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SPCC Requirements and Pollution Prevention Practices for Farms and Ranches
![Farm](farm.jpg)
This guide will assist farms and ranches
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 Farms and Ranches
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.
Farms and ranches constitute a sizeable portion of the SPCC-regulated
universe and approximately eight percent of the farms in the United
States are regulated. However, farms and ranches generally have
smaller storage capacity, fewer tanks, and lower throughput levels
than other facilities regulated by the Oil Pollution Prevention
Regulation.
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 farms and ranches require the storage of oil products (e.g.,
motor oil, hydraulic oil, brake fluid, gasoline, and diesel) for
machine lubrication, equipment maintenance and cleaning, heating
buildings, running irrigation pumps, and fueling vehicles and heavy
equipment. Farm tanks of certain sizes and for certain uses are
excluded from environmental regulations and programs implemented
in many states. However, the state exemptions do not supersede
the requirement to comply with the federal EPA's SPCC regulation.
All facilities that meet or exceed the storage quantities discussed
above are required to comply.
Most farms will have either aboveground storage or belowground storage;
few (by comparison) have a combination. More and more agriculture
facilities are installing very large single compartment aboveground
tanks to store diesel fuels for fueling heavy equipment, such as
tractors and combine harvesters and other farm vehicles, and for
running irrigation pumps. These large quantity tanks are popular
because farmers realize a cost savings if the fuels are bought in
bulk. These large tanks subject the farm to the SPCC regulation.
It is not expected that a farm or ranch would be subject to the
SPCC regulation based solely on the volume of their underground
storage capacity; not many farms require 42,000 gallons of fuel
products. If, however, a farm utilizes both aboveground and below-ground
tanks for fuel storage, and the combined quantity of aboveground
storage exceeds 1,320 gallons, the aboveground and
the belowground tanks are subject to the regulations.
Once the 660-gallon single tank or 1,320-gallon combined aboveground
storage quantities are exceeded, all oil products that fall under
the regulation's definition must be managed to comply with the regulations
(e.g., motor oils, cutting and lubricating oils, heating oils, diesel).
Although some farms and ranches 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 Farms and Ranches
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 surface waters.
Secondary containment and diversionary structures should be in place
to contain oil-contaminated drainage (e.g., rainwater) or leaks
around fuel dispensers, piping, 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).
Secondary containment structure may be damaged by the chemical action
of any spilled or leaking product or by the head pressure created
by the oil and water inside the diked area.
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.
A drainage control system 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.
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 farm or ranch 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.
There
are many types of storage tanks used to store petroleum products.
Tanks may be located aboveground, underground, partially underground,
and inside buildings and may be horizontal or vertical, supported
or unsupported. Tank sizes on farms can range from fewer than one
hundred gallons to more than several thousand. More recently, tanks
holding up to 10,000 gallons have been installed to store diesel
fuel.
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 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 (704) 271-4800 and at http://www.ncdc.noaa.gov
on the worldwide web.
The following table describes the most common secondary
containment systems.
Secondary Containment Systems | |
Type of System | Description |
Poured Concrete Walls | Poured concrete walls are strong, fairly watertight, and
resistant to petroleum penetration if adequately designed
and maintained according to good engineering practices. Limitations:
|
Containment Curbs | Containment curbs are similar to speed bumps and are often
used where vehicles need to access the containment area. Limitations:
|
Containment Pits/Trenches | Pits or trenches are belowgrade containment structures,
which may be covered with metal grates and lined with concrete.
Limitations:
|
Earthen Berms | Earthen berms containing clay or bentonite mixtures are
commonly used at very large oil storage facilities. Limitations:
|
Concrete Block Walls | Concrete block walls are also commonly used for containment.
Limitations:
|
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:
- X-ray or radiographic analysis measures wall thickness and
detects cracks and crevices in metal.
- Ultrasonic analysis measures shell metal thickness.
- Hydrostatic testing shows leaks caused by pressure.
- Visual inspection detects some cracks, leaks, or holes.
- Magnetic flux eddy current test used in conjunction with
ultrasonic analysis detects pitting.
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:
The steam return or exhaust lines from internal heating coils that
discharge into an open water course should be monitored for contamination
or routed to a settling tank, skimmer, or other separation system
to remove oil;
Consider using external heating coils and insulating the sides of
the tank if necessary. Because of the problems encountered with
internal steam-heating coils, there has been a movement away from
their use to more modern external heat-exchanger systems.
