MAINE DEPARTMENT OF ENVIRONMENTAL PROTECTION

Transcription

1 Oxford Hills Bus Garage 36 Brown St, Norway, ME Oil Storage Inspection 2/20/14 CONDITIONS OBSERVED Underground Oil Storage: 12,000 gallon underground oil storage tank (split 10,000 gallon diesel/2,000 gallon gasoline). DEP Registration # Underground tank leak detection system in alarm. Audible alarm not functioning. Gasoline dispenser cabinet door off. Snow inside dispenser. Update: Certified underground oil storage tank installer (CTI) Mike Lewis contacted DEP. CTI Lewis inspected system on 2/24/2014. Tank interstitial space was dry (no leak). Leak detection system malfunctioning. The system will be replaced ASAP. Aboveground Oil Storage: 1,000 gallon waste oil tank 275 gallon waste oil tank 275 gallon waste oil tank 275 motor oil tank 330 gallon #2 oil tank 330 gallon #2 oil tank 4 x 55 gallon oil drums The Bus Garage has an aboveground oil storage capacity of 2,705 gallons. 1 When asked, District officials attending this inspection informed D.E.P. that a Spill Prevention Control and Countermeasures (SPCC) plan was never developed for this facility. 1 The federal spill prevention control and countermeasure (SPCC) rule requires facilities exceeding 1,320 gallons of aboveground oil storage capacity with tanks and containers of 55 gallons or larger counting toward the threshold to implement an SPCC plan for their facility. SAD 17 Page 1

2 Oxford Hills Bus Garage 36 Brown St, Norway, ME Oil Storage Inspection 2/20/14 (cont.) No secondary containment for Evidence of oil spills not 275 gallon motor oil tank. properly cleaned up. Evidence of overfills of two 330 gallon #2 oil tanks Oil staining appears to be penetrating cinderblock seam. Evidence of overfill of 275 gallon waste oil tank. Approximately 1 inch of waste oil setting in tank secondary containment. SAD 17 Page 2

3 Oxford Hills Bus Garage 36 Brown St, Norway, ME Oil Storage Inspection 2/20/14 (cont.) Fluid Storage Area (drum containment). Cracks in walls and floor of drum containment area. 55 gallon drum of lube oil not in Debris piled on and around 275 gallon secondary containment waste oil tank and containment (difficult to visually inspect for leaks) RECOMMENDATIONS As soon as possible, develop and implement an SPCC Plan for the Bus Garage. Given the observations made, special attention should be paid to accounting for all aboveground oil storage tanks and containers and to providing adequate secondary containment for all aboveground tanks and containers. In the process of developing the plan, any oil storage area that was not inspectable at the time of the D.E.P. visit must be looked at with conditions documented. As soon as possible, arrange to correct all instances where there is evidence of past spill mitigation efforts (e.g. properly dispose all oil soaked piles of sorbent material) and SAD 17 Page 3

4 Oxford Hills Bus Garage 36 Brown St, Norway, ME Oil Storage Inspection 2/20/14 (cont.) clean-up all unaddressed spills, particularly what was observed in the waste oil tank containment structure outside. The following photos and descriptions are provided to illustrate the kind of secondary containment and spill prevention alarms that should be considered. All drums, totes, and other oil containers should be on properly sized spill containment pallets or mobile drum containment. Properly sized containment must be large enough to contain the entire contents of the largest tank or container in that secondary containment structure. Ensure adequate spill clean-up kits are located near oil transfer areas. Double-walled heating oil tanks may be used to meet secondary containment requirements. SAD 17 Page 4

5 Oxford Hills Bus Garage 36 Brown St, Norway, ME Oil Storage Inspection 2/20/14 (cont.) Utilize high level audible and visual alarm for remote fill waste oil tank to prevent future undetected overfills. SAD 17 Page 5

6 Underground Oil Storage: None. Aboveground Oil Storage: - One 11,400 gallon #2 fuel oil tank Paris Elementary School 4 Hathaway Road, South Paris, ME Oil Storage Inspection 2/20/2014 CONDITIONS OBSERVED Rust staining on boiler room floor (looking toward access to tank vault). Note: mobile sump pump staged at the vault entrance. Rust staining from liquid running into tank vault- looking from inside tank vault. Rust staining on tank vault floor. Severe corrosion and pitting on tank supports. SAD 17 Page 6

7 Paris Elementary School 4 Hathaway Road, South Paris, ME Oil Storage Inspection 2/20/2014 (cont.) Interface between tank bottom and vault floor. Bottom of tank is not visible for inspection and shows signs of corrosion. As shown in the preceding photos, the 11,400 gallon tank is located in a vault room that is below the elevation of and immediately adjacent to the school s boiler room. There is no berm between the vault access location and boiler room. From floor staining and the description of condition in these rooms by District officials attending the inspection, liquids reaching the boiler room floor flow toward the vault access point, and when released in sufficient quantities, flow through access point and into the vault. When asked, District officials attending this inspection informed D.E.P. that a Spill Prevention Control and Countermeasures (SPCC) plan was never developed for this facility. RECOMMENDATIONS As soon as possible, develop and implement an SPCC Plan for the aboveground oil storage tank. Given observations made during the inspection, it appears boiler blow down water, which typically has highly corrosive properties unless neutralized, has in the past been introduced into the tank vault. Such an event, particularly if it occurred routinely, would explain the extensive and premature corrosion observed on the tank bottom and tank cradles/supports. That said, definitive conclusions about the tank s condition were impossible because there is essentially zero clearance between its bottom and the floor. SAD 17 Page 7

