legal issues. For example, the Workgroup is conducting research on the physical properties of oils and oil-like substances and reviewing and developing scientific models to characterize oils and oil-like substances. The workgroup is also researching Federal and international approaches to characterize oils, and reviewing previous Agency positions on the characterization of oils. USCG has published a list of materials it considers as oils under the CWA, and EPA plans to develop guidance on the characteristics of oils for implementing the CWA .
  • Supplemental Information Natural gas (including liquid natural gas and liquid petroleum gas) is not considered an oil. EPA does not consider highly volatile liquids that volatilize on contact with air or water, such as liquid natural gas or liquid petroleum gas, to be oil (67 FR 47076). Petroleum distillate or oil that is produced by natural gas wells and stored at atmospheric pressure and temperature (commonly referred to as condensate or drip gas), however, is considered an oil. Dry gas production facilities are not subject to the SPCC rule. A dry gas production facility produces natural gas from a well (or wells) but does not also produce condensate or crude oil that can be drawn off the tanks, containers, or other production equipment at the facility. EPA has clarified that a dry gas production facility does not meet the description of an “oil production, oil recovery, or oil recycling facility” for which the wastewater treatment exemption would apply under §112.1(d)(6). Wet gas production facilities are subject to the SPCC rule. In addition to natural gas, wet gas production facilities produce condensate or crude oil that can be drawn off the tanks, containers, or other production equipment at the facility. Since wet gas production facilities produce and store condensate, which is considered an oil, they are regulated under the SPCC rule. See excerpt from “Notice Concerning Certain Issues Pertaining to the July 2002 Spill Prevention, Control, and Countermeasure (SPCC) Rule,” 69 FR 29728, May 25, 2004.
  • Supplemental Information: What to Count All containers of oil with a capacity of 55 gallons or greater are to be counted (unless listed below) when calculating total oil storage capacity at a facility. What Not to Count Permanently closed containers are not counted when calculating total oil storage capacity. “Permanently closed,” as defined in §112.2, refers to containers “for which (1) All liquid and sludge has been removed from each container and connecting line; and (2) All connecting lines and piping have been disconnected from the container and blanked off, all valves (except for ventilation valves) have been closed and locked, and conspicuous signs have been posted on each container stating that it is a permanently closed container and noting the date of closure.” Completely buried tanks, as defined in §112.2, and connected underground piping, underground ancillary equipment, and containment systems that are currently subject to all of the technical requirements of 40 CFR part 280 or all of the technical requirements of a state program approved under 40 CFR part 281 are not counted. Such tanks must still be marked on the facility diagram as provided in §112.7(a)(3). “Completely buried tank” as defined in §112.2 refers to “any container completely below grade and covered with earth, sand, gravel, asphalt, or other material. Containers in vaults, bunkered tanks, or partially buried tanks are considered aboveground storage containers for purposes of this part.”
  • Description: Tank farms very near the ocean, in a rural Alaskan location. This illustrates proximity to navigable waterways.
  • Note: the compliance deadline for non-farm facilities has passed (was 11/10/2011). See next slide for farm dates. Production facilities (in the oil-fields basically – extracting oil and/or oil condensate) have 6-months after beginning ops to prepare and implement a Plan for the first time.
  • Approximate Duration: 4 hours Presentation Materials: PowerPoint slides 35mm slides Region VI video ( “SPCC Training Series Highlights” - 30 minutes) Reference Materials: Title 40 CFR part 112 (Tab 11) References to Good Engineering Practices (Tabs 19-27) Summary of DOT Requirements for Vehicles (Tab 14) Outline: This lesson is designed to introduce students to the SPCC regulation outlined in 40 CFR part 112. The lesson addresses the requirements for preparing and implementing SPCC Plans and inspecting facilities for which SPCC Plans are required.
  • Supplemental Information:
  • Supplemental information: EPA may challenge the initial decision on SPCC applicability made by the owner/operator.
  • Approximate Duration: 4 hours Presentation Materials: PowerPoint slides 35mm slides Region VI video ( “SPCC Training Series Highlights” - 30 minutes) Reference Materials: Title 40 CFR part 112 (Tab 11) References to Good Engineering Practices (Tabs 19-27) Summary of DOT Requirements for Vehicles (Tab 14) Outline: This lesson is designed to introduce students to the SPCC regulation outlined in 40 CFR part 112. The lesson addresses the requirements for preparing and implementing SPCC Plans and inspecting facilities for which SPCC Plans are required.
