EPA's Region 6 Office
Serving: Arkansas, Louisiana, New Mexico, Oklahoma, Texas, and 66 Tribal Nations
Spill Prevention Requirements for Facilities Conducting Large Volume Transfer Operations
This guide is intended for facilities that transfer oil products to or from tanker trucks, marine vessels, railcars, and pipelines. All facilities that refine, store and distribute oil conduct transfer operations. Some transfer products in high frequencies and volumes, such as pipeline transfer/ terminal facilities, marine terminals, refinery marketing facilities, railyards, home heating oil and lubricating oil distributors, and others involved in the distribution of refined product. This guide discusses the equipment and operating practices needed to meet the requirements of the Oil Pollution Prevention Regulation in Title 40 Code of Federal Regulations (CFR) Part 112, which includes the Spill Control and Countermeasure (SPCC) Plan requirements and the Facility Response Plan (FRP) requirements. The SPCC requirements are the focus of this guide; other guides are available for facility response planning requirements (40 CFR 112.20 and 112.21)and general information on the Oil Pollution Prevention Regulation.
Due to the special circumstances for facilities involved
in large volume transfer operations, many of these facilities are subject
to multiagency jurisdictions for oil spill prevention and response.
For this reason, this guide addresses other agency regulatory jurisdictions.
For additional information about other agency regulatory programs, contact
information is provided in this guide.
Recommended practices for pollution prevention and avoiding
discharges of oil are also included in this guide. These practices may
also assist facilities in achieving compliance with the SPCC requirements
and reduce the possibility of product loss and a discharge.
* A discharge is essentially a spill that reaches
a navigable water or adjoining shoreline. The legal definition can be
found in 40 CFR 112.2(b).
Facilities (complexes) may be regulated by more than one agency under the Oil Pollution Act of 1990 (OPA). The EPA is responsible for the nontransportation-related facilities located landward of the coastline*. The Department of Interior (DOI) Minerals Management Service (MMS) is responsible for offshore nontransportation-related facilities located seaward of the coastline, including certain pipelines. The Department of Transportation (DOT) United States Coast Guard (USCG) or other designated agency is responsible for deepwater ports and fixed offshore facilities. The EPA is responsible for facilities in inland lakes and rivers, including certain piping, and coastal areas landward of the low water mark. The USCG handles transportation-related offshore facilities located landward of the coastline, while the DOT, Office of Pipeline Safety (OPS) handles all onshore pipelines. The OPS is a component of the Research and Special Programs Administration (RSPA).
Facilities
conducting large volume transfer operations are often regulated by more
than one regulatory body under OPA based on the jurisdictions identified
above. In addition to OPA and oil spill prevention programs, facilities
may also be regulated by the following (this list is not all
inclusive): Resource Conservation and Recovery Act (RCRA), Title 1 -
Underground Storage Tank (UST) regulations (40 CFR Part 280 and 281);
DOT railcar and tanker truck loading and unloading requirements in 49
CFR Parts 171, 173, 174, 177, and 179; DOT OPS regulations for the transportation
of hazardous liquids by pipeline in 49 CFR Part 195; the DOT USCG requirements
for facilities transferring oil or hazardous material in bulk in 33
CFR Part 154; and the Occupational Safety and Health Administration
(OSHA) requirements for flammable and combustible liquids storage in
29 CFR 1910.106.
Many sites at which oil is transferred in bulk to or from
vessels are likely to include both a transportation-related transfer
area regulated by the USCG and a nontransportation-related oil storage
area regulated by the EPA.
The division of authority is such that pipelines or hoses
leading to and from over-water operations would be regulated by the
USCG requirements, for transfers to or from a vessel with a capacity
of 250 barrels or more, while the terminal and any transfer sites within
the terminal would be regulated by EPA. The first valve within the secondary
containment area constitutes the change in jurisdiction. Similarly,
for pipeline terminals, the OPS regulates the transportation-related
portion of the pipeline running to, or from, a fixed facility, while
EPA would regulate the terminal and transfer sites within the facility.
Railyards have similar divisions of authority, with the railcars and
tracks regulated by DOT and operations within the railyard regulated
by EPA.
On June 5, 1996, the EPA published a notice in the
Federal Register announcing the availability of the National
Response Team's (NRT's) Integrated Contingency Plan (ICP) Guidance ("one
plan"). This guidance is to help owners and operators prepare emergency
response plans for their facilities. The one plan provides a mechanism
for consolidating multiple response and contingency plans that facilities
may have prepared to manage many regulations in one functional emergency
response plan. The notice contains the suggested ICP outline and guidance
on how to develop an ICP and demonstrate compliance with the regulatory
requirements. The policies set out in this notice are intended solely
as guidance and do not supersede any regulatory requirements. The ICP
must be cross-referenced to the applicable sections and page numbers
of the regulatory requirements. All requirements of regulations incorporated
into the ICP must be met.
Two components of EPA's Oil Pollution Prevention Regulation
may be included as a part of the ICP. These are the FRP (40 CFR 112.20
and 112.21)and the oil spill contingency plan and written
commitment of manpower, equipment, and materials (40 CFR
112.7(d)(1) and (d)(2)). The requirements of 40 CFR 112.7(d) must be
met by those facilities demonstrating impracticability for the installation
of containment or diversionary structures as required by 40 CFR 112.7(c).
The following regulations contain response or contingency
planning requirements that can be addressed through the ICP. The list
does not include state and local emergency response planning requirements.
Facilities are encouraged to coordinate the development of ICPs with
relevant state and local agencies.