Fail-Safe Devices -
Level Gauging Systems and Alarms
Facilities must take precautions to ensure that tanks are not overfilled.
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). For farms and ranches acceptable
measures may include the use of direct site (visual) gauges in combination
with tank "sticking".
Level Gauging Systems and Alarms | |
Type of System | Description |
Direct Sight Level Gauges | In the simplest case, the gauge is a small-diameter glass
or plastic tube vertically attached to two openings in the
tank shell. Liquid level in the tank is shown by the level
in the tube. Another common sight level gauge is a float gauge. A float rides on top of the liquid in the tank and moves a marker attached to a cable or chain on the outside of the tank. The marker moves up or down with the product level in the tank. |
Digital Computers or Telepulse | Telepulse is a simple and accurate system for remote supervision of storage tank liquid levels and temperatures. The unit consists of a transmitter and receiver to relay and receive tank temperature and product level readings. Digital computers can be tied in to display data at more than one location. Portable fill alarm systems are also available that can be used while liquid cargoes are transferred from a storage container into a transportation vehicle. Many variations of these systems are in use. |
High Liquid Level Alarms | High liquid level alarms are usually tied into a float gauge or level gauging system. The alarms produce an audible or visual signal when the liquid level in the tank reaches a predetermined height. In older systems, a simple sound is produced by air motion; this is called an audible air vent. |
High Liquid Level Pump Cutoffs | This consists of a fill-level alarm connected to a pump control that automatically shuts down the pump when a preset liquid level is reached. This system eliminates the possibility of human failure and is effective at stopping overfilling of tanks. |
Direct Audible/Code Signal Communication | This system consists of communication between the tank gauger and pumping station and relies on human perception of liquid levels in the tanks and pumping rates to avoid overfilling tanks. Human error could cause a spill if the tank gauger or pumping station misreads an audible or code signal to start or stop pumping. Communication between the gauger and pump station is usually through two-way radio. |
Additional Safety Features | Relief valves and overflow lines are part of safety and level control systems on most petroleum storage tanks. Valves for pressure and vacuum relief will prevent tank damage but may result in a spill or discharge of liquid. Excess liquid may be allowed to flow into another tank through an overflow line. Vacuum vents prevent a tank from collapsing when liquid is pumped out of the tank. |
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.
Partially Buried Storage
Tanks
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.
Portable Oil Storage
Containers
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.
Containment for drums and other small containers does not have to
be expensive. If there are a small number of drums, a facility may
purchase spill pallets or portable containment devices (e.g., overpack
drums) designed for drum containment. Other inexpensive alternatives,
such as plastic troughs, are available at feed stores for larger
containers.
Generally,
farms or ranches do not have extensive piping arrangements. Flexible
hosing and short segments of pipelines typically are used for product
transferring from trucks or to drums.
After fuel tanks are filled, the pipe transfer point
should be capped or blank-flanged, and marked as to tanks it feeds.
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.
Inspections of Aboveground
Pipes, Valves, and Pumps
All aboveground pipes and valves should be regularly examined on
a scheduled basis. 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.
Warning Signs for Aboveground
Pipes
To avoid possible damage from vehicles colliding with oil-containing
pipes or other oil-containing equipment, tank truck drivers who
deliver diesel or gasoline to, or remove used oil from, a farm or
ranch should be verbally cautioned or warned by appropriate signs
of the location of any aboveground pipes, smaller tanks and containers,
as appropriate. Tank truck loading/unloading areas should have appropriate
protection for aboveground pipes or adequate signs posted to warn
drivers of the presence of aboveground pipes in traffic areas.
The common method for delivering diesel, gasoline
or heating fuels to farms and ranches is by tank trucks. The loading/unloading
operations, which can result in oil spills from poor hose connections
between the truck and the tank or from operator error through overfilling,
require care and constant attention during the transfer.
DOT Procedures
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 CFR 171, 173, 174,
177, and 179.
Secondary Containment
Due to their function, truck loading/ unloading areas have a high
probability for spills. Secondary containment systems must be designed
specifically for a facility's topography configuration, and the
size of the truck loading or unloading at the site. 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.