  • Supplemental Information: The general containment requirements do not have a required sizing design criteria and do not necessarily have to be designed to contain the catastrophic failures of a device, equipment or container (this decision of design rests with the PE). However, the specific containment requirements include set sizing design criteria and do have to be designed to contain the catastrophic failures of a device equipment or container and in some cases includes a consideration of freeboard in the design (this design decision does not rest with the PE, as it has been dictated in the rule itself). The SPCC rule specifies a required minimum size for secondary containment for the following areas: • Bulk storage containers, • Loading/unloading racks, • Mobile or portable bulk storage containers, and • Production facility bulk storage containers, including tank batteries, separation, and treating vessels/equipment.  
  • NOTE TO INSTRUCTOR:
  • Briefly show how general containment falls in diagram: Handout #5
  • C
  • Supplemental Information: This table lists all the secondary containment provisions of the SPCC rule for different types of facilities.
  • Source: 2002 Final Rule Text, 67 FR 47042
  • Description: Bulk Storage Tanks. This is a photo of an earthen secondary containment berm for storage tanks. This photo shows adequate containment.
  • Description: This photo depicts another effective means of providing secondary containment.
  • Description: NOT SUFFICIENTLY IMPERVIOUS. This is a photo of a concrete block containment wall. This is a common problem with concrete block containment walls. Also, concrete block containment walls, unless reinforced or very short, are not strong enough to hold significant quantities of oil or water.
  • Description: This is a photo of a containment pallet for drums. This photo shows adequate containment.
  • Supplemental Information: The rule establishes substantive requirements for stormwater drainage from diked areas, and recordkeeping requirements for stormwater bypass events. Records required under permits issued in accordance with the National Pollutant Discharge Elimination System (NPDES) rules are sufficient for recording stormwater bypass events. For such events, an owner or operator does not need to prepare records specifically for SPCC compliance. Source: 2002 Final Rule Text, 67 FR 47042
  • Description: This is valve controls dike drainage but must never be left in the open position.
  • Supplemental Information:
  • Description: Tank was over-filled and approximately 200 barrels of crude oil escaped. (Harris County, Texas, 2000)
  • Description: Compromised integrity – golf tee used to fill a hole in the tank
  • If a Production facility has a rack, it must follow 112.7(h). Production facilities are Not exempt from the requirements in 112.7. Supplemental Information: Scully systems are common in newer, larger facilities. These are electronic or computer controlled fail-safe systems that do not allow transfer to commence unless all necessary safety conditions and measures are in place. DOT regulations addressing loading and unloading are found at 49 CFR part 177. The loading and unloading rack should have secondary containment if the oil does not flow into a treatment facility. The treatment facility must be located in the facility. An oil and water separator can be acceptable if it is manually operated. Warning signs or barriers (e.g., cones) are also acceptable to prevent premature vehicular departure. Instructions to Presenter: Images to follow.
  • Description: This is a photo of a truck loading area quick drainage system.
  • Supplemental Information: The practice of capping or blank-flanging valves when not in service or in standby service for an extended time should also apply to pipelines that are emptied of liquid content either by draining or by inert gas pressure. For facility lighting, consideration should be given to: Discovery of spills occurring during hours of darkness, both by operating personnel, if present, and by non-operating personnel (the general public, local police, etc.); and Prevention of spills occurring through acts of vandalism. Starter controls on oil pumps should be locked in the off position (i.e., “electronically isolated”). Instructions to Presenter: Images to follow.
  • Be aware that if your facility has an oil spill to navigable waters, not only must you report it to the National Response Center, but you may have to submit information from your SPCC plan Per 40 CFR 112.4 to the Regional Oil Program office.