EPA's Oil Pollution Prevention Regulation (SPCC and FRP
Requirements): 40 CFR 112.7(d) and 112.20 -112.21.
MMS's Facility Response Plan Regulation: 30 CFR 254.
RSPA's (OPS) Pipeline Response Plan Regulation: 49 CFR
194.
EPA's Risk Management Programs Regulation: 40 CFR 68.
OSHA's Emergency Action Plan Rules: 29 CFR 1910.38(a),
29 CFR 1926.35.
OSHA's Hazardous Waste Operations and Emergency Response
(HAZWOPER) Standards: 29 CFR 1910.120, 29 CFR 1926.65.
EPA's RCRA Contingency Planning Requirements: 40 CFR 264/265
Subpart D and 40 CFR 279.57.
USCG's Facility Response Plan Regulation: 33 CFR 154, Subpart F.
| Federal Agency Contact Information |
|
EPA's Oil Pollution Prevention Regulation David Lopez, MS 5203G, U.S. EPA 401 M Street, SW, Washington, DC 20460 (703) 603-8707 or EPCRA/RCRA/Superfund Hotline at (800) 424-9346 U.S. Coast Guard's Facility Response Plan Regulation LCDR Mark Hamilton, U.S. Coast Guard, Commandant (G-MOR),2100 2nd Street, SW, Washington, DC 20593, (202) 267-1983 (E-mail M.Hamilton/G-M03@CGSMTP.uscg.mil) DOT/RSPA's Pipeline Response Plan Regulation Jim Taylor, U.S. Department of Transportation, Room 2335,400 7th Street, SW, Washington, DC 20590 (202) 366-8860 (E-mail OPATEAM@RSPA.DOT.GOV) OSHA Regulations Contact either your Regional or Area OSHA office by calling
directory service or the OSHA National Information Line at (800)
326-2577 DOI/MMS Facility Response Plan Regulation Larry Ake, U.S. Department of the Interior-- Minerals Management Service, MS 4700,381 Elden Street, Herndon, VA 22070-4817 (703) 787-1567 (E-mail Larry__Ake@SMTP.MMS.GOV) EPA's Risk Management Program Regulation William Finan, U.S. EPA, Mail Code 5101,401 M Street, SW, Washington, DC 20460, (202) 260-0030 (E-mail homepage.ceppo@epamail.epa.gov) RCRA's Contingency Planning Requirements Contact the EPCRA/RCRA/Superfund Hotline at (800) 424-9346 |
Applicability of EPA's
SPCC Requirements
EPA's SPCC requirements (40 CFR 112.1 through 112.7) apply
to nontransportation-related facilities that could reasonably be expected
to discharge oil into or upon the navigable waters of the United States
or adjoining shorelines, and that have (1) a total underground buried
storage capacity of more than 42,000 gallons; or (2)
a total aboveground oil storage capacity of more than 1,320
gallons, or (3) an aboveground oil storage capacity of more than 660
gallons in a single container.
Some facilities may not be regulated if, due to their
location, they could not reasonably be expected to discharge oil into
navigable waters of the U.S. or adjoining shorelines. SPCC-regulated
facilities must also comply with other federal, state, or local laws,
some of which may be more stringent.
Many facilities involved with high volume product transfers
associated with pipelines and marine vessels are also subject to the
Facility Response Plan (FRP) requirements of 40 CFR 112. The FRP requirements
can be found at 40 CFR 112.20, 112.21 and associated Appendices A-F.
As outlined in 40 CFR 112.20(f)(1), a facility has the
potential to cause substantial harm and, therefore, must prepare an
FRP if:
- The facility transfers oil over water to or from vessels and
has a total oil storage capacity, including both aboveground storage
tanks (ASTs) and underground storage tanks (USTs), greater than
or equal to 42,000 gallons; or
- The facility's total oil storage capacity, including both ASTs
and USTs, is greater than or equal to one million gallons, and
one of the following is true:
- The facility lacks secondary containment that is able to contain
the capacity of the largest AST within each storage area plus freeboard
to allow for precipitation;
- The facility is located at a distance such that a discharge from
the facility could cause injury to an environmentally sensitive
area;
- The facility is located at a distance such that a discharge from
the facility would shut down a public drinking-water intake; or
- The facility has had a reportable spill greater than or equal
to 10,000 gallons within the last five years.
All facilities must document the determination of substantial harm by completing the "Certification of the Applicability of the Substantial Harm Criteria Checklist," provided as Attachment C-II in Appendix C of 40 CFR 112. This certification should be kept with the facility's SPCC Plan.
SPCC and Specific Spill Prevention Requirements
The owner or operator of an SPCC-subject facility is required to have a written site-specific spill prevention plan, which details how a facility's operations comply with the requirements of 40 CFR 112.
Requirements for specific elements to be included in the SPCC Plan are found in 40 CFR 112.7. The SPCC Plan must be reviewed and certified by a Registered Professional Engineer who is familiar with SPCC and has examined the facility. To be in compliance, the facility's SPCC Plan must satisfy all of the applicable requirements for drainage, bulk storage tanks, tank car and truck loading and unloading, transfer operations (intrafacility piping), inspections and records, security, and training. Most importantly, the facility must fully implement the SPCC Plan. Newly constructed facilities and facilities that make modifications must prepare or revise their SPCC Plan within six months. Modifications may include, for example, changes in piping arrangements or installation or removal of tanks.
