Bulk Storage Program. Cornell University 8/22/2014

Transcription

1 Cornell University 8/22/2014

2 Written Program Table of Contents 1. Introduction Definitions Roles and Responsibilities EHS College/Unit Regulatory and Operational Scope Scope of Covered CU Facilities and Operations Applicable Regulations and Aspect Overview Aboveground Petroleum Storage Tanks Underground Petroleum Storage Major Oil Storage Recordkeeping, Reporting & Monitoring... 5 Page 1 of 8

3 1. Introduction This Cornell University Bulk Storage Compliance manual is intended for use by personnel at Cornell University (CU) responsible for the inspection, care and maintenance of bulk storage tanks which store petroleum and chemicals. This manual is designed to assist University personnel in achieving and maintaining compliance with Federal, State and Local bulk storage regulations. Implementation of requirements and recommendations provided in this manual will help to ensure protection of the environment from petroleum and chemical releases. 2. Definitions "Aboveground tank" means any stationary tank which is not entirely covered with earth or other material, or any tank which can be inspected in a subterranean vault. "Cathodic protection" means corrosion protection for an underground metal tank or pipe by causing a continuous electric current to flow from one or more electrodes or a sacrificial anode to the protected structure. "Combined storage capacity" means the sum of the design storage capacity of each tank at a facility which has not been permanently closed. "Facility" or "storage facility" means one or more stationary tanks, including any associated intra-facility pipelines, fixtures, or other equipment, which have a combined storage capacity of over eleven hundred (1,100) gallons of petroleum at the same site. A facility may include aboveground tanks, underground tanks or a combination of both. Pipelines which enter or leave the site and non-stationary tanks are not part of the facility. "Leak monitoring system" means a leak detection system as required in sections and and paragraph (g)(3) of this Title. "Non-stationary tank" means any tank which in practice and design is mobile including tanks on wheels, trolleys, skids, pallets or rollers, and vessels such as a 55-gallon drum. "Permanently closed" means an out-of-service storage tank or facility which has been closed in a manner prescribed by subdivision 613.9(b) of this Title. "Petroleum" means any petroleum-based oil of any kind which is liquid at 20 C under atmospheric pressure and has been refined, re-refined, or otherwise processed for the purpose of being burned as a fuel to produce heat or usable energy, or which is suitable for use as a motor fuel or lubricant in the operation or maintenance of an engine. Waste oil which has been reprocessed or re-refined and which is being stored for sale or use as fuel or lubricant is considered petroleum for purposes of this Part. "Spill" or "spillage" means any escape of petroleum from the ordinary containers employed in the normal course of storage, transfer, processing or use. "Stationary tank" means all underground tanks or any aboveground tank which is non-mobile. Examples of stationary aboveground tanks include tanks which may rest on the ground or may Page 2 of 8

4 be fixed or permanently in place on foundations, racks, cradles, or stilts. "Storage facility" See "Facility". "Tightness test" means a test which is performed in a manner consistent with the criteria set forth in paragraph 613.5(a)(6) of this Title. "Underground tank" means any tank completely covered with earth or other material. Tanks in subterranean vaults accessible for inspections are considered aboveground tanks for the purpose of this Part. "Working capacity" means total capacity of the tank less an allowance for expansion and freeboard. 3. Roles and Responsibilities 3.1 EHS Communicate requirements and any changes which will impact operations Provide knowledge and training of the on-line tank monitoring system. Communicate with IT if the system fails or any changes need to be made to the inspection information. Verify that inspections are being performed and documented on the required periodic basis. Provide labels and any signage to be posted at the facility. Obtain registrations for new petroleum tanks and renewing existing registrations for tanks. Provide copies of the registration to the facility to post. Remind facilities of upcoming testing requirements. Provide assistance for tank removals, upgrades, replacement projects or changes to existing operations which would impact current petroleum storage. Provide contact for facility in the event of an unplanned release. Advise and assist with requirements and corrective actions. Provide support and guidance during inspections. 3.2 College/Unit Post registration s in accessible site for review by agency. Conduct required tank inspections so as to meet compliance requirements for the respective facility storage tanks. Notification of Product Change or major modification Notification of designated inspector changes for monthly on-line inspections Check tanks for leaks and other types of damage periodically Page 3 of 8