Spurlin spc cshortversfinal mb Spurlin spc cshortversfinal mb Presentation Transcript

  • 1SPCC Overview
  • 2Outline1. Background2. SPCC Applicability3. Written SPCC Plan Requirements4. Implementation of SPCC Requirements
  • 3USEPA Office of EmergencyManagement: Oil Pollution Prevention Prevention– SPCC Preparedness– Facility Response Plans (FRP)– Area Contingency Plans Response– National Contingency Plan– Local, State, Federal (EPA & USCG),Responsible Party
  • 4USEPA - Region 4 EmergencyResponse Program Cadre of 30 Federal On-Scene Coordinators (OSCs)– Based in Atlanta, GA. Outpost locations in Mobile, AL,Tallahassee, FL, Louisville, KY, Raleigh, NC, Jackson, TN 24/7 On-Call Status Respond to releases of hazardous substances and oilspills; All environmental hazards response (air, water, land,); Federal disaster and WMD/CT response capability; Planning and Preparedness (Drills) Oil Pollution Prevention (SPCC and FRPInspections)
  • 5Oil Pollution Prevention Regulations –SPCC Rule – 40 CFR 112 Spill, Prevention, Control, andCountermeasure (SPCC) regulation (40 CFR 112)requires the preparation and implementation of site-specific plans to prevent oil discharges that couldaffect navigable waters Authority: Clean Water Act (CWA) § 311(j)(1)(C)and 501 and codified under 40 CFR Part 112 EPA’s Office of Emergency Management administers the Rule
  • 6Oil Pollution Prevention Regulations –FRP Rule - 40 CFR 112.20 Facility Response Plan (FRP) regulationsrequire certain facilities to prepare and submit toEPA plans to respond to discharges of varioussizes– Only applies to a subset of SPCC regulated facilities Basis: 1990 OPA amendments to CWA Authority: CWA §§ 311(j)(5) and 501, andcodified under 40 CFR §§112.20-112.21
  • 7Purpose SPCC - (40 CFR Part 112) To prevent oil discharges from reachingthe navigable waters of the U.S. oradjoining shorelines; To ensure effective and proactivemeasures are used in response to an oilspill;
  • 8Purpose of SPCC?
  • 9
  • History of Oil Pollution Prevention Regulations1972 Federal Water Pollution Control Act Amendments1974 Original SPCC Rule Published1988 Ashland Oil Spill – SPCC Task Force Formed1989 Exxon Valdez Spill in Alaska1991/93 Proposed SPCC Rule Revisions1994 Final Facility Response Plan (FRP) Rule published2001 Draft Final SPCC Rule Revisions2002 Final “Revised” SPCC Rule published 7/17/022004 SPCC litigation settlement2006 SPCC Rule Amendments published 12/26/062008 SPCC Rule Amendments published 12/5/082009 12/5/08 SPCC Rule amendments delayed2009 SPCC Rule Amendments published 11/5/092010 Compliance Date Extension issued on 10/7/10 (except for FRPs)2011 Compliance Date Extension for FARMs published on 10/18/11
  • 13Applicability of SPCC
  • General SPCC Rule ApplicabilityThe SPCC rule applies to a facility that meets thefollowing criteria:Drills, produces, gathers, stores, processes, refines, transfers,distributes, uses, or consumesoil and oil products; andIs non-transportation-related; andDue to location, could reasonably be expected to discharge oil inquantities that may be harmful into or upon the navigable watersof the U.S. or adjoining shorelines; andMeets capacity thresholds• Aboveground storage > 1,320 gallons; or• Completely buried storage > 42,000 gallons*1122334455(*Note: many USTs are exempt from the SPCC Rule)
  • 15Definition ofDefinition of “Facility”“Facility” – (– (§ 112.2)112.2)Facility means any mobile or fixed, onshore or offshore building, property,parcel, lease, structure, installation, equipment, pipe, or pipeline (other than avessel or a public vessel) used in oil well drilling operations, oil production, oilrefining, oil storage, oil gathering, oil processing, oil transfer, oil distribution, andoil waste treatment, or in which oil is used, as described in Appendix A to thispart. The boundaries of a facility depend on several site-specific factors,including but not limited to, the ownership or operation of buildings, structures,and equipment on the same site and types of activity at the site. Contiguous ornon-contiguous buildings, properties, parcels, leases, structures,installations, pipes, or pipelines under the ownership or operation of thesame person may be considered separate facilities. Only this definitiongoverns whether a facility is subject to this part.11
