Industry News
January 2008
SPCC Requirements and Pollution Prevention Practices for Bulk Storage Facilities
This guide will assist bulk oil storage facilities 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)
http://www.epa.gov/earth1r6/6sf/sfsites/oil/bulk.htm
December 2005
SPCC Guidance for Regional Inspectors
On December 2, 2005, EPA released the SPCC Guidance for Regional
Inspectors. The guidance document is intended to assist regional
inspectors in reviewing a facility's implementation of the Spill
Prevention, Control, and Countermeasure (SPCC) rule at 40 CFR part
112 and understanding the rule's applicability, and to help clarify
the role of the inspector in the review and evaluation of the performance-based
SPCC requirements. The guidance document is also available to owners
and operators of facilities that may be subject to the requirements
of the SPCC rule and the general public on how EPA intends the
SPCC rule to be implemented. The document is designed to provide
a consistent national policy on several SPCC-related issues.
Click
here to review and download the the SPCC Guidance for Regional
Inspectors document.
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EPA Prepares for Publication of "SPCC Guidance for Regional
Inspectors"
EPA is preparing to release its "SPCC Guidance for Regional
Inspectors." The document is undergoing thorough review, and
it will be made publicly available within the next several weeks.
Please check back, more information will be posted soon.
The document is intended to assist regional inspectors in reviewing
a facility's implementation of the Spill Prevention, Control, and
Countermeasure (SPCC) rule (40 CFR part 112). It is intended to
establish a common understanding among regional EPA inspectors
on how certain provisions of the rule may be applied. It will cover
topics such as applicability, environmental equivalence, secondary
containment and impracticability, and integrity testing, as well
as the role of the inspector in the review of these provisions.
It will also be available as a guide to owners and operators of
facilities that may be subject to the requirements of the SPCC
rule and the general public on how EPA intends the SPCC rule to
be implemented.
http://www.epa.gov/oilspill/
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Emergency Venting is Required on All Tanks Storing Gasoline & Distillate
Fuels
The following information is from the standard UL-142 Steel Aboveground
Tanks for Flammable and Combustible Liquids and NC Fire Code. Emergency
venting is required for Aboveground Storage Tanks that store Gasoline,
Diesel, Kerosene, Fuel Oil (NA on Residential Fuel Tanks) and in
some cases Hydraulic and Lubrication Oils.
Members must be advised - do not tighten manhole bolts on tanks
that use manholes for emergency venting. In addition, do not attach
anything to manholes that are used as emergency venting.
UL-142 Section 8 Venting:
8.1 —Each primary containment tank and each compartment
of a compartment tank shall have provision for both normal and
emergency venting. The interstitial (annular) space of a secondary
containment tank shall have provision for emergency venting. A
vent opening shall be in addition to the fill, withdrawal, and
liquid level gauge openings.
8.2— The normal venting shall be sized in accordance with
Table 8.2 and shall be at least as large as the filling or withdrawal
connection, whichever is larger, but in no case less than 1-1/4
inch (30 mm) nominal inside diameter.
8.3— The provision for emergency venting shall be:
a) An opening that complies with the requirements in 8.4 and is
provided for that purpose only or
b) A manhole with cover as described in 8.9 – 8.11 and a
vent opening for normal venting complying with the requirements
in 8.12. A weak shell-to-roof joint construction may be used for
emergency venting on vertical cylindrical tank constructions in
accordance with Construction, Section 15.
8.9— A manhole in the top of a tank, with a cover constructed
so as to lift under internal pressure such that the pressure in
the tank cannot exceed a gauge pressure of 2.5 psig (17.2 kPa)
may serve for emergency venting. Where emergency venting is provided
by such manhole and cover, the tank shall include a vent opening
for normal venting in accordance with the requirements in 8.12.
8.10— Emergency venting in accordance with 8.9 may be obtained
by an arrangement such that the cover of a manhole not less than
16 inches (0.4 m) in diameter can be lifted vertically not less
than 1-1/2 inches (38 mm) under conditions requiring emergency
venting.
8.11— A long bolt manhole intended for emergency venting
shall comply with Figure 9.1, except that the number of bolts and
the number of holes may be reduced to one-half the number specified
in Table 9.1. The bolts shall have an unthreaded section so that
the cover can lift a minimum of 1-1/2 inches (38 mm).
8.12— Each tank provided with a manhole in accordance with
8.9 shall have a vent opening in the top of the tank for normal
venting.
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July 2005
June 2005
SPCC REQUIREMENTS APPLY TO BULK PLANTS BEING CLOSED
PMAA has learned that some marketers are choosing to close down
their bulk plants rather than make the necessary financial investment
to comply with the revised SPCC rule. EPA staff has informed PMAA
that even if a marketer closes his plant after the February deadline
to have a plan certified by a professional engineer (PE), but before
the August implementation date, they must still have a plan in
place despite the fact that it will never be implemented.
In other words, if a marketer closes down his bulk plant between
February 17, 2006 and August 18, 2006, he must have a PE-certified
SPCC plan that meets the requirements of the new rule.
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June 2002
EPA ISSUES REVISED SPCC RULES
http://www.steeltank.com/library/tanktalk
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EPA RECOGNIZES PERFORMANCE OF CERTAIN SHOP
BUILT AST'S
The Office of Solid Waste and Emergency Response of the U.S. Environmental Protection Agency has issued a memorandum that enables the use of shop-built aboveground storage tanks (ASTs) in excess of 12,000 gallons capacity for compliance with the Clean Water Act.
The Spill Prevention Containment and Countermeasure (SPCC) mandates of the Clean Water Act call for extra protection against possible product spills that would threaten navigable waterways. Those mandates can be found at 40 CFR 112.
"After nearly a decade of evaluation of the construction, performance, and use of certain shop-built double-wall ASTs, we believe that they may serve as an 'equivalent' preventive system for purposes of §112.7(c)," the EPA memo said.
"We believe that a 12,000-gallon limitation on the use of certain shop-built double-wall ASTs is therefore no longer necessary, and believe that shop-built double wall ASTs that use the protective measures described in 1992 generally satisfy the secondary containment requirements found in §112.7(c)."
The EPA memo also found that shop-built ASTs could meet regulatory expectations for environmental protection provided by bulk storage.
"For the same reasons outlined above, we also believe that shop-fabricated double-wall AST, regardless of size, may generally satisfy not only they secondary containment requirements of §112.7(c), but also the bulk storage secondary containment requirements found at §112.8(c)(2)," the memo said. "Section 112.8(c)(6) requires the owner or operator to conduct integrity testing on a regular schedule and whenever he makes repairs."
"Owners or operators should conduct this integrity testing and inspection in accordance with industry standards, when practicable. One industry standard presently available is 'SP001-00, Standard for Inspection of In-Service Shop-Fabricated Aboveground Tanks for Storage of Combustible and Flammable Liquids.'"
SP001-00 is a Steel Tank Institute standard.
In addition to STI, other organizations cited as providing acceptable standards are the American Petroleum Institute and the American Concrete Institute.
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