5 Check secondary containment for water accumulation and properly dispose of excess Ensure the proper signage and markings are visible and in good condition Ensure the spill kits are accessible, current and able to be used if needed Train all oil handling employees how to respond if a spill occurs. Train all oil handling employees how to report a release if needed. 4. Regulatory and Operational Scope The Bulk Storage Program encompasses numerous Federal and State laws and regulations. The program areas are administered by the Environmental Health and Safety Office (EHS) to ensure Cornell University-wide compliance with these associated regulations. Cornell facilities located outside of New York State may be subject to other state laws. Management of the Bulk Storage Program is broken down into several functional subprograms. The subprogram areas listed below are included in the overall Bulk Storage Compliance Program. Aboveground Petroleum Storage Facilities Underground Petroleum Storage Facilities Major Oil Storage Facilities Chemical Bulk Storage 4.1 Scope of Covered CU Facilities and Operations All Cornell University facilities and operations in the U.S. are within the scope of the Bulk Storage program. The nature of the facility, its operations, and activities taking place will determine if specific environmental requirements are applicable. Therefore specific requirements will vary between facilities and respective operations. Petroleum Bulk Storage currently is applicable to the College of Agriculture and Life Sciences, the College of Veterinary Medicine, Weill Medical Center, Facilities Services, and Cornell Transportation Department. Cornell Utilities Department qualifies for a MOSF license. 4.2 Applicable Regulations and Aspect Overview Aboveground Petroleum Storage Tanks University activities/operations designed to prevent releases of oil from Aboveground Petroleum Storage Tanks (ASTs) required to comply with following regulations: Resource Conservation and Recovery Act 42 USC 6691 Solid Waste Disposal Act P.L Title 10 NYS ECL NYCRR Parts CFR PART 112 Page 4 of 8

6 4.2.2 Underground Petroleum Storage University activities/operations designed to prevent releases of oil from Underground Petroleum Storage Tanks (USTs) required to comply with following regulations: Navigation Law Article CFR Part 280 ECL NYCRR Part 610, Major Oil Storage University activities/operations designed to prevent releases of oil from Aboveground Petroleum Storage Tanks (ASTs) required to comply with following regulations: Navigation Law Article 12 ECL NYCRR Part 610, Recordkeeping, Reporting & Monitoring Program Area Aboveground Petroleum Bulk Storage Aspects Total 10/2012: on campus and remote research locations (includes NYS (165), NH (4), ME(4)=173 tanks Recordkeeping, Reporting, or Monitoring Activity State PBS registration of bulk petroleum tanks. (NYS >1100 gal; ME, NH, all tanks) Posting of PBS registration inspection and record retention Frequency Responsibility Internal or External Deliverable 5 years ECPA External NYS DEC, ME Local Fire Dept, NH DEP, Upon issuance from agency inspections, record retention for 10 years. ECPA: distribution of Unit/facility manager: posting of Retention satisfied by EHS on-line inspection system Internal CU Internal CU agency-nys DEC, ME Local Fire Dept., NH DEP. Page 5 of 8

7 Underground Storage Tanks Total 4/2008: on campus and remote research locations (includes NYS, =7 tanks ( 6 tanks not regulated by 40CFR Part 280) Labeling Continuous State PBS registration of bulk petroleum tanks. (NYS >1100 gal; ME, NH, PR all tanks) Internal CU 5 years ECPA External NYS DEC, ME Local Fire Dept., NH DEP. Posting of PBS registration Upon issuance from agency ECPA: distribution of Unit/facility manager: posting of Internal CU inspection and record retention Annual line testing for pressurized piping Annual Cathodic testing Monitor for traces of petroleum inspections, record retention for 10 years. () Minimum 1 year (EPA) 1 year retention 3 year minimum retention Weekly Retention satisfied by EHS on-line inspection system Results sent to ECPA Results sent to ECPA Internal CU Internal-CU EPA Internal-CU EPA Internal-CU Page 6 of 8

8 EPA Tank Closure reports if a tank is phased out continuous ECPA Internal. EPA Major Oil Storage Facility (MOSF) License (Utilities) Tank #0004, Design Capacity 665,000 gallons, Working Capacity 600,000 gallons, Ultra Low Sulfur Diesel (ULSD); Tank #0005, Capacity 500 gallons, ULSD; Tank #0006, Capacity 2,000 gallons, ULSD. State MOSF registration of bulk petroleum tanks (>400,000 gallons at facility) Annual testing of monitoring wells for VOCs and SVOCs 5 years Annual lab reports directly to monitoring of wells for free product Spill Prevention and Containment Plan (SPC Plan) Description of Previous Spills Environmental Compliance Report ; retain reports for 5 years; report finding of free product to DEC Spill Hotline within two hours. Whenever major changes occur; at least every 5 years Annually, January 1 for year previous Every five years with license CHP Maintenance Staff Page 7 of 8

9 Chemical Bulk Storage Registered chemical storage in the Central Heating Plant, Water Treatment Plant, Water Filter Plant, CDS Treatment Plant Certification for Secondary Containment Updated SPCC Plan necessitated by change Site Assessment for Facility Closure Spill Prevention Report Plan renewal application October 30, 2012 and every five years thereafter Within 60 days of amendment effective date Prior to facility closure Updated annually as necessary, CDS, Re-registration of bulk storage tanks Maintain Spill Prevention Report (SPR) Every two years Review and update annually, CDS, CDS Page 8 of 8