SPCC requires containment of drainage from the operating
areas of a facility to prevent oil spills and contaminated runoff from
reaching storm drains, streams (perennial or intermittent), ditches, rivers,
bays, and other navigable waters.
Secondary containment and diversionary structures should
be in place to contain oil-contaminated drainage (e.g., rainwater) or
leaks around fuel dispensers, pipelines, valves, joints, transfer connections,
and tanks. For these purposes, facilities should use dikes, berms, curbing,
culverts, gutters, trenches, absorbent material, retention ponds, weirs,
booms, and other barriers or equivalent preventive systems. SPCC requirements
are performance-based, which permits facility owners and operators to
substitute alternative forms of spill containment if the substitute provides
substantially equivalent protection against discharges to navigable waters
to that provided by the systems listed in 40 CFR 112.7(c).
Substantially equivalent containment systems may be possible
for AST systems (e.g., small double-walled ASTs equipped with spill prevention
devices) that generally have capacities of less than 12,000 gallons. Alternative
containment systems may not be appropriate for tank systems larger than
12,000 gallons or for systems that consist of several tanks connected
by manifolds or other piping arrangements that would permit a volume of
oil greater than the capacity of one tank to be spilled as a result of
a single system failure.
Facilities conducting transfer operations may have spills
that could be released to waterways by means other than direct overland
flow. For example, if a terminal does not have adequate curbing or diking
to prevent spills from oil transfer operations, then a release may reach
a storm drain which empties into a navigable waterway. Many transfer operations
utilize drip pans or drains under transfer connections which may route
spills to an oil-water separator or onsite wastewater treatment plant.
Trained personnel must inspect the effluent prior to discharging so these
systems must be manually controlled. Systems which automatically discharge
to a storm drain, sewer or other offsite system are not in compliance
with the regulations. An automatic system is not acceptable because if
it were to be overloaded, a malfunction and a discharge of oil is likely
to happen.
Facilities most often use poured concrete walls or earthen
berms to contain drainage and provide secondary containment for storage
tanks and curbing and catchment basins for truck loading/unloading areas.
These contained areas are considered diked areas. Concrete and earthen
dike containment structures around storage tanks may accumulate significant
amounts of water. Drain lines, which must be watertight, are usually installed
through the dike walls and are used to drain accumulated stormwater from
the diked area. These lines should be fitted with valves or other positive
means of closure that are normally sealed closed and locked to prevent
any oil discharges from escaping the diked area. These valves must be
open-close manual valves; flapper valves are not acceptable.
These
valves must be opened to drain rainwater and resealed following drainage
by trained and authorized facility personnel only. Adequate records must
be kept of such drainage events (i.e., date, time, personnel names) and
made part of the SPCC Plan. The accumulated rainwater must be examined
and determined to be free of oil contamination before diked areas are
drained. If any oil sheen or accumulation of oil is observed, an alternate
method of draining the diked area must be employed. The contaminated water
may be diverted to an onsite treatment plant or oil-water separator; however,
the adequacy of these systems is determined on a case-by-case basis for
each one's adherence to good engineering practices and ability to retain
a spill in the event of a system malfunction.
Facilities may employ many different types and designs of drainage control systems and oil-water separators. Facilities must implement a system that is consistent with good engineering practices, based on the size and complexity of their operations.
The secondary containment structure must be impervious and must prevent water and fuel from percolating through the soil, contaminating the soil and groundwater and possibly surfacing aboveground into navigable waters or adjoining shorelines.
Other operating areas that do not have secondary containment
systems specifically designed for those areas (otherwise referred to as
"localized containment") are considered undiked areas. Drainage
must be controlled for undiked areas which may include truck or engine
washdown areas, piping and manifold areas, garage bays, and fuel islands.
All undiked areas can be designed to control drainage through a combination
of curbing, trenches, catchment basins, and retention ponds, as necessary
to retain a spill. These structures must be inspected and examined for
integrity and their effectiveness. For example, if a paved area is improperly
graded or if a curb is deteriorating, contaminated water may escape from
the facility. For this reason, a Professional Engineer must certify the
SPCC Plan to ensure that the drainage system is adequately designed and
properly maintained in accordance with good engineering practices.
Whatever techniques are used, the facility's drainage systems
should be adequately engineered to prevent oil from reaching navigable
waters in the event of equipment failure or human error at the facility.
Many types of units are used to store oil products. Storage
containers or tanks may be located aboveground, underground, partially
underground, and inside buildings.
No tank should be used for the storage of oil unless its
construction material is compatible with the material stored and conditions
of storage such as pressure, physical and chemical properties, and temperatures.
It is recommended that the construction, materials, installation,
and use of tanks conform with relevant portions of industry standards,
such as American Petroleum Institute (API), National Fire Protection Association
(NFPA), Underwriters Laboratory (UL), or American Society of Mechanical
Engineers (ASME), which may be required in the application of good engineering
practices or by state or local regulations.
All storage containers (e.g., tanks, oil-water separators)
must have secondary containment for the entire contents of the largest
single container within the containment area, plus sufficient freeboard
to allow for precipitation. An alternative system could consist of a complete
drainage trench enclosure arranged so that a spill could terminate and
be safely confined in a catchment basin. The containment structure must
be sufficiently impervious to the types of oil products stored at a facility.
Diked areas should be free of pooled oil; spills should be removed promptly.
The
volume of freeboard should be based on regional rainfall patterns. Facilities
in states with large amounts of rainfall (e.g., Washington, Alaska, and
Hawaii, and the Commonwealth of Puerto Rico) will require secondary containment
to accommodate greater amounts of water.
