Secondary Containment and 'Impracticability'...2009/04/13 · •Mobile or portable bulk storage...

Section 5Section 5

Secondary Containment Secondary Containment and and ‘‘ImpracticabilityImpracticability’’(as applicable to APSA tank (as applicable to APSA tank

facilities)facilities)

APSA/SPCC Plan Compliance PrimerAPSA/SPCC Plan Compliance Primer Slide Slide 111111

Summary Secondary Containment Summary Secondary Containment RequirementsRequirements

Several SPCC rule requirements and Several SPCC rule requirements and specifications for controlling releases from specifications for controlling releases from tanks, containers and equipmenttanks, containers and equipment

All to prevent a harmful discharge to navigable All to prevent a harmful discharge to navigable waters waters

Requirements located in several placed in the ruleRequirements located in several placed in the rule

Two basic typesTwo basic types…… applicability depends applicability depends on tank/container typeon tank/container type

General ContainmentGeneral Containment

Specific Specific ‘‘sizedsized’’ ContainmentContainment


Secondary Containment ProvisionsSecondary Containment ProvisionsNonNon--Tier I facilitiesTier I facilities (as related to APSA)(as related to APSA)

Secondary Containment RequiredSecondary Containment Required 40 CFR Section(s)40 CFR Section(s)

General containmentGeneral containment for areas with potential for for areas with potential for discharge, e.g.:discharge, e.g.:PipingPipingOilOil--filled operational and manufacturing equipment filled operational and manufacturing equipment Bulk and nonBulk and non--bulk loading and transfer bulk loading and transfer areasareas (non(non--rackrack related transfer areas)related transfer areas)NonNon--transportation related tank truckstransportation related tank trucks

Specific (sized) containmentSpecific (sized) containment for:for:

Loading/unloading Loading/unloading racksracks

Bulk storage containers (tanks, containers) Bulk storage containers (tanks, containers) –– fixedfixed

112.7(c)112.7(c)

112.7(h)(1) 112.7(h)(1)

112.8(c)(2)112.8(c)(2)

Specific (sized) containmentSpecific (sized) containment (and discharge (and discharge prevention positioning) for:prevention positioning) for:Bulk storage containers (tanks, containers) Bulk storage containers (tanks, containers) –– mobile or mobile or portableportable 112.8(c)(11)112.8(c)(11)


Secondary Containment ProvisionsSecondary Containment ProvisionsTier I Qualified FacilitiesTier I Qualified Facilities (as related to APSA)(as related to APSA)

Secondary Containment RequiredSecondary Containment Required 40 CFR Section(s)40 CFR Section(s)

General containmentGeneral containment for areas with potential for for areas with potential for discharge, e.g.:discharge, e.g.:PipingPipingOilOil--filled operational and manufacturing equipment filled operational and manufacturing equipment Bulk and nonBulk and non--bulk loading and transfer bulk loading and transfer areasareas (non(non--rackrack related transfer areas)related transfer areas)NonNon--transportation related tank truckstransportation related tank trucks

Specific (sized) containmentSpecific (sized) containment for:for:

Loading/unloading Loading/unloading racksracks (likely not present at Tier I (likely not present at Tier I QFsQFs))

Bulk storage containers (tanks, containers) Bulk storage containers (tanks, containers) –– fixedfixed

112.7(c)112.7(c)

112.6(a)(3)(ii)112.6(a)(3)(ii)

Specific (sized) containmentSpecific (sized) containment (and discharge (and discharge prevention positioning) for:prevention positioning) for:Bulk storage containers (tanks, containers) Bulk storage containers (tanks, containers) –– mobile mobile or portableor portable 112.6(a)(3)(ii)112.6(a)(3)(ii)


Example Methods of Secondary Containment Example Methods of Secondary Containment Listed in 40 CFR 112.7(c)Listed in 40 CFR 112.7(c)