  • 16Oil (§ 112.2) Includes oil of any kind or in any form such as:– Petroleum and fuel oils– Mineral oils– Sludge– Synthetic oils– Oil mixed with wastes other than dredged spoil– Animal fats, oils, and greases– Vegetable oilsNote: E85, and Bio-Diesel are oils for SPCC purposes.Denatured ethanol (if denaturant is an oil) is also.33
  • Natural Gas Natural gas (including liquid natural gas and liquid petroleum gas) isnot considered an oilHazardous Substances and HazardousWaste Hazardous substances that are oils, or mixed with oils, are subject toSPCC rule requirements– Containers storing these substances may also be covered by RCRA andCERCLA Tanks containing RCRA hazardous wastes are not subject to the USTrules, and therefore are not exempt under §112.1(d)(2)(i) or (4) if theycontain oil Hazardous substances that are not oils nor mixed with oils are notsubject to SPCC rule requirements33
  • Storage Capacity CalculationIncluded in storage capacity Excluded from storage capacity*Containers (i.e. bulk storagecontainers, oil-filled equipment,mobile/portable containers) with acapacity of 55 gallons or greater.*Completely buried tanks andassociated underground piping, &ancillary equipment, subject to alltechnical requirements of 40 CFR part280 or 281*Containers used exclusively forwastewater treatment*Motive power containers*Hot mix asphalt containers*Pesticide application equipment andcontainers*Heating oil containers at single familyresidences*USTs deferred under 40 CFR 280 andvaulted tanks at nuclear power facilities*Capacity of containers that arepermanently closed.Meets capacity thresholds55
  • 19Navigable watersNavigable Waterways could include: Traditional navigable waters– Rivers– Lakes Tributaries of navigable waters– Creeks & Streams– WetlandsAlso consider conduits to navigable waters Storm drains, storm sewers Ditches Wetlands44
  • 20
  • 21
  • 22
  • Service StationDispenser IslandASTsStreetRestaurantOverland Path ofOil SpillStorm Drain – connectsTo Storm Drain atStreetTruck TransferAreaUnnamed Tributary (Fish Kill)
  • Current Compliance DatesA facility starting operation… Would…On or before 8/16/02 Maintain existing Plan.Amend and implement Plan nolater than 11/10/2011 *After 8/16/02through 11/10/2011*Prepare and implement Plan nolater than 11/10/2011*.After 11/10/2011*(excluding production facilities)Prepare and implement Planbefore beginning operations.After 11/10/2011*(production facilities)Prepare and implement Planwithin 6-months after beginningoperations*Note: For FRP facilities and for off-shore drilling, production, & workover SPCCfacilities, the compliance date was 11/10/2010.Extends the dates by which a facility must amend andimplement its SPCC Plan in accordance with revisions to therule promulgated since 2002
  • Farm Compliance DatesA farm starting operation… Would…On or before 8/16/02 Maintain existing Plan.Amend and implement Plan nolater than 5/10/2013After 8/16/02Through 5/10/2013Prepare and implement Plan nolater than 5/10/2013After 5/10/2013 Prepare and implement Planbefore beginning operations.Extends the dates by which a FARM must amend andimplement its SPCC Plan in accordance with revisions to therule promulgated since 2002
  • 26Requirements for Preparationof SPCC Plans
  • §112.1 General applicability of the rule§112.2 Definitions of terms used in the rule§112.3 Requirement to prepare an SPCC Plan§112.4 Amendment of SPCC Plan by RA§112.5 Amendment of SPCC Plan by owner or operator§112.6 Qualified Facilities§112.7 General requirements for all facilities§112.8 Specific requirements for onshore facilities (excludingproduction facilities)§112.9 Specific requirements for onshore production facilities§112.10 Specific requirements for onshore oil drilling andworkover facilities§112.11 Specific requirements for offshore oil drilling, production,or workover facilities§112.20 Facility Response Plans§112.21 Facility Response training and drills/ exercises40 CFR 112 Structure
  • Overview of information required tobe in your written SPCC Plan PE certification of Plan (112.3(d)– May self-certify Plan if store 10,000 gallons or less (112.6) Management review of Plan (112.5(b) Include amendments to Plan (112.5) Management approval of Plan (112.7) List all containers including oil type and volume (112.7(a)(3) Site diagram (112.7(a)(3) Analysis of spill volumes, rates, pathways/directions (112.7(b) Discuss containment methods for: tanker truckloading/unloading areas, piping, & oil filled equipment (112.7(c)– If utilized, discuss monitoring method for oil filled op equip (112.7(k) Discuss impracticability determinations (if any) (112.7(d)