Precipitation data is available from the National Oceanic
and Atmospheric Administration's (NOAA) National Climatic Data Center
(NCDC). The NCDC can be reached by telephone at (828) 271-4800 and at
http://www.ncdc.noaa.gov/oa/climate/research/monitoring.html on the worldwide web.
The following table describes the most common secondary containment systems.
| Secondary Containment Systems | |
| Type of System | Description |
| Poured Concrete Walls | Poured concrete walls are strong, fairly watertight, and resistant
to petroleum penetration if adequately designed and maintained according
to good engineering practices. Limitations:
|
| Containment Curbs | Containment curbs are similar to speed bumps and are often used
where vehicles need to access the containment area. Limitations:
|
| Containment Pits/Trenches | Pits or trenches are belowgrade containment structures, which
may be covered with metal grates and lined with concrete. Limitations:
|
| Earthen Berms | Earthen berms containing clay or bentonite mixtures are commonly
used at very large oil storage facilities. Limitations:
|
| Concrete Block Walls | Concrete block walls are also commonly used for containment. Limitations:
|
ASTs should be properly maintained to prevent oil leaking
from bolts, gaskets, rivets, seams, and any other part of the tank. The
older riveted or bolted steel tanks tend to "weep" oil from
rivets and bolts.
Personnel should note visible oil leaks on an inspection
form and report them to the person in charge of spill prevention. Leaks
should be repaired immediately. In some cases, the product in the tank
will require removal.
Another area of concern for ASTs is tank bottom deterioration.
Tank bottoms may be subject to extensive corrosion, which may not be evident
during visual inspections. Measures must be taken to prevent this corrosion
based on the type of tank installation and tank foundation. Corrosion
protection can be provided by dielectric coatings and carefully engineered
cathodic protection. Some facilities have installed double-bottom tanks
to reduce the corrosion factor.
Corrosion of a tank's surface may also result in tank failure.
Corrosion that is concentrated in small areas of a tank's surface or "pitting"
creates a high potential for tank failure. If tanks are rusty, holes may
form causing the tank to leak. Tank supports and foundations should also
be inspected for cracks, crumbling, deterioration, and seepage.
ASTs should be subjected to periodic integrity testing. Some of the accepted methods for testing are the following:
- X-ray or radiographic analysis measures wall thickness and detects cracks and crevices in metal.
- Ultrasonic analysis measures shell metal thickness.
- Hydrostatic testing shows leaks caused by pressure.
- Visual inspection detects some cracks, leaks, or holes.
- Magnetic flux eddy current test used in conjunction with ultrasonic analysis detects pitting.
Internal steam-heating coils are sometimes used in heavy
oil tanks to maintain the oil in a fluid, less viscous state in cold weather.
The deterioration of the steam-heating coils from internal corrosion can
result in product leakage when oil drains through a corroded coil to discharge
into a nearby waterway. To control leakage through defective internal
heating coils, the following factors should be applied:
- The steam return or exhaust lines from internal heating coils that
discharge into an open water course should be monitored for contamination
or routed to a settling tank, skimmer, or other separation system
to remove oil;
- Consider using external heating coils and insulating the sides of
the tank if necessary. Because of the problems encountered with internal
steam-heating coils, there has been a movement away from their use
to more modern external heat-exchanger systems.
Facilities
must take precautions to ensure that tanks are not overfilled. There are
two basic objectives for using a fail-safe system:
- prevent the tank from overfilling and spilling liquid.
- prevent damage to the tank.
Level gauging systems must be selected in accordance with good engineering practices based on the size and complexity of operations at a facility. It is not adequate to only "stick" a tank. A second overfill protection measure should be used as a backup. Some trucks have automatic shutoff systems, which shut off the pump once the meter reaches the volume of product that has been determined to be a safe fill level (e.g., 90% of capacity).
Larger tanks may be designed with gauges, high-level alarms,
and high-high level alarms to satisfy this requirement. The following
table contains examples of acceptable systems.
| Level Gauging Systems and Alarms | |
| Type of System | Description |
| Direct Sight Level Gauges | In the simplest case, the gauge is a small-diameter glass or plastic
tube vertically attached to two openings in the tank shell. Liquid
level in the tank is shown by the level in the tube. Another common sight level gauge is a float gauge. A float rides on top of the liquid in the tank and moves a marker attached to a cable or chain on the outside of the tank. The marker moves up or down with the product level in the tank. |
| Digital Computers or Telepulse | Telepulse is a simple and accurate system for remote supervision of storage tank liquid levels and temperatures. The unit consists of a transmitter and receiver to relay and receive tank temperature and product level readings. Digital computers can be tied in to display data at more than one location. Portable fill alarm systems are also available that can be used while liquid cargoes are transferred from a storage container into a transportation vehicle. Many variations of these systems are in use. |
| High Liquid Level Alarms | High liquid level alarms are usually tied into a float gauge or level gauging system. The alarms produce an audible or visual signal when the liquid level in the tank reaches a predetermined height. In older systems, a simple sound is produced by air motion; this is called an audible air vent. |
| High Liquid Level Pump Cutoffs | This consists of a fill-level alarm connected to a pump control that automatically shuts down the pump when a preset liquid level is reached. This system eliminates the possibility of human failure and is effective at stopping overfilling of tanks. |
| Direct Audible/Code Signal Communication | This system consists of communication between the tank gauger and pumping station and relies on human perception of liquid levels in the tanks and pumping rates to avoid overfilling tanks. Human error could cause a spill if the tank gauger or pumping station misreads an audible or code signal to start or stop pumping. Communication between the gauger and pump station is usually through two-way radio. |
| Additional Safety Features | Relief valves and overflow lines are part of safety and level control systems on most petroleum storage tanks. Valves for pressure and vacuum relief will prevent tank damage but may result in a spill or discharge of liquid. Excess liquid may be allowed to flow into another tank through an overflow line. Vacuum vents prevent a tank from collapsing when liquid is pumped out of the tank. |
Underground Storage Tanks
When compared to ASTs, USTs have some advantages for storing petroleum
products, such as reduced vapor loss, increased safety, efficient land
use and greater security. The obvious disadvantages are undetected leaks
and higher corrosion factors for metal tanks. Fiberglass-reinforced plastic
tanks are commonly used for storing petroleum products underground. They
have a distinct advantage over metal tanks in being corrosion-free. Corrosion-resistant
coatings are also available.