Loading/unloading areas typically are designed to permit vehicle
access and incorporate a secondary containment (localized containment).
The most common loading area containment system is a covered, curbed,
and graded area that drains to a sump. Alternatively, loading/ unloading
areas can be designed to direct drainage and spills to retention
ponds or flow into retention ponds, catchment basins or treatment
systems designed to retain oil or return it to the facility. A system
that incorporates good engineering practices minimizes the volume
of water, ice and snow that enters the containment area.
Warning or Barrier
System
A barrier system or warning signs should be provided in loading/unloading
areas to prevent a vehicle from leaving before being completely
disconnected from the fuel transfer lines. A barrier system can
be simple for small facilities. For example, blocks can be placed
under truck tires.
Inspections and Records [40 CFR 112.7(e)(8)]
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
procedures such as a checklist should be included in the facility's
SPCC Plan. Inspection records must be kept for a minimum of three
years.
Security [40 CFR 112.7(e)(9)]
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. Since it is not always practicable to
install fencing around an entire farm or ranch, the security fencing/access
restriction can be designed to surround only those areas containing
stored oil. The access gate must be locked during nonoperating hours.
If tanks or containers are located within a building, be sure to
provide security for all building access points. Wherever oil is
stored, there should be adequate lighting to respond to spills during
hours of darkness. Starter controls for fuel pumps should be locked.
Any valves that will allow the direct outflow of product are also
required to be locked.
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.
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. Oil spill problems most often result
from uncontrolled drainage from storage and operation areas, tank
and container failure or leaks, transfer pipe failures, improper
loading and unloading procedures, and poor security.
The best management practices (BMPs) included here may be supplemental
to the regulatory requirements. Others may be essential to achieving
compliance with the SPCC requirements or state regulations.
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 should 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.
Keep a portable pump nearby and available to empty secondary containment
areas that are not equipped with drains and valves.
Use drip pans under valves, whether or not valves are noted to be
leaking. A drip pan beneath each valve will catch unobserved drips.
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.
Some states permit the burning of waste oil as a fuel for heating.
Prior to burning oil for heating, call the state's environmental
compliance agency or state fire marshal to determine what the state
regulations allow. During warm weather, facilities need to make
arrangements for offsite disposal or recycling so that safe fill
levels of tanks are not exceeded. All tanks and drums must have
secondary containment to control spills.
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.
Protect tanks from lightning, earthquakes and floods. All metal
tanks should be grounded to reduce damage from lightning. Lightning
strikes can rupture tanks and cause catastrophic releases. In areas
that experience earthquakes, work with an engineer to determine
stabilization needs to prevent tanks from falling off their foundation
during an earthquake. In areas prone to flooding, protect the tanks
from inundation. This can be accomplished by positioning tanks on
raised foundations or by building a wall around the tanks to control
rising waters from damaging the tanks. Tanks can float away in a
flood.
Keep
portable and flexible hosing in good shape. Flexible hosing may
be used to transfer oil from one tank to another (such as heating
oil), or from a tank to a piece of heavy equipment for fueling or
maintenance. If so, keep hoses in good shape and leak-free by avoiding
kinks and by not stretching them beyond their intended lengths.
Replace or extend hosing that is too short to comfortably reach
from the tanks to the equipment being filled. Replace cracked hosing
instead of attempting to repair it.
Develop and implement procedures for oil vendors to
follow while they are filling storage tanks. Post signs outlining
these requirements and work with the drivers to familiarize them
with these procedures. These procedures should include proper positioning
of the truck to avoid damaging pumps or other equipment, proper
engagement of hose couplings, and proper pre- and post-filling inspection
protocol (i.e., looking for closed valves prior to filling and ensuring
the hoses are completely disconnecting before leaving the loading
area and spill cleanup and notification). These same procedures
should be required of waste oil haulers. Another requirement for
drivers should be notification of when they arrive and when they
leave.
In some cases it may be acceptable to use absorbent
booms for infrequent loading/unloading operations. These booms can
be purchased through industrial supply companies. Keep them on hand
and available so the driver(s) can position them around the truck
loading operations to serve as containment in the event of a release.
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.
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
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. Maintenance facilities that change large quantities
of fluids in vehicles should consider installing collection systems
that automatically accumulate the fluids inside the maintenance
pits. The collection device can be piped directly to a storage tank.