  • Overview of information required tobe in your written SPCC Plan cont’d Discuss inspection methods and procedures (112.7(e),112.8(c)(6)/(d)4) Discuss training (112.7(f) Discuss security (112.7(g) Discuss truck/railcar loading/unloading rack areas (112.7(h) Discuss secondary containment systems for tanks (112.8(c)(2) Discuss liquid level sensors on tanks (112.8(c)(8) Discuss procedures for the drainage of rainwater fromcontainment structures (112.8(b) & 112.8(c)(3) Discuss piping/transfer operational requirements (112.8(d)
  • 30Amendments to SPCC Plan (§112.5) SPCC Plan must be amended within 6-months of anychange in facility design or construction whichaffects the facility’s potential to discharge oil. Technical Amendments MUST be certified by a PE{Qualified facilities may self-certify any amendments} Amendments must be implemented within 6-monthsof plan change
  • If the facility has… And… And the facility has… Then:10,000 U.S.gallons or lessaggregateaboveground oilstorage capacity;Within any twelve-monthperiod, three years prior tothe Plan certification date,or since becoming subjectto the SPCC rule if inoperation for less thanthree years, there hasbeen:(1) No single discharge ofoil to navigable waters oradjoining shorelinesexceeding 1,000 U.S.gallons; and(2) No two discharges of oilto navigable waters oradjoining shorelines eachexceeding 42 U.S. gallonsin any 12 -month periodNo individualaboveground oilcontainers greaterthan 5,000 U.S.gallons;Tier I: Completeand self-certify Plantemplate (AppendixG to 40 CFR part112) in lieu of a fullPE-certified Plan.Any individualaboveground oilcontainer greaterthan 5,000 U.S.gallons;Tier II: Prepare self-certified Plan inaccordance with allapplicablerequirements of§112.7 and subpartsB and C of the rule,in lieu of a PE-certified Plan.Qualified Facilities – (§ 112.6) (optional)
  • SPCC Plans No requirement to submit SPCC Plans to EPA EPA does not formally “approve” ordisapprove SPCC Plans Plan is required upon inspection during regularworkday
  • 33Last Word on your Written SPCC Plan Include discussions on each section and subsectionof the regulation in your Plan. Include site specific details!– Regurgitating the regulation is not adequate
  • 34Implementation of SPCCRequirements
  • Implementation Requirements Amend SPCC Plan as needed – 112.5(a & c) Review SPCC Plan at least once every 5 years – 112.5(b) Secondary containment for loading/unloading areas – 112.7(c) Secondary containment for piping – 112.7(c) Secondary containment for oil filled operational equipment – 112.7(c)– Monitoring program option for such equipment – 112.7(k) Maintain records of inspections and tests for 3-years – 112.7(e) Train oil-handling personnel on SPCC -- 112.7(f) Conduct spill prevention briefings annually – 112.7(f) Secure facility – 112.7(g) Secondary containment for truck/railcar loading racks – 112.7(h) Secondary containment for bulk storage containers – 112.8(c)(2)– Containment for bulk storage containers must be sufficiently impervious
  • Implementation Requirements Control dike drainage; keep dike valves closed; inspectrainwater before drainage event; keep records of drainevents - 112.8(c)(3) Test or inspect bulk storage containers – 112.8(c)(6) Provide liquid level sensors, alarms, gauges, devices toprevent tank overflows – 112.8(c)(8) Correct leaks/drips from tanks, piping, valves; cleanupaccumulations of oil in diked areas – 112.8(c)(10) Protect buried piping; provide proper pipe supports;Inspect piping and valves; mechanisms to protectaboveground piping from vehicles – 112.8(d)
  • 37Secondary Containment Requirements-(Two types of containment) General Provision – (§ 112.7(c): addresses the potential foroil discharges from any area within a regulated facility– In determining the method, design, and capacity for secondarycontainment, you need only to address the typical failure mode,and the most likely quantity of oil that would be discharged– Containment may be either active or passive in design Specific Provisions – (§ 112.8(c)(2), § 112.8(c)(11), § 112.7(h)):addresses the potential of oil discharges from specificparts of a facility where oil is stored or handled– Containment design, sizing, and freeboard requirements arespecified by the SPCC rule to address a major container failure