8 Paris Elementary School 4 Hathaway Road, South Paris, ME Oil Storage Inspection 2/20/2014 (cont.) Based on the original specifications provided to us by the school district and the tank vendor, the specifications called for use of a zero clearance tank cradle. When asked, the tank vendor has stated that the standard specification for this manufacturer is a six inch clearance tank cradle. This would allow for visual inspection of the tank s underside as opposed to a more costly internal integrity test required by Steel Tank Institute (STI) Standard SP001.The long-term integrity of that tank is a significant factor in determining the extent that a spill risk exists at this facility. Based on the evidence of severe corrosion, we believe the District must, as soon as practicable, have the tank evaluated by a certified STI tank inspector in order to determine whether this tank is suitable to remain in service, using STI Standard SP001 (see below). This may require an internal tank inspection and follow up by a structural engineer. Whether from boiler blow down activities or other sources, the evidence of accelerated tank corrosion on what is a relatively new tank should lead the District to consider what actions it can immediately take to eliminate water flow to the vault. These actions will likely include installation of a berm between the rooms and discharge of blow down water to a dedicated drain plumbed to the area s municipal wastewater treatment facility. This will also require you to contact the municipal wastewater treatment facility regarding a pretreatment agreement. To the extent that the containment vault has had a history of groundwater infiltration, we recommend that its design be evaluated in accordance to ACI Standards 504R-90 and 350.2R-04. (See below) SAD 17 Page 8

9 Paris Elementary School 4 Hathaway Road, South Paris, ME Oil Storage Inspection 2/20/2014 (cont.) In addition, your review of this structure should include a determination of whether the vault fits the definition of a vault under National Fire Protection Association (NFPA) Code 30 or is a dedicated tank room or enclosure under NFPA Code 31. Proper characterization in light of these definitions is important because they affect the following design requirements: Ventilation Fire Rating of the roof Termination of the emergency vent (inside or outside of the enclosure) Leak detection requirements Making this determination will likely require consultation with your architect, Office of the State Fire Marshal, and/or the Maine Fuel Board. This vault may be considered a confined space and may require additional safety procedures when entering. We recommend contacting Safety Works at the Maine Department of Labor to assist you with this determination. Also, because vaults are typically not inspected on a regular basis, we recommend a leak detection sensor be installed at the lowest level of the containment vault in order to detect any liquid. SAD 17 Page 9

10 Paris Elementary School 4 Hathaway Road, South Paris, ME Oil Storage Inspection 2/20/2014 (cont.) According to the tank specifications, an OPW 61f stop overfill prevention valve was installed in the tank fill port. This type of overfill prevention device is similar to that of underground oil storage tanks which are required to be inspected annually. Often the annual inspection reveals that the device was not operating properly. We recommend annual testing of the valve to ensure proper operation. If the valve is installed in such a way that it is not practical to test annually, we recommend installing an audible and visual high level alarm at the fill pipe. See below. Regardless of the ability to test the overfill prevention valve annually, we recommend in all cases installing an audible and visual high level alarm that is obvious to the oil delivery driver at the point of filling. SAD 17 Page 10

11 Underground Oil Storage: None. Aboveground Oil Storage: Oxford Hills Comprehensive High School 256 Main St, South Paris, ME Oil Storage Inspection 2/20/14 CONDITIONS OBSERVED - two (2) 10,000 gallon #2 fuel oil tank - one (1) 100 gallon double-walled waste oil container Because of the confined nature of the tank vault, no photos of the two 10,000 gallon tanks were taken. Fill ports for the two 10,000 gallon tanks 100 gallon double-walled waste oil container RECOMMENDATIONS As with the recommendations for the Paris Elementary School, perform an evaluation of the facility to: Develop and implement an SPCC Plan for the aboveground oil storage tanks and containers. Evaluate containment to ACI standards, including design, compatible concrete coating, and joint sealant Determine ventilation requirements Fire Rating of the roof Termination of the emergency vent (inside or outside of the enclosure) Leak detection Audible and visual high level alarm Confined space entry determination SAD 17 Page 11

12 Underground Oil Storage: None. Aboveground Oil Storage: - one (1) 3,000 gallon #2 fuel oil tank Hebron Station School 884 Station Road, Hebron, ME Oil Storage Inspection 2/20/14 CONDITIONS OBSERVED Fill and vent pipes for 3,000 gallon Tank Inside tank vault RECOMMENDATIONS As with the recommendations for the Paris Elementary School and the Oxford Hills Comprehensive High School, perform an evaluation of the facility to: Develop and implement an SPCC Plan for the aboveground oil storage tanks and containers. Evaluate containment to ACI standards, including design, compatible concrete coating, and joint sealant Determine ventilation requirements Fire Rating of the roof Termination of the emergency vent (inside or outside of the enclosure) Leak detection Audible and visual high level alarm Confined space entry determination SAD 17 Page 12