Steel USTs should be protected from corrosion by coatings, cathodic protection,
or other effective methods compatible with local soil conditions. Underground
corrosion of metal surfaces is a direct result of an electric current
that is generated by the reaction between the metal surfaces and chemicals
present in the soil and water. The flow of current from one portion of
the tank to another causes metal ions to leave the surface of the metal,
creating pits. The rate of destruction of the metal is directly related
to soil moisture and chemical makeup.
All USTs should also be subjected to regular pressure testing and adequate
records must be kept of such tests. These records must be made part of
the SPCC Plan and kept for at least three years.
The federal UST regulations found in 40 CFR 280 have technical
requirements consistent with the underlying regulatory purposes of the
SPCC program and are equally protective for purposes of preventing discharges
of oil into waters of the United States. These regulations contain provisions
for corrosion protection, leak detection, tank overfill and spill prevention
equipment, and tank tightness testing. Facilities should refer to the
full text of 40 CFR 280 when making determinations of compliance.
Partially buried metallic storage tanks used for petroleum
storage should be avoided unless the buried section of the shell is adequately
coated. Partial burial in damp earth can cause rapid corrosion of metallic
surfaces due to water collecting at the soil surface. Protective corrosion-resistant
coatings and cathodic protection should be used to prevent corrosion.
Partially buried tanks are considered to be aboveground tanks and are
subject to the same requirements as other aboveground tanks under the
provisions of 40 CFR 112 due to their potential threat to surface waters.
Mobile
or portable oil storage tanks (including trucks containing product), 55-gallon
drums, and other small containers should be positioned or located so as
to prevent spilled oil from reaching navigable waters. A secondary means
of containment, such as dikes, basins, or spill pallets, must be provided.
The containment area must hold the contents of the largest container stored
in the area. Many facilities keep drums and portable oil tanks inside
covered, contained warehouse storage areas. It is best to have a covered
area to reduce exposure to the elements so that the containers remain
in good condition and runoff is eliminated.
These storage areas must be located where they will not
be subject to periodic flooding or washout.
Transfer operations consist of piping, valves, gauges, regulators,
compressors, pumps and other mechanical devices used to transfer oil from
one area to another within a facility. Pipelines used to transport oil
for interstate or intrastate commerce are considered transportation-related
systems and are regulated under the DOT OPS program. Pipelines which are
used for the transport of oil exclusively within the confines of a nontransportation-related
facility are regulated under the EPA SPCC program. Some of the more common
mechanical transfer systems are the piping systems required to transfer
product between tanks and railcar or truck loading and unloading areas.
SPCC requires that the terminal connection at the transfer point be capped
or blank-flanged and marked as to origin for a pipeline that is not in
service or in standby service for an extended time. Aboveground pipe supports
should be designed and spaced in order to prevent sagging, minimize abrasion
and corrosion, and allow for expansion and contraction.
Buried piping must have a protective wrapping and coating,
and should be cathodically protected if used in corrosive soil conditions.
If any section of buried piping is exposed for any reason, it must be
examined for deterioration and corrosion and repaired, if necessary. Obviously,
buried piping cannot be visually examined and must be subjected to periodic
pressure testing, regardless of materials of construction. Plastic or
fiberglass-reinforced pipes do not require protective coatings or cathodic
protection.
All aboveground pipes and valves should be regularly examined
on a scheduled basis by operating personnel. Flange joints, expansion
joints, valve glands and bodies, and metal surfaces should be evaluated.
Piping in high spill probability areas should be periodically subjected
to pressure testing. Pipes, valves, and connecting joints should be free
of leaks, drips, and oil-saturated soil underneath. Defective or leaking
equipment should be replaced or repaired, and adequate records should
be made of such repairs. All records should be made part of the SPCC Plan
and kept for at least three years.
Pumps, valves, and gauges are covered under the same regulations
as piping. They must be regularly examined by facility personnel. They
should be free of leaks, drips, or any defects which could lead to a spill.
Soil underneath pumps, valves, and connections should be free of oil stains
or pooled oil. Flow valves must be periodically packed with grease to
prevent leakage, and gaskets must be replaced periodically. Pumps require
periodic rebuilding and connecting lines need to be resealed to prevent
leaks.
Drivers granted entry into a facility must be verbally cautioned
or warned by appropriate signs to assure that their vehicle, because of
its size, will not endanger aboveground piping or hosing. Tank truck loading/unloading
areas should have appropriate protection for aboveground pipes (e.g.,
bumper poles) and adequate signs posted to warn drivers of the presence
of aboveground pipes in traffic areas.
