Presented by: James Montgomery STI/SPFA, Jordan Johnson of Condor Earth

Transcription

1 Presented by: James Montgomery STI/SPFA, Jordan Johnson of Condor Earth

2 o Explore SWPPP Applicability o Review of SPCC and its Applicability o Overview of STI Standard SP001 for Inspection of Aboveground Storage Tanks

3 and Spill Prevention, Control, and Countermeasures (SPCC) Plan Similar, yet different.

4 30,000ft. Overview Fundamental part of storm water permits A facility/site specific document addressing pollution in storm water discharges from industrial facilities and construction sites in order to protect the integrity of receiving waterways. SPCC Plan Applies to designated oil storage facilities that have the potential to discharge oil to navigable water of the United States and adjoining shorelines. A facility-specific document focused on oil pollution from facilities in order to protect the integrity of waterways.

5 o Do you operate an Industrial Facility in California? Potential Industrial General Permit (IGP) DWQ Coverage o Do you operate a Construction Site in California? Potential Construction General Permit (CGP) DWQ Coverage

6 Any Facility included in IGP Permit Attachment A, items 1-9. A-List

7 Standard Industrial Classification (SIC) Codes: a system for classifying industries by a four-digit code

8 No-Exposure Certification (NEC) Storm water discharges from my facility, however storm water does not contact my industrial process (i.e. under cover) Notice of Intent (NOI) Only IGP coverage type requiring a SWPPP Exclusions My facility discharges storm water exposed to my industrial process. Notice of Non-Applicability (NONA) I have sufficient containment of storm water from my facility (i.e. storm water retention pond)

9 Notice of Intent (NOI) Requires a SWPPP Construction sites disturbing 1 acre or more of the land surface (includes sites less than acre if part of a common plan that is 1 acre or more) Construction activity includes: Demolition, Clearing, Grading, Excavation, and Other land disturbance activities Note: An Erosivity Waiver if eligible provides an exemption from CGP requirements.

10 o Develop Document o Training o BMP Implementation o Inspections o Sampling o Annual Report Evaluation

11 Do any of you have General Permit Coverage for Storm Water that requires a SWPPP? What type?

12 Spill Prevention Control and Countermeasure (SPCC) rule 40 CFR part 112 Requires facilities to develop and implement SPCC Plan: Procedures to diminish the potential for oil to Spill Prevent oil discharges through containment Control measures to keep oil discharges from impacting shorelines and waters of the U.S. Countermeasures to contain, clean-up, and mitigate any discharge (spill response measures)

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14 Under the SPCC regulations, oil is defined as: "oil of any kind or in any form including, but not limited to, petroleum, fuel oil, sludge, oil refuse and oil mixed with wastes other than dredged spoil and oily mixtures." Petroleum and Fuel Oils Gasoline Diesel Lube oils Aviation gasoline Jet fuel Naptha Mineral oils Mineral spirits Oil mixed with wastes Oil refuse Denatured ethanol Animal fats, oils, greases, vegetable oil (AFVO) This also includes: non-petroleum oils, synthetic oils, animal fats, oils and greases, and vegetable oils.

15 Storage capacity is defined as the shell capacity of the container Rated design capacity not operational capacity In containers with mixtures, total tank capacity is to be used, not oil percentage* Under the SPCC Rule only containers 55 gallon counted in total oil capacity

16 1. My facility is not transportation related (transportation facilities fall under DOT coverage) 2. Reasonable chance of a discharge to waters of the U.S. or adjoining shorelines (includes storm water conveyance systems) 3. Oil capacity at my Facility exceeds: a. Aboveground 1,320 gallons b. Underground 42,000 gallons If 1, 2, and 3 apply to your facility - you need a SPCC

17 o Develop Document o Training o BMP Implementation o Inspections

18 In the three years before the SPCC Plan is certified, the facility has had no discharges to navigable waters or adjoining shorelines as described below: A single discharge of oil >1,000 gallons, or Two discharges of oil each >42 gallons within any 12-month period.

19 Tier 1 Tier 2 Facilities with <10,000 gallons total oil storage capacity Individual container <5,000 gallons Complete and self-certify Plan template in lieu of a full PE-certified Plan or other self-certified SPCC Plan. Facilities with <10,000 gallons total oil storage capacity Container(s) 5,000 gallons Prepare a self-certified Plan in accordance with all applicable requirements of and subparts B or C of the rule, in lieu of a PEcertified Plan. Facilities with >10,000 gallons total oil storage or those that don t qualify must have Professional Engineer (PE) certification of the SPCC Plan

20 YES! For example: A manufacturing facility using hydraulic equipment with diesel ASTs (more than 1,320 gallons) that has industrial exposure to storm water, potential to discharge to waters of the US.

21 BMP Implementation Training SPCC Annual Review IGP Annual Review CGP Recommended Annual Review All Programs New Hire/New Contractor Regular Inspections SPCC Monthly visual observations of oil containers, regular tank integrity testing IGP Monthly and Storm Water Inspections CGP Quarterly, Weekly, Pre-Storm, Storm, and Post Storm Inspections Facility Maps

22 A Facility Map or Site Map is required when submitting your SWPPP or included Facility Boundary. Is there surface water flowing onto / from your facility? with your SPCC Plan on file. SWPPP and SPCC Site Maps are often identical when a facility is subject to both a SWPPP and SPCC Plan. BMPs

23 Roof Storm Water Gutter Where will this oil end up? Tank rupture

24 Key component of keeping oil from leaking tanks out of the storm drains Integrity testing is necessary to determine if the container (e.g. a tank) is suitable for continued use until the next formal inspection. Test/inspect each aboveground container for integrity on a regular schedule and whenever material repairs are made. Thousands of aboveground tanks will require periodic inspection because of revisions to the USEPA SPCC rule!