Examples include:Examples include:Dikes, berms, or retaining Dikes, berms, or retaining wallswallsCurbingCurbingCulverting, gutters, or Culverting, gutters, or other drainage systemsother drainage systemsWeirs or boomsWeirs or booms BarriersBarriers

Spill diversion ponds and Spill diversion ponds and retention pondsretention pondsSorbent materialsSorbent materialsDrip pansDrip pansSumps and collection Sumps and collection systemssystems


Which Can a Facility Use?Which Can a Facility Use?Can a facility use Can a facility use anyany of the listed example methods for of the listed example methods for general OR specific sized containment?general OR specific sized containment?

MaybeMaybe…… but likely not:but likely not:Specific sized criteria imposes technical and engineering limitaSpecific sized criteria imposes technical and engineering limitations on tions on some of these measuressome of these measuresActive measures, separators (unless HUGE), sorbents, weirs or boActive measures, separators (unless HUGE), sorbents, weirs or booms oms cancan’’t meet the t meet the passivisitypassivisity, volume, or containment holding , volume, or containment holding requirements of sized specific containmentrequirements of sized specific containment


Specific (Sized) Secondary Containment Specific (Sized) Secondary Containment RequirementRequirement

Specific Specific ‘‘SizedSized’’ ContainmentContainmentAddress the potential of oil discharges from Address the potential of oil discharges from specificspecific parts parts of or equipment at a facility where oil is stored or handled of or equipment at a facility where oil is stored or handled Requirements include set sizing design criteria, and minimum Requirements include set sizing design criteria, and minimum freeboard intended to address catastrophic failure of bulk freeboard intended to address catastrophic failure of bulk tanks & containers and certain equipmenttanks & containers and certain equipment

•• The design decision does not rest with the PEThe design decision does not rest with the PE…… it has it has been dictated in the rule itselfbeen dictated in the rule itself

The SPCC rule specifies a required minimum size The SPCC rule specifies a required minimum size for secondary containment for the following areasfor secondary containment for the following areas•• Bulk storage containers 40 CFR 112.8(c)(2)Bulk storage containers 40 CFR 112.8(c)(2)

•• Loading/unloading racks 40 CFR 112.7(h)Loading/unloading racks 40 CFR 112.7(h)

•• Mobile or portable bulk storage containers 40 CFR Mobile or portable bulk storage containers 40 CFR 112.8(c)(11)112.8(c)(11)


Specific Secondary Containment CriteriaSpecific Secondary Containment Criteria

Must contain the Must contain the largest single oil compartment or largest single oil compartment or containercontainer plus plus ““sufficient freeboardsufficient freeboard”” to contain to contain precipitationprecipitation

Largest single compartment may consist of permanently Largest single compartment may consist of permanently manifoldedmanifoldedcontainers (i.e. more than a single tank)containers (i.e. more than a single tank)

Must be passive and permanent Must be passive and permanent –– no deployment or no deployment or other action necessaryother action necessary

•• e.g. curbs, dikes, doublee.g. curbs, dikes, double--wall shellwall shell•• Valves must remain closed and be manually operable onlyValves must remain closed and be manually operable only

Precipitation determination?Precipitation determination?•• N/A for integral double wall or indoor/weather protected tanks oN/A for integral double wall or indoor/weather protected tanks or r

containerscontainers

Tank/container displacement volume?Tank/container displacement volume?

Sufficiently impervious to the spilled materialSufficiently impervious to the spilled material


Sufficient Freeboard Design StandardSufficient Freeboard Design Standard

EPA did not set a standard requirement EPA did not set a standard requirement for freeboard capacityfor freeboard capacity

e.g., precipitation from a 25e.g., precipitation from a 25--year, 24year, 24--hour storm event or 110% of storage hour storm event or 110% of storage tank capacitytank capacity

The proper method of design is a The proper method of design is a matter of good engineering practicematter of good engineering practice

Whatever method is used to calculate Whatever method is used to calculate amount of freeboard amount of freeboard ““sufficientsufficient”” for for the facility and container configuration the facility and container configuration should be documented in the Planshould be documented in the Plan


Example Calculations Example Calculations from SPCC Plansfrom SPCC Plans


SUFFICIENT FREEBOARD ?