  • 38Example Methods of SecondaryContainment These are examples only.– Dikes, berms, orretaining walls– Curbing– Culverting, gutters,or other drainagesystems– Weirs– Booms– Barriers– Spill diversion pondsand retention ponds– Sorbent materials– Drip pans– Sumps and collectionsystems
  • 39General Secondary ContainmentRequirement (§ 112.7(c)) Requires secondary containment for any area within afacility where a discharge may occur:– such areas can include:Oil filled equipment (operating, manufacturing)Truck and railcar Loading/Unloading areas(non-rack transfer areas)Piping Intended to address the most likely discharge in theseareas Allows for active and passive containment measures
  • Active Containment Measures Active containment measures require deployment orother specific action by the owner or operator May be appropriate for certain discharges if it:– Can contain the volume and rate of oil– Is deployed in a timely manner– Is properly constructed Can be RISKY !!!!! ARE NOT ALLOWED FOR BULK STORAGETANKS
  • 41Specific Secondary ContainmentRequirements Areas where certain types of containers, activities, orequipment are located that are subject to more stringentcontainment requirements Specific minimum size requirement for secondarycontainment for the following areas:– Bulk storage containers – § 112.8(c)(2)– Loading/unloading racks – § 112.7(h)(1)– Mobile or portable bulk storage containers – § 112.8(c)(11)– Production facility bulk storage containers – § 112.9(c),(includes tank batteries, separation, and treating vessels/equipment)
  • Type of Facility Secondary Containment RuleSection(s)ALL FACILITIES General containment (areas with potential for discharge:piping, oil-filled operating and manufacturing equipment, non-rack related transfer areas, mobile refuelers):Loading/unloading racks:OPTION: Oil-filled equipment:112.7(c)112.7(h)(1)112.7(k)Onshore Storage Bulk storage containers:Mobile or portable oil containers:112.8(c)(2)/112.12(c)(2)112.8(c)(11)/112.12(c)(11)Onshore Production Bulk storage containers, including tank batteries,separation, and treating facility installations:OPTION: Flow-through process vessels:OPTION: Produced water containers:112.9(c)(2)112.9(c)(5)112.9(c)(6)Onshore Oil Drillingand WorkoverMobile drilling or workover equipment: 112.10(c)Offshore Oil Drilling Oil drilling, production, or workover equipment: 112.7(c)Secondary Containment Provisions
  • If the facility… And theequipment…Then the owner/operator of thefacility……has oil-filledoperationalequipment…meets the oildischarge historycriteria describedbelow…may implement an inspection andmonitoring program, develop an oil spillcontingency plan, and provide a writtencommitment of resources to control andremove oil discharged, for qualifiedequipment in lieu of secondarycontainment for the oil-filled operationalequipment…does not need to make animpracticability determination for eachpiece of equipment§ 112.7(k)(1)- To use this alternative, a facility’s oil-filled operational equipment must meetrequirements for its reportable discharge history. The facility’s oil-filled operational equipmentmust not have had (1) a single discharge of oil to navigable waters exceeding 1,000 U.S. gallonsor (2) two discharges of oil to navigable waters each exceeding 42 U.S. gallons within anytwelve-month period, in the three years prior to the SPCC Plan certification date, or sincebecoming subject to 40 CFR part 112 if operating for less than three years.Oil-filled Operational Equipment Option – (§ 112.7(k)
  • 44Bulk Storage Containers Must follow specific requirements as describedunder § 112.8(c) for bulk storage containers Oil-filled operating or manufacturing equipment are not bulk storagecontainersField Erected Tank Shop-Built Tank
  • 45Secondary Containment for Bulk StorageContainers: (§ 112.8(c)(2))1. Provide secondary containment for entirecapacity of largest single container andsufficient freeboard for precipitation2. Ensure diked areas are sufficientlyimpervious to contain discharged oil
  • 46
  • 49
  • 50Sufficiently impervious?
  • 51Sufficiently impervious?