The contents of the tank can then be removed by a recycler. Operators
must ensure that these tanks do not overfill and they should be
serviced at regular intervals. 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.
Summary of Common Industry Standards | |
Underwriters
Laboratory (UL) Standard 142
Steel Aboveground Tanks for Flammable and Combustible Liquids |
This standard applies to steel atmospheric tanks intended for aboveground storage of noncorrosive, stable, flammable, and combustible liquids that have a specific gravity not exceeding that of water. The standard does not apply to API Standard 650, 12D, and 12F tanks. |
National
Fire Protection Association (NFPA) Code 30A
Automotive and Marine Service Station Code, Chapters 1 and 2 |
This standard applies to automotive and marine service stations and to service stations located inside buildings (special enclosures). The code does not apply to service stations that dispense liquefied petroleum gas, liquefied natural gas, or compressed natural gas as motor fuels. |
National Fire Protection Association (NFPA)
Code 30
Flammable and Combustible Liquids Code, Chapter Two |
This standard applies to all flammable and combustible liquids, including waste liquids (except those that are solid at 100 degrees Fahrenheit or above and those that are liquefied gases or cryogenic). Chapter Two, Tank Storage, applies to aboveground and indoor storage of liquids in fixed tanks and portable tanks with storage capacities of more than 660 gallons. |
American
Petroleum Institute (API) Standard 620
Design and Construction of Large, Welded, Low-Pressure Storage Tanks |
This standard addresses large field-assembled storage tanks that have a single vertical axis of revolution and contain petroleum intermediates and finished products, as well as other liquid products handled and stored by the petroleum industry. |
API Standard 650
Welded Steel Tanks for Oil Storage |
This standard provides material, design, fabrication, erection, and testing requirements for vertical, cylindrical, aboveground, closed- and open-top, welded steel storage tanks in various sizes and capacities. |
API Recommended Practice 651
Cathodic Protection of ASTs |
This recommended practice describes the corrosion problems characteristic in steel ASTs and associated piping systems and provides a general description of the two methods used to provide cathodic protection. |
API Recommended Practice 652
Lining AST Tank Bottoms |
This recommended practice describes the procedures for achieving effective corrosion control in ASTs by application of tank bottom linings to existing and new storage tanks. |
API Standard 653
Tank Inspection, Repair, Alteration, and Reconstruction |
This standard pertains to carbon and low alloy steel tanks built in conformance with API Standard 650 or 12C and provides criteria for the maintenance, inspection, repair, alteration, relocation and reconstruction of welded or riveted, nonrefrigerated, atmospheric pressure ASTs after they have been placed in service. |
API Recommended Practice 920
Prevention of Brittle Fracture |
This recommended practice addresses toughness levels for pressure vessels to prevent failure by brittle fracture. |
API Standard 2015
Safe Entry and Cleaning of Tank |
This standard provides guidelines for the development of safety practices for planning, managing, and conducting work in atmospheric and low pressure storage tanks. |
API Recommended Practice 2350
Overfill Protection for Petroleum Tanks |
This recommended practice provides guidelines for establishing operating procedures and for selecting equipment to assist in the reduction of overfills. |
API Standard 2610
Design, Construction, Operation and Maintenance and Inspection of Terminal and Tank Facilities |
This standard compiles various standards, specifications, and recommended practices developed by API and other entities for managing terminals and tanks. |
Acknowledgments
We would like to acknowledge the following agencies
and organizations for contributing information to the preparation
of this guide: U.S. Department of Agriculture, National Commission
on Small Farms; California Environmental Protection Agency, Department
of Toxic Substances Control Office of External Affairs; the California
Institute of Rural Studies; South Dakota Department of Environment
and Natural Resources Groundwater Quality Division; North Dakota
State Health Department Environmental Program; North Dakota State
Fire Marshal's Office; Colorado Department of Public Health; American
Farm Bureau Federation and various Farm Bureau Federation Offices
from the following states: California; Colorado; Wyoming; Nebraska,
Montana, Kansas, North Dakota and South Dakota.
The following publication also provided valuable assistance
in its preparation: U.S. Environmental Protection Agency, 1995.
SPCC/OPA Manual. U.S. EPA Region VIII, Ecosystem Protection
and Remediation Preparedness Team. Denver, Colorado.