Double Walled Tanks?Double Walled Tanks?How do you know?How do you know?


Double Walled Tanks?Double Walled Tanks?How do you know?How do you know?

Visual vs Visual vs mfr specs vs mfr specs vs

purchase records purchase records vs optional vs optional equipment equipment


Sufficiently ImperviousSufficiently Impervious

Secondary containment system Secondary containment system ““must be capable of containing must be capable of containing oil and must be constructed so oil and must be constructed so that any discharge that any discharge …… will not will not escape containment system before escape containment system before cleanup occurscleanup occurs””(40 CFR 112.7(c))(40 CFR 112.7(c))

Diked areas must be Diked areas must be ““sufficiently impervious to sufficiently impervious to contain oilcontain oil”” (40 CFR 112.8(c)(2))(40 CFR 112.8(c)(2))

Describe in the PlanDescribe in the Plan


Sufficiently Sufficiently Impervious?Impervious?


Secondary Containment for Mobile/Portable Secondary Containment for Mobile/Portable ContainersContainers

Mobile and portable bulk containers must comply to Mobile and portable bulk containers must comply to the specific sized secondary containment the specific sized secondary containment requirements of 40 CFR 112.8(c)(11)requirements of 40 CFR 112.8(c)(11)

Must be positioned or located to prevent a Must be positioned or located to prevent a discharge to navigable watersdischarge to navigable waters

Secondary containment must be sized to contain Secondary containment must be sized to contain capacity of largest single compartment or capacity of largest single compartment or container with sufficient freeboard for container with sufficient freeboard for precipitationprecipitation

•• While in stationary or unattended mode of While in stationary or unattended mode of operationoperation

Except mobile refuelers and nonExcept mobile refuelers and non--transportation transportation related tank trucksrelated tank trucks


Secondary Containment RequirementsSecondary Containment Requirements((General Provisions)General Provisions)

‘‘General ProvisionsGeneral Provisions’’ aka General aka General Containment Containment (40 CFR 112.7(c))(40 CFR 112.7(c))

Addresses the potential for oil discharges from Addresses the potential for oil discharges from allallparts of a facility where oil is handled, and from parts of a facility where oil is handled, and from specific equipmentspecific equipmentContainment method, design, and capacity are Containment method, design, and capacity are determined by good engineering practice to contain the determined by good engineering practice to contain the most likely oil discharge until cleanmost likely oil discharge until clean--up occursup occurs

Intended to address most likely dischargeIntended to address most likely discharge•• Site, equipment, location and personnelSite, equipment, location and personnel--specific specific •• Determined or reviewed/certified by PEDetermined or reviewed/certified by PE

–– Or facility owner/operator for qualified facilitiesOr facility owner/operator for qualified facilities


General Secondary Containment RequirementGeneral Secondary Containment Requirement

Required secondary containment for all areas Required secondary containment for all areas with the potential for a dischargewith the potential for a discharge

Performance requirementPerformance requirement…… broader than usual use broader than usual use of term of term ‘‘secondary containmentsecondary containment’’: i.e.:: i.e.:•• Appropriate containment and/or diversionary structures to Appropriate containment and/or diversionary structures to

prevent a discharge to navigable waters that may be harmful prevent a discharge to navigable waters that may be harmful

This is the This is the minimumminimum expectation for expectation for containmentcontainmentThis is where plan preparer experience & This is where plan preparer experience & technical knowledge come in (e.g. PE using technical knowledge come in (e.g. PE using good engineering practice)good engineering practice)


General Secondary Containment RequirementGeneral Secondary Containment Requirement

