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Spill Prevention Requirements for Facilities Conducting Large Volume Transfer Operations

Overview

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.

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* 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).

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Multiagency Jurisdiction

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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.

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Integrated Contingency Planning

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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

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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.

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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.

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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.

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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.

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Many types of units are used to store oil products. Storage containers or tanks may be located aboveground, underground, partially underground, and inside buildings.

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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.

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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.

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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:

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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:

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Facilities must take precautions to ensure that tanks are not overfilled. There are two basic objectives for using a fail-safe system:

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.

 

 

 

 

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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).

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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.

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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.

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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.

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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.

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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.

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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.

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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.

 

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.

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