25 Standard for Inspection of Aboveground Storage Tanks (ASTs) Released Sept. 16, 2011

26 Spill Control Best Management Practices (BMPs) to Prevent release of liquid to environment (i.e. storm water systems and groundwater aquifers) Continuous Release Detection Method (CRDM) A means of detecting a release of liquid through inherent design Release Prevention Barrier (RPB) Liquid containment barrier designed to divert leaks toward the parameter of the tank Overfill Prevention Systems, procedures or devices used to prevent liquid in ASTs from running over or spilling out of the AST during the filling process. A person who is physically present and in control of a shutoff device during the entire tank filling process is an acceptable procedure to achieve overfill protection.

27 Welded steel AST fabricated in a manufacturing facility OR An AST without a nameplate with a volume less than or equal to 50,000 U.S. gallons Indoor Vertical Fire Rated Outdoor Diked Generator

28 Welded steel AST erected on-site where it will be used. Limited to a maximum shell height of 50 feet and a maximum diameter of 30 feet An AST without a nameplate that is more than 50,000 U.S. gallons and a maximum shell height of 50 feet and a maximum diameter of 30 feet

29 Tanks offering greatest risk have significantly more inspections Tanks with less risk have less inspections

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31 Secondary containment, dikes, berms, and double-wall construction are effective Best Management Practices (BMPs) that help prevent oil and grease from entering your Storm Water Elevated Double-wall Conveyance Tank System! Tanks with Overfill Prevention Tanks in a Concrete Dike

32 Tanks in earthen dike Dike prevents release due to catastrophic tank release only Soil and possible Storm Water Contamination if there is no liner installed under the gravel or if there is a breach in the dike.

33 Soil and possible Storm Water Contamination No Secondary Containment No RPB RPB, but no secondary containment

34 Closed top AST 55 U.S. gallons or more and not intended for fixed installation Fills void in industry for inspection A Facility or Site with less than 1,320 US gallons should note that portable containers are still subject to Periodic Inspections and are required to follow same BMPs outlined in your SWPPP and SPCC Plans. Open and Rusted (Oil, Grease, Metals or other Constituents) No Secondary Containment Pallets (Oil and Grease in Storm Water)

35 Owner Monthly/Annual Inspections Check operation of vents, coating, foundation Formal External Inspections Just like the IGP and CGP, the SPCC Plan includes regular inspection intervals Certified inspector, but no entry Leak Test Determine if AST is leaking. Formal Internal Inspections Entry into tank is necessary for full assessment

36 More Risk P Periodic Inspection by Owner E-External Inspection by Certified Inspector I-Internal Inspection L-Leak Test More Risk Shop built tanks Tank Size Category 1 Category 2 Category P P P, E&L(10) ,000 P P, E&L(10) [P, E&L(5), I(10)] or [P, E(5) & L(2)] 5,001-30,000 P, E(20) [P, E(10)& I(20)] or [P, E(5) & L(10)] [P, E&L(5), I(10)] or [P, E(5) & L(1)] 30,001-50,000 P, E(20) P, E&L(5), I(15) P, E&L(5), I(10) Field erected Portable containers P, E(5), I(10) P, E(5), I(10) P, E(5), I(10) P P P

37 Just like the IGP and CGP, the SPCC Plan includes regular inspection intervals

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39 Requires a Certified Inspector Retain Report for the Life of Tank Final Report (including field data, measurements, pictures, drawings, tables and an inspection summary) Containment area and foundation Shell coating Normal vents operation Emergency vents operation Tank level gauge Interstitial space monitor Overfill valves and alarms Anti-siphon, check, gate valves Pressure Regulator Monthly & Annual Inspections Expansion relief Solenoid valve Fire / shear valve Leak detectors Filter / Strainer Labels and tags Remove insulation where moisture or product collects UT of accessible areas, near base of tank (internal inspection if problems found)

40 Check all external inspection items UT of entire tank bottom elevated tanks do not require entry UT methods UTT point measurements (15 points per sq. ft.) UTS full scan if problems found in UTT

41 Are any of you storing oil at your facility (Site)?

42 Human Risk (Safety) Environmental Quality (Clean-up) Company Profit Loss (Penalties)

43 Regional Water Control Board issued a settlement where Caltrans violated provisions of the National Pollutant Discharge Elimination System (NPDES) Individual Permit for storm water discharges at an construction site.

44 EPA correspondence from an inspection conducted at a facility that did not provide information related to its compliance with the requirements for SPCC rule.

45 IGP SWPPP CGP Training BMPs Site Maps Regular Inspections Storm Water and Watershed Protection SPCC Rule SPCC Plan

46 What were the two main types of Storm Water Permits discussed? Is it acceptable to repurpose an Under Ground Storage Tank for Aboveground Storage? What is the alternative to a self-certified SPCC Plan?