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SPCC Requirements and Pollution Prevention Practices for Farms and Ranches



Farm

Overview

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.

FarmRecommended 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


SPCC: Preparation and Certification [40 CFR 112.3]

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.


Containment and Diversionary Structures Appropriate for Farms and Ranches [40 CFR 112.7(c)]

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.


Facility Drainage [40 CFR 112.7(e)(1)]

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.

Clouds and RainThese 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.

Problem Dike 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.


Oil Storage: Bulk Storage Tanks, Portable Tanks, Drums, and Oil-Containing Equipment [40 CFR 112.7(e)(2)]

Fire HazardThere 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.

Instruments 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:
  • conventional concrete is not totally impervious to petroleum; any spill left inside a containment area may eventually penetrate the concrete and could contaminate groundwater sources. Therefore, spills inside diked areas should be cleaned up as soon as possible.
  • the expansion and contraction of piping which runs through containment walls can create areas of weakness.
  • grouting in expansion joints requires maintenance to prevent weak points, which may allow petroleum penetration.
Containment Curbs Containment curbs are similar to speed bumps and are often used where vehicles need to access the containment area.

Limitations:
  • they fill up with rainwater more rapidly than higher containment areas; and
  • they can be worn down as a result of vehicle crossings.
Containment Pits/Trenches Pits or trenches are belowgrade containment structures, which may be covered with metal grates and lined with concrete.

Limitations:

  • earthen structures have the potential for groundwater contamination unless constructed with appropriate materials;
  • if pits and trenches are not properly supported, they deteriorate quickly; and
  • they pose a danger since people can fall into them if grates are not properly maintained.
Earthen Berms Earthen berms containing clay or bentonite mixtures are commonly used at very large oil storage facilities.

Limitations:

  • earthen berms are subject to water and wind erosion and require frequent rebuilding;
  • sandy soil does not effectively contain oil spills; groundwater contamination may result. Impervious liners of clay or synthetic membranes may be required to contain oil spills; and
  • vegetation inside bermed areas is a fire hazard and restricts the operator's ability to detect spills or defective equipment. In addition, the root systems of plants, such as trees, shrubs or bushes, could degrade the berm and promote leakage.
Concrete Block Walls Concrete block walls are also commonly used for containment.

Limitations:

  • settling eventually separates or cracks the blocks and destroys the integrity of the wall.
  • concrete blocks are very porous therefore they do not form liquid-tight seals between mortared joints.
  • water and ice penetrate the blocks and eventually break them apart due to the different phases of water.




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.

GaugeLevel 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".

Remember

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.


Transfer Operations: Hosing, Pipelines, and Joints [40 CFR 112.7(e)(3)]

Water PipeGenerally, 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.


Tank Car and Tank Truck Loading and Unloading Procedures [40 CFR 112.7(e)(4)]

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.

Hand CheckInspection 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)]


Lock and KeySecurity 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.

InformationThe 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.

 


Spill Prevention Training [40 CFR 112.7(e)(10)]

Spill Prevention WomanA 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.


Recommended Practices


LightFacilities 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.

InformationKeep 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.


Facility Construction and Design

Tractor 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.


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