General facility requirement with no specified sizing or General facility requirement with no specified sizing or freeboard requirementsfreeboard requirements

ActiveActive or or passive passive (e.g. spill or discharge response, (e.g. spill or discharge response, weirs, closing valves, drain mat placement, berms, weirs, closing valves, drain mat placement, berms, dikes, containment pallets, predikes, containment pallets, pre--positioned socks, etc.)positioned socks, etc.)Can be facilityCan be facility--wide or equipment/tank specificwide or equipment/tank specific


General Secondary ContainmentGeneral Secondary ContainmentCan be a combination of all types of measuresCan be a combination of all types of measures

Performance standard: Performance standard: •• Prevent navigable water dischargesPrevent navigable water discharges

•• Keep the discharge from esKeep the discharge from escaping caping containment untilcontainment until clean up occursclean up occurs


Passive vs. Active MeasuresPassive vs. Active Measures40 CFR 140 CFR 112.7(c) allows for the use of certain types of 12.7(c) allows for the use of certain types of active containment measures to prevent a discharge active containment measures to prevent a discharge and may be used when permanent containment is not and may be used when permanent containment is not feasiblefeasible

Feasibility determined by the facility Feasibility determined by the facility owner/operator or the reviewing/certifying PEowner/operator or the reviewing/certifying PE

PassivePassive measures are permanent installations measures are permanent installations and do not require deployment or action by and do not require deployment or action by the owner or operatorthe owner or operator

ActiveActive containment measures are those that require deployment or

containment measures are those that require deployment or other specific action by the owner other specific action by the owner or operatoror operator


Active Measure ExamplesActive Measure Examples

Placing a properly designed storm drain Placing a properly designed storm drain cover over a drain to contain a potential cover over a drain to contain a potential spill in an area where a transfer occurs, spill in an area where a transfer occurs, prior to the transfer activityprior to the transfer activity

Placing a storm drain cover over a Placing a storm drain cover over a drain in reaction to a discharge, drain in reaction to a discharge, before the oil reaches the drainbefore the oil reaches the drain

Using spill kits in the event of an oil Using spill kits in the event of an oil dischargedischarge

Using spill response capability (spill Using spill response capability (spill response teams) in the event of an oil response teams) in the event of an oil dischargedischarge


Efficacy of Active MeasuresEfficacy of Active Measures

Efficacy depends on:Efficacy depends on:Effectiveness & capacity Effectiveness & capacity of the containment of the containment measuremeasure

Timely deployment and Timely deployment and proper placement proper placement prior toprior toor following a discharge or following a discharge

Availability of personnel Availability of personnel and equipment to and equipment to implement the active implement the active measure timely and measure timely and effectively at the facilityeffectively at the facility

Personnel and equipmentPersonnel and equipmentperformance (drills?)performance (drills?)

Active containment measures to be used at a facility (and descriActive containment measures to be used at a facility (and described in the SPCC Plan) bed in the SPCC Plan) should be reasonable, appropriate, tested and believableshould be reasonable, appropriate, tested and believable


Unloading Procedures Impact on Spill Prediction / Failure Unloading Procedures Impact on Spill Prediction / Failure Analysis and ContainmentAnalysis and Containment


Can include both Can include both passive and active passive and active measuresmeasures

But like anything else: But like anything else: must be maintained and must be maintained and implemented!implemented!


OilOil--Filled Operational EquipmentFilled Operational Equipment

Subject to the general secondary Subject to the general secondary containment requirements of 40 containment requirements of 40 CFR 112.7(c)CFR 112.7(c)


Requirements for Mobile Refuelers & Other Requirements for Mobile Refuelers & Other NonNon--Transportation Related Tank TrucksTransportation Related Tank Trucks

General secondary General secondary containment requirements containment requirements applyapply

Dec. 2006 amendment eliminated Dec. 2006 amendment eliminated the specific sized secondary the specific sized secondary containment requirementcontainment requirement

Does not apply to vehicles that are used Does not apply to vehicles that are used primarily to store oil in a stationary locationprimarily to store oil in a stationary location

As with any portable/mobile container, must As with any portable/mobile container, must also position or locate them to prevent a also position or locate them to prevent a harmful navigable water dischargeharmful navigable water discharge

APSA/SPCC Plan Compliance PrimerAPSA/SPCC Plan Compliance Primer Slide Slide 148148What do you observe? Any issues?What do you observe? Any issues?


