1	SPCC Program & Issues Michael L. Walker, P.E. Manager, Environmental & Engineering Services EI, Inc.
2	August Deadline Approached… Owners wrestled with rules implications Require additional items in Plans Operating implications Some new rules burdensome
3	…and approached “New” rules first published in 2002 Much written and said Not another overview Discussion on several specific items
4	Our Workshop Informative & Interactive Any SPCC topic Ask questions Panel Some new elements requiring thought & decision Security – 112.7(g) Unloading Areas – 112.7(h) Inspection and Testing – 112.8(c)(6) Mobile Tanks – 112.8(c)(11)
5	I. Security Requirements (112.7(g)) Purpose: to prevent accidental or intentional (vandalism) releases of oil 112.7(g)(a) requires “Fully fence each facility handling, processing, or storing oil, and lock and/or guard entrance gates when the facility is not in production or is unattended.” July 17, 2002 preamble rule: “When you use a fence to protect a facility, the design of the fence should deter vandalism. Methods of deterring vandals might include barded wire or other devices.”
6	Security Challenges Large rural facility Truck access
7	Security Challenges Some fences better than others Lock containment drains
8	Security Challenges Along railroad spur Deviation from standard allowed 112.7(a)(2)
9	II. Loading/Unloading Areas Commonly overlooked in facility design process 2002 preamble: loading and unloading of fuel represents a significant risk of release Rules now include specific requirements (rather than suggestions) Containment Warning systems or physical barriers Inspections
10	Unloading Area Containment Catchment basins Direct the material to treatment system “Quick drainage system” that collects and contains the oil
11	Loading/Unloading Containment Challenges Rail car unloading
12	Loading/Unloading Containment Challenges Fueling from asphalt parking lot
13	Loading/Unloading Containment Challenges Fueling from public street
14	III. Inspection & Testing (112.8(c)(6)) Most significant impact of the rule Larger facilities may have employed certain industry standard inspections Most owners now have a new requirement
15	Inspection & Testing Rules Paragraph 112.7(e) requires that the inspection and testing of bulk storage tanks be defined Paragraph 112.8(c)(6) requires integrity testing on a regular basis the testing combine visual inspection with some other technique, and that records be kept to facilitate comparisons about tank wall thicknesses.
16	Where is the Guidance EPA acknowledges that specific industry standards: API Standard 653, “Tank Inspection, Repair, Alteration, and Reconstruction” API Recommended Practice 575, “Inspection of Atmospheric and Low-Pressure Tanks” Steel Tank Institute Standard SP001, “Standard for Inspection of In-Service Shop Fabricated Above-Ground Tanks for Storage of Combustible and Flammable Liquids” API 653 and 575 applied to larger field-fabricated tanks STI standard specifically developed for smaller shop-fabricated tanks
17	STI SP001-03 January 2003 Establishes specific standards Periodic inspections Certified inspections Owners are to visually inspect Monthly Quarterly Annual Copy of the STI checklist in notebook
18	Comments on STI Inspection List Some find the three levels of inspection slightly burdensome Whatever the inspection regiment, it must be clearly defined in the SPCC Plan. Items not included loading/unloading area containment spill kit contents closed and locked containment drain valves
19	Visual Inspections Testimonies Double-wall tanks Imperative to inspect prevention and containment systems Imperative to test electronics
20	Visual Inspections Testimonies Full diversionary sump Checking would improve the capabilities
21	Tank Integrity Testing Most significant change Qualified tank inspector Useful for owners to know elements of standard Tank type: Single-wall tank not in contact with the ground Single-wall tank in contact with the ground Double-wall tanks
22	Single-wall tanks not in contact with the ground Saddles or legs Allow for visual inspection of entire tank exterior Pressure (or vacuum) testing is optional Ultrasonic testing required on a ten-year cycle Except where measured changes in wall thicknesses are encountered
23	Single-wall tank in contact with the ground Ten-year cycle unless measurements of wall thickness require more frequent testing. Ultrasonic testing Point method of testing tank must be pressure (or vacuum) tested
24	Single-wall tank in contact with the ground (Con’t.) Double-bottom with a vacuum on the interstice Verify leak detection operating Check for fuel in interstice Pressure (or vacuum) test is optional Single-wall tanks without manways Empty tank Inspect bottom Determine remaining wall thickness Ultrasonic testing or visual inspection
25	Double-Walled Tanks Offer good spill protection Ultrasonic or pressure testing not required (although always optional) Inspector (10-year cycle) Verify that the leak detection equipment is operating Check for water and fuel in the rupture tank
26	IV. Mobile Tanks (112.8(c)(11)) Mobile or portable storage containers Positioned and located to prevent the discharge of oil Secondary means of containment must be employed. Include any storage tank larger than 55 gallons Portable emergency generators Tank trucks (if used to store oil) Portable fueling or waste oil tanks
27	Portable Containers Emergency generators, an owner could utilize drip pans under the parked units. The fuel truck (such as at airports) or portable fueling tanks could be parked within a bermed containment area Potential operational difficulty
28	Rules Allow Flexibility Containment be impractical, 112.7(d) allows for the deviation from the standard. include in the SPCC Plan Contingency plan to effectively respond to spill incident Written commitment of resources to implement plan
29	Conclusion Numerous changes that impact the owners of regulated facilities Testing requirements add activity and expense Containment systems not optional for loading/unloading facilities and portable tanks Some flexibility to prevent the discharge of oil Responsibility of the owner and his engineer
30	Panel Discussion You are the panel Specific examples Questions for our experts