  • 52
  • Mobile/Portable Containers – § 112.8(c)(11)(55-gallon drums, totes, skid tanks)
  • Mobile/portable containers require secondary containment (§ 112.8(c)(11)
  • 56Stormwater Drainage (§ 112.8(c)(3)) Drainage of rainwater from diked areas canbypass in-plant treatment if:– Bypass valve is normally sealed closed!!– Inspection of runoff rainwater ensures no sheen– Bypass valve is opened and resealed following drainage unresponsible supervision– Adequate records are kept of such events Records for NPDES permits are sufficient for recording stormwater bypassevents
  • 57
  • 59Inspection and Testing ofBulk Storage Containers (§ 112.8(c)(6)) Test or inspect each aboveground bulk storagecontainer for integrity on a regular schedule andwhenever material repairs are made– Determine, in accordance with industry standards (e.g.,API, STI, UL), the appropriate qualifications of personnelperforming tests and inspections and the frequency andtype of testing and inspections, which take into accountcontainer size, configuration, and design Allows integrity testing requirements that are outlined inindustry standards in lieu of integrity testing without theneed for environmental equivalence determinationscertified by a PE.
  • 61Overfill sensing devices for BulkStorage Tanks – (§ 112.8(c)(8)(i to v)) One of the following devices must be provided:– High level alarms– High liquid level pump cutoff devices– Direct audible or code signal communications– Fast response system for determining liquid levels oftanks: digital, computers, telepulse, direct visiongauges Must regularly test liquid level sensing devices
  • 62
  • 63Correction of Discharges and Clean-up ofOil Accumulations – (§ 112.8(c)(10) Promptly correct visual discharges resulting in aloss of oil from containers, seams, gaskets,piping, pumps, valves, etc Promptly remove any accumulations of oil
  • 65
  • 66
  • Loading/unloading rack means a fixed structure (such as aplatform, gangway) necessary for loading or unloading a tanktruck or tank car, which is located at a facility subject to therequirements of this part. A loading/unloading rack includes aloading or unloading arm, and may include any combination ofthe following: piping assemblages, valves, pumps, shut-offdevices, overfill sensors, or personnel safety devices.Definition of Loading/Unloading Rack
  •  Provide general secondary containment per § 112.7(c)– Design containment methods to contain the most likely discharge in these areas Provide buried piping with coating/wrapping and cathodic protection Provide proper pipe supports Inspect aboveground piping for leaks, corrosion Cap or blank flange the terminal connections Warn vehicular traffic of aboveground pipingPiping Requirements – § 112.7(c) and § 112.8(d)
  • 69
  • 71Loading Rack vs Loading/UnloadingArea Clarifications The loading/unloading rack provisions of§ 112.7(h) only apply in instances where a rackstructure is present Loading/unloading areas utilizing a single hoseand connection or standpipe are not considered“racks” --- these are loading/unloading areas (non-racktransfer areas) Loading/unloading areas require a containmentmethod per § 112.7(c)– Base containment method and volume on good engineeringpractice
  • 72Tank Car/Tank Truck Loading/UnloadingRack Requirements - (§ 112.7(h)) Tank car and tank truck loading/unloading racksrequire secondary containment to handle a spill fromthe single largest compartment of a tank car ortank truck loaded or unloaded at the facility System to prevent vehicle departure beforedisconnection Inspect vehicle drain outlets before departure
  • 73Loading Rack
  • 74LOADING RACK
  • 75Loading/Unloading Area
  • 76Security Requirements (§ 112.7(g))– Performance-based– Tailored to the facility’s specific characteristics and location A facility owner/operator is required to describe inthe SPCC Plan how facility will:– Secure and control access to all oil handling, processing andstorage areas;– Secure master flow and drain valves;– Prevent unauthorized access to starter controls on oil pumps;– Secure out-of-service and loading/unloading connections of oilpipelines; and– Address the appropriateness of security lighting to both preventacts of vandalism and assist in the discovery of oil discharges.
  • 78SPCC Spill Reporting If your SPCC facility has a dischargeabove the thresholds in §112.4, the Rulerequires the submission of additionalreporting information to EPA Reporting information must be submittedwithin 60-days of spill
  • 79For Additional Information Ted Walden EPA R4 404-562-8752walden.ted@epa.gov Steve Spurlin 731-394-8996Spurlin.Steve@epa.gov www.epa.gov/oilspill National SPCC/RCRA Hotline1-800-424-9346
  • 80