PipingPiping

All piping, including buried piping, at All piping, including buried piping, at regulated facilities must comply with the 40 regulated facilities must comply with the 40 CFR 112.7(c) general secondary containment CFR 112.7(c) general secondary containment requirementsrequirements

A determination of adequate secondary A determination of adequate secondary containment should consider:containment should consider:

The reasonably expected sources of dischargeThe reasonably expected sources of discharge

Maximum flow rateMaximum flow rate

Duration of a dischargeDuration of a discharge

Spill detection capabilitySpill detection capability


PipingPipingIn many cases, secondary In many cases, secondary containment (especially active containment (especially active measures) will be possiblemeasures) will be possible

In other cases, active measures In other cases, active measures would not be appropriatewould not be appropriate•• E.g. 8E.g. 8”” high pressure jet fuel transfer high pressure jet fuel transfer

pipeline at facility edgepipeline at facility edge

–– Facility recently replaced this Facility recently replaced this with doublewith double--walled pipingwalled piping

If active methods of containment are If active methods of containment are selected, facility personnel should be able selected, facility personnel should be able to demonstrate that they can effectively to demonstrate that they can effectively deploy these measures to contain a deploy these measures to contain a potential spill potential spill beforebefore it reaches navigable it reaches navigable waters or adjoining shorelineswaters or adjoining shorelines


Transfer AreasTransfer Areas

Activities that occur within transfer areas Activities that occur within transfer areas include:include:

Unloading fuel from a truck to a bulk fuel tankUnloading fuel from a truck to a bulk fuel tankLoading oil into a vehicle from a dispenserLoading oil into a vehicle from a dispenserLoading fuel from a mobile refueler into an Loading fuel from a mobile refueler into an airplaneairplaneLoading lubricating oil from a truck into Loading lubricating oil from a truck into equipmentequipmentUnloading and moving drums and totes on a Unloading and moving drums and totes on a forkliftforklift

Transfer areas are subject to the general containment Transfer areas are subject to the general containment requirements of 40 CFR 112.7(c)requirements of 40 CFR 112.7(c)


Containment at Transfer AreasContainment at Transfer Areas

Determination of adequate secondary Determination of adequate secondary containment should consider: containment should consider:

Reasonably expected sources and causes of Reasonably expected sources and causes of a discharge a discharge

Reasonably expected maximum rate of Reasonably expected maximum rate of discharge discharge

Ability to detect and react to the discharge Ability to detect and react to the discharge

Reasonably expected duration of the Reasonably expected duration of the dischargedischarge

Time it would take a discharge to impact Time it would take a discharge to impact navigable waters or adjoining shorelinesnavigable waters or adjoining shorelines


Loading/Unloading RacksLoading/Unloading RacksDefinition of loading/unloading Definition of loading/unloading rackrack was clarified was clarified and made more specific in the 12and made more specific in the 12--2008 2008 amendments, and the requirements clarifiedamendments, and the requirements clarified

Fixed structure (such as a platform, gangway)Fixed structure (such as a platform, gangway)

Necessary for loading or unloading a tank truck Necessary for loading or unloading a tank truck or tank car and located at an SPCC regulated or tank car and located at an SPCC regulated facility facility

