SPCC Requirements and Pollution Prevention Practices for Vehicle Service Facilities

This guide will assist vehicle service facilities with the prevention and control of oil spills. Other guides have been developed to assist other industry sectors in the regulated community. This guide discusses the equipment and operating practices needed to meet the requirements of the Federal Oil Pollution Prevention Regulation found in Title 40 Code of Federal Regulations (CFR) Part 112, which includes the Spill Prevention 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 the facility response planning requirements (40 CFR 112.20 and 112.21) and general information on the Oil Pollution Prevention Regulation.

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).

Applicability of the SPCC Requirements to Vehicle Service Facilities

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.

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 vehicle service facilities require the storage of oil products (e.g., motor oil, hydraulic oil, brake fluid, gasoline, and diesel) for maintenance and fueling activities. These facilities range from small auto repair shops and gas stations to truck repair garages and truck stops. It is important for these facilities to recognize that they may be subject to the SPCC requirements by either meeting the regulated aboveground storage tank (AST) volumes or underground storage tank (UST) volumes. In either case, if a facility is subject to SPCC, then all storage tanks, both ASTs and USTs, at a facility are required to meet the spill prevention measures prescribed in 40 CFR 112.7. For example, if a facility stores over 42,000 gallons of product in USTs and in one 500-gallon AST, then all tanks are subject. Conversely, if a facility stores product in one 1,000-gallon AST, then any USTs at the facility are also subject. Under SPCC, tanks in vaults or partially buried tanks are considered to be ASTs.

Although vehicle service facilities are subject to the SPCC requirements, they are usually not subject to the FRP requirements due to their storage capacities. However, all facilities must document this determination 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 for Vehicle Service Facilities

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). 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.

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.

Diked Areas

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. The 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.

Vehicle service 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.

One design may consist of a sump located inside a containment area, which may be a blind sump (no drains) or a sump restrained by a normally closed valve. Facilities may remove the floating oil product by manual skimming or using sorbent materials. These materials must be disposed of properly or recovered for reuse. Any oil removed from skimming or the sorbent material must be disposed of as a waste oil. The remaining water in the sump must be inspected before discharging it outside the containment areas. Once sufficiently inspected and found to be free of oil, the water may be discharged by authorized personnel as long as the discharge is supervised and documented.

Other facilities may use a completely or partially buried oil-water separator system equipped with an inlet valve and a weir and baffle system, which directs the oil to one compartment and the water to another. The oil-water separator must never automatically discharge treated water to a sanitary sewer or anywhere outside a contained area.

Another alternative is to pump out diked areas with a manual pump or vacuum truck. Any oil-contaminated water must be transported to an appropriate waste-handling facility for disposal or treated on site.

Undiked Areas

Other operating areas of a vehicle service facility 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 these areas: truck-to-tank filling sites (unloading), 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. At vehicle service facilities, storage units can range in size from a few gallons to more than 20,000 gallons.

Tank Material

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.

Secondary Containment

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 on the worldwide web at http://www.ncdc.noaa.gov/oa/climate/research/monitoring.html.

The following table describes the most common secondary containment systems.

Tank Integrity - Inspections and Testing

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:

Internal Heating Coils

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:

Fail-Safe Devices - Level Gauging Systems and Alarms

Vehicle service 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 provides examples of some acceptable systems.