Tank
car (rail car) and tank truck loading/ unloading areas, due to their function,
are high spill probability areas. Large volumes of petroleum products
move through these areas, increasing the probability of spills.
Regardless of the types of trucks servicing a facility,
all drivers must follow loading/ unloading procedures established by the
Department of Transportation (DOT) in 49 CFRs 171, 173, 174, 177, and
179. Training programs should thoroughly address these requirements and
procedures should be incorporated into a Standard Operating Procedures
(SOP) manual for product transfer. Moreover, facilities should consider
ways to ensure that other commercial drivers or contractors are competent
in these procedures (e.g., issue driver certifications).
Secondary containment systems must be designed specifically
for a facility's topography configuration and the size of the tank car
or tank truck loading or unloading at the site.
Loading/unloading areas typically are designed to permit
vehicle access and incorporate a secondary containment system. The most
common tanker truck loading/unloading area containment system is a covered,
curbed, and graded area that drains to a catchment basin. Railcar loading/unloading
areas can be contained by incorporating a catchment basin underneath the
railroad track.
The containment system must be designed to hold the maximum
capacity of the largest compartment of a tank car or truck loaded or unloaded
at the facility. For facilities that load or unload from "unit trains,"
the containment system must be capable of containing the aggregate volume
of product for all open railcars/compartments which may be linked to the
manifold in a series for product transfer at the same time. If there are
separate areas for different unloading or loading operations, each area
should be designed specifically to hold the capacity of the largest carrier
anticipated to conduct operations in that area. An engineer must look
at the entire facility as a unit to determine the adequacy of the spill
containment systems in place.
An interlocked warning light or physical barrier system
(such as a brake-interlock system), or warning signs should be provided
in loading/unloading areas to prevent bottom-loading vehicles from leaving
before being completely disconnected from the fuel transfer lines.
Prior to filling and departure of a tank car or truck, the lowermost drain
and all outlets of such vehicles should be closely examined for leakage.
If necessary, valves should be tightened, adjusted, or replaced to prevent
leaking in transit.
Inspections are an important part of preventing spills due
to equipment or containment system failure. Adequate inspection and maintenance
programs are a critical component of a spill prevention program. Inspection
and maintenance records provide the only real evidence of compliance testing
of storage tanks, piping, level gauging systems, alarms and related equipment.
Records of inspection procedures (including frequencies
of inspections), maintenance, and draining of diked areas should be included
in the facility's SPCC Plan.
Records of drainage of diked areas are important in determining
a facility's compliance, especially when drainage flows directly into
a navigable waterway and bypasses in-plant treatment systems.
The following table includes the types of records that should be maintained at a facility. Such records must be kept for a minimum of three years.
| Inspection and Maintenance Program Records | |
| Aboveground Storage Tanks and Piping | Regular visual inspections and/or tank integrity testing
(e.g., shell thickness testing). Pipe supports, pipes, valves and pumps (regular visual inspections).
Piping in high risk spill areas (periodic pressure testing).
Storage tank flow valves, supports, foundations (regular visual
inspections). Storage tank level gauges and alarms (regular mechanical function testing/visual inspections). |
| Underground Storage Tanks and Piping | Pressure testing of tanks and piping. Inventory monitoring for leaks. Testing of cathodic protection system. |
| Dikes, Berms, Secondary Containment Systems | Containment dikes and berm integrity (regular visual inspections).
Records of drainage of rainwater from diked containment areas
(must be recorded whenever areas are drained). Rainwater must be free of oil sheen. Date, time, and signature of employee who performed drainage and/or manager. |
Security is critical to preventing accidental releases or vandalism by
the public. The security measures required under SPCC are simple precautions
that greatly reduce the risks of vandalism and undetected spills.
The perimeter of a facility should be protected with good
lighting, fencing, and locked gates. Motion detectors and video cameras
may be used for added security. Access to the facility should be restricted
during nonbusiness hours. Starter controls for fuel pumps should be locked.
Any valves that will allow the direct outflow of product are also required
to be locked (e.g., water draw-off, sampling, and sparge valves). It is
recommended that tanks and pipelines be labeled and kept out of public
access areas. Loading/ unloading connections and pipelines should be capped
or blank-flanged when they are not in service.
A large number of spills are caused by operator error; therefore, training and briefings are important for the safe and proper functioning of a facility. Training encourages up-to-date planning for the control and response to a spill and an understanding of the facility's spill prevention controls and SPCC Plan. Regular safety and spill prevention briefings should be held to facilitate discussions of spill events or failures, malfunctioning equipment, and recently developed precautionary measures. Also, one person must be designated accountable for spill prevention at the facility.
Owners and operators are responsible for properly instructing
drivers, tank gaugers, pumpers, and any other operating personnel involved
in oil operation systems in the operation and maintenance of equipment
to prevent the discharge of oil and applicable pollution control laws,
rules and regulations. All employees should be familiar with the SPCC
Plan and where it is kept, or have a copy of the Plan available for their
use.
Records of employee training and spill prevention briefings
for personnel should be included in the SPCC Plan and kept for a minimum
of three years.
Facilities should consider current operations and how they can be improved
to prevent spills and meet the regulatory requirements by conforming with
good engineering practices. To this end, the questions and answers appearing
below are based on practices observed by federal, state, and local regulatory
agencies. Some of the issues and practices discussed are best management
practices (BMPs) and may be supplemental to the regulatory requirements.
Others may be essential to achieving compliance with the SPCC requirements
or state regulations.
What types of procedures or equipment are in
place at the facility to prevent and control a product discharge in the
event of a human error or equipment malfunction?
Make sure that all valves are working properly. Shutoff
valves that do not work properly may result in spills. These spills must
be cleaned up by the attendants or drivers immediately and the valve must
be repaired or replaced.
How does the facility manage drainage of diked
areas (or other water accumulation areas?)
Facilities must ensure that drainage valves are in the closed
position. At the close of each business day and during and after storm
events, facility personnel should double-check the position of the valves.
Facilities must develop checklists and logs for noting the appearance
of the water in diked areas. Checklists should note the time of valve
opening and valve closing, and should be signed by trained, authorized
personnel. Facility managers should make sure the checklists and logs
have been adequately completed to evidence that all drainage procedures
are properly followed.
If an overfill were to occur while filling an
underground storage tank (UST), does the facility have response equipment
in place to control the discharge?
The overflow protection equipment on USTs may only hold
a small spill. Diversionary structures, such as curbing, must also be
in place for UST filling areas. The containment areas must be capable
of holding the contents of the largest single compartment of a tank car
or truck that loads or unloads at the facility. Facilities should also
have emergency response kits available nearby to contain any spills that
occur.
The UST regulations found in 40 CFR Part 280 have many requirements
for overfill protection, such as in-line leak detection and automatic
pump shutoff systems, which may be applicable to the facility.
What is the facility's protocol for maintaining
the exteriors and interiors of aboveground storage tanks (ASTs) to prevent
corrosion?
Facilities must follow good engineering practices to identify
when it is appropriate and necessary to paint or coat ASTs and to retrofit
tanks with liners. Internal corrosion, due to standing water inside the
tank, is a contributing factor to tank failure. The water, being denser
than the hydrocarbon product, collects in the bottom of the tank and corrodes
the tank walls and bottom.
Are there visible oil stains in containment
areas?
Oil leaks from tank seams, gaskets, rivets, and bolts must
be cleaned immediately and the surfaces of containment areas should be
kept clean. The leaking equipment should be repaired immediately. Washdown
waters must be removed for proper disposal or treated prior to discharge
to remove all oil contamination.
What is the facility's protocol for conducting
integrity tests on tanks?
SPCC requires integrity testing, and each facility is responsible
for determining which type of test is warranted based on good engineering
practices and a regular schedule for these tests. To determine a schedule,
the facility should consider the tank's age, location, and exposure. Tanks
should also be integrity tested after earthquakes and major storms.
Is the facility located in a flood-prone area?
Tanks in flood-prone areas should be designed so that the
lowest floor is elevated to or above the base flood level or be designed
so that the structure below the base level is watertight with walls substantially
impermeable to the passage of water, with structural components having
the capability to resist effects of buoyancy.
How does the facility prevent pipeline ruptures?
Monitor pressure in piping systems, especially in the summer
when temperatures may be high. Regulate pumping pressure so that the piping
pressure does not exceed its pressure rating. Couplings and connections
should have pressure ratings compatible with piping systems. Pressure-test
piping before returning it to service and at regular intervals while in
service.
How does the facility maintain flexible hosing?
Do not allow hosing to become twisted or kinked and avoid
sharp bends. Be sure to stay within the manufacturer's recommended bend
radius. Change flexible hosing when it is cracking or shows signs of excessive
wear. Replace or repair connections and piping when leaks occur.
Are the loading/unloading procedures identified
in the SPCC Plan readily available and visible to all facility personnel
and contractors involved in product transfer operations at the facility?
In addition to displaying procedures on signs, supervise
transfer operations and ensure that drivers are knowledgeable in the correct
use of equipment and critical oil spill response measures.
How are equipment leaks controlled and responded
to at the loading/unloading racks and fuel dispensers?
When equipment, such as shutoff valves, does not function
properly, repair it immediately. Clean up and contain spills quickly.
Use catch buckets to control leakage from loading arms and terminal connections.
To control leaks and spills from fuel dispensers, install catch pans with
a leak-monitoring system.
Waterfront facilities or marine docks should consider using
drains under all hose connection positions. Drippage and drainage can
be routed to collection tanks and reinjected back to storage. Covers or
valves should be used to prevent stormwater from entering the system.
How is the facility's equipment protected from
vehicle impact?
All fuel tanks, pipelines, and dispensers should be protected
by installing bumper poles and other physical barriers and warning signs,
including signs identifying truck clearances.
How does the facility document spill prevention
inspections?
Prepare facility-specific checklists for inspections of
ASTs, valves, piping, pumps, dikes, oil-water separators, drainage sumps,
monitoring devices, alarms, gauges, the truck loading/ unloading rack,
and spill control equipment. Use these checklists during equipment inspections.
What is the facility's protocol for maintaining
equipment and correcting visible oil leaks?
Institute a regular preventive maintenance program to prevent
leaks, equipment malfunctions, and spills. Replace worn seals, fittings,
and other parts before they leak or break. Pipeline valves which exhibit
incomplete shutoff of flow, difficulty in operation of moving parts, or
leakage of fluid to the outside of the valve indicate a need for corrective
action.
Wastewater or stormwater treatment system equipment, including
oil-water separators, must be regularly maintained to prevent clogging
and other problems that may lead to equipment failure.
Is the site adequately protected against vandalism?
Fences should completely enclose operating areas and be
adequately designed to prevent passage (consider the height and durability
of the fence). Consider installing motion detectors for activating lights
at night. Make sure that all equipment that would permit the flow of product
is adequately locked down.
Is the facility's training program adequate
to maintain personnel awareness of the spill prevention techniques described
in the SPCC Plan and correct operating procedures?
Owners or operators are responsible for instructing their
personnel in the operations and maintenance of equipment to prevent the
discharges of oil and applicable pollution control laws, rules, and regulations.
Refresher training should be conducted at regular intervals.
Training should include testing to ensure that personnel, especially new
hires, have an understanding of the concepts discussed.
Does the facility have a spill response plan?
For those facilities not required to prepare a facility
response plan under 40 CFR 112.20, it is still recommended to develop
a spill response plan. Provide this plan to the fire department and local
response agencies. Have frequent drills and invite local responders to
participate.
Keep spill kits containing absorbent pads, booms, shovels,
disposal containers or bags, an emergency response guidebook, and a fire
extinguisher in a cabinet or locker near the storage and loading/unloading
areas. Regularly inspect the cabinet where emergency spill response supplies
are kept to ensure the cabinet is properly stocked.
One way for facilities to be prepared for larger spills
is by establishing a contract with a spill response organization, for
additional assistance and an expedient response.
There are a variety of ways for a facility to be designed and constructed to achieve compliance with the SPCC requirements.
Facilities may differ greatly in the types of diversionary
structures and spill control equipment employed. Small facilities may
utilize simple yet effective methods while large facilities may employ
state-of-the-art technologies to treat contaminated drainage, achieve
overfill protection on tanks and tank trucks, conduct integrity testing,
provide facility security, and train employees. Facilities should also
consult industry associations, which specifically identify technical and
engineering standards for the design and construction of tanks and pipelines;
cathodic protection of tanks and pipelines; AST tank bottom liners; tank
inspection, repair, alteration, and reconstruction; tank cleaning; and
tank overfill protection. These standards may assist the facility in identifying
good engineering practices and achieving compliance with the SPCC requirements.
| Summary of Common Industry Standards | |
| Underwriters Laboratory
(UL) Standard 142
Steel Aboveground Tanks for Flammable and Combustible Liquids |
This standard applies to steel atmospheric tanks intended for aboveground storage of noncorrosive, stable, flammable, and combustible liquids that have a specific gravity not exceeding that of water. The standard does not apply to API Standard 650, 12D, and 12F tanks. |
| National
Fire Protection Association (NFPA) Code 30A
Automotive and Marine Service Station Code, Chapters 1 and 2 |
This standard applies to automotive and marine service stations and to service stations located inside buildings (special enclosures). The code does not apply to service stations that dispense liquefied petroleum gas, liquefied natural gas, or compressed natural gas as motor fuels. |
| National Fire Protection Association (NFPA) Code 30
Flammable and Combustible Liquids Code, Chapter Two |
This standard applies to all flammable and combustible liquids, including waste liquids (except those that are solid at 100 degrees Fahrenheit or above and those that are liquefied gases or cryogenic). Chapter Two, Tank Storage, applies to aboveground and indoor storage of liquids in fixed tanks and portable tanks with storage capacities of more than 660 gallons. |
|
American Petroleum Institute (API) Standard 620
Design and Construction of Large, Welded, Low-Pressure Storage Tanks |
This standard addresses large field-assembled storage tanks that have a single vertical axis of revolution and contain petroleum intermediates and finished products, as well as other liquid products handled and stored by the petroleum industry. |
| API Standard 650
Welded Steel Tanks for Oil Storage |
This standard provides material, design, fabrication, erection, and testing requirements for vertical, cylindrical, aboveground, closed- and open-top, welded steel storage tanks in various sizes and capacities. |
| API Recommended Practice 651
Cathodic Protection of ASTs |
This recommended practice describes the corrosion problems characteristic in steel ASTs and associated piping systems and provides a general description of the two methods used to provide cathodic protection. |
| API Recommended Practice 652
Lining AST Tank Bottoms |
This recommended practice describes the procedures for achieving effective corrosion control in ASTs by application of tank bottom linings to existing and new storage tanks. |
| API Standard 653
Tank Inspection, Repair, Alteration, and Reconstruction |
This standard pertains to carbon and low alloy steel tanks built in conformance with API Standard 650 or 12C and provides criteria for the maintenance, inspection, repair, alteration, relocation and reconstruction of welded or riveted, nonrefrigerated, atmospheric pressure ASTs after they have been placed in service. |
| API Recommended Practice 920
Prevention of Brittle Fracture |
This recommended practice addresses toughness levels for pressure vessels to prevent failure by brittle fracture. |
| API Standard 2015
Safe Entry and Cleaning of Tank |
This standard provides guidelines for the development of safety practices for planning, managing, and conducting work in atmospheric and low pressure storage tanks. |
| API Recommended Practice 2350
Overfill Protection for Petroleum Tanks |
This recommended practice provides guidelines for establishing operating procedures and for selecting equipment to assist in the reduction of overfills. |
| API Standard 2610
Design, Construction, Operation and Maintenance and Inspection of Terminal and Tank Facilities |
This standard compiles various standards, specifications, and recommended practices developed by API and other entities for managing terminals and tanks. |
Acknowledgments
We would like to acknowledge Bobbie Lively - Diebold, U.S.
EPA Headquarters and their valuable assistance in the preparation of this
guide. The following publication provided valuable assistance: U.S. Environmental
Protection Agency, 1995. SPCC/OPA Manual. U.S. EPA Region VIII,
Ecosystem Protection and Remediation Preparedness Team. Denver, Colorado.