A loading/unloading rack includes a loading or A loading/unloading rack includes a loading or unloading arm, and may include any combination unloading arm, and may include any combination of the following: of the following: •• piping assemblages, valves, pumps, shutpiping assemblages, valves, pumps, shut--off devices, overfill off devices, overfill

sensors, or personnel safety devicessensors, or personnel safety devices


Facility Drainage: From Diked AreasFacility Drainage: From Diked AreasDrainage from diked storage areas must be restrained by Drainage from diked storage areas must be restrained by valves to prevent discharges into facility drainage or effluent valves to prevent discharges into facility drainage or effluent treatment systems treatment systems

Unless the systems are designed to control such dischargeUnless the systems are designed to control such discharge

Diked areas may be emptied by pumps or ejectors only by Diked areas may be emptied by pumps or ejectors only by manual activationmanual activation

Must inspect the condition of the accumulation before starting, Must inspect the condition of the accumulation before starting, to to ensure no oil will be dischargedensure no oil will be discharged

If the facility drainage drains directly into a watercourse (i.eIf the facility drainage drains directly into a watercourse (i.e. . storm water discharge) and not into onstorm water discharge) and not into on--site wastewater site wastewater treatment, the facility must inspect uncontaminated retained treatment, the facility must inspect uncontaminated retained stormwater prior to drainingstormwater prior to draining

40 CFR 112.8(c)(3)(i) 40 CFR 112.8(c)(3)(i) -- (iv) are also required(iv) are also required


Facility Drainage: From Diked AreasFacility Drainage: From Diked AreasDraining diked areas into stormwater (or other Draining diked areas into stormwater (or other surface watercourse) requires compliance with 40 surface watercourse) requires compliance with 40 CFR 112.8(c)(3)(ii) CFR 112.8(c)(3)(ii) -- (iv):(iv):

Not allow drainage of uncontaminated rainwater from the Not allow drainage of uncontaminated rainwater from the diked area into a storm drain or open watercourse, lake, or diked area into a storm drain or open watercourse, lake, or pond, bypassing the facility treatment system unless the pond, bypassing the facility treatment system unless the facilityfacility•• Normally keeps the bypass or drainage valve sealed closedNormally keeps the bypass or drainage valve sealed closed

•• Inspect the retained rainwater to ensure that its presence will Inspect the retained rainwater to ensure that its presence will not not cause a discharge as described in cause a discharge as described in §§112.1(b)112.1(b)

•• Open the bypass valve and reseal it following drainage under Open the bypass valve and reseal it following drainage under responsible supervision; andresponsible supervision; and

•• Keep adequate records of such events, for example, any records Keep adequate records of such events, for example, any records required under relevant stormwater discharge permits or NPDES required under relevant stormwater discharge permits or NPDES discharge permits discharge permits


A drainage log is provided in Template A drainage log is provided in Template Attachment 3.3 (Table GAttachment 3.3 (Table G--18)18)


UnUn--Diked Facility DrainageDiked Facility Drainage

When secondary containment requirements When secondary containment requirements are addressed through facility drainage are addressed through facility drainage controls (vs. berms or dikes), other controls (vs. berms or dikes), other requirements applyrequirements apply

•• 40 CFR 112.8(b)(3) and (4)40 CFR 112.8(b)(3) and (4)

The drainage system must be designed to flow The drainage system must be designed to flow into ponds, lagoons, or catchment basins designed into ponds, lagoons, or catchment basins designed to retain oil or return it to the facilityto retain oil or return it to the facility


Impracticability ProvisionImpracticability Provision

If a facility owner or If a facility owner or operator finds that operator finds that containment methods containment methods are are ““impracticable,impracticable,”” a a combination of other combination of other measures in place of measures in place of secondary containment secondary containment may may conditionallyconditionally be be substitutedsubstituted

Bulk tanks/containersBulk tanks/containers

Transfer areas, pipingTransfer areas, piping

OilOil--filled equipmentfilled equipment

Loading/unloading racks Loading/unloading racks


Meaning of Meaning of ““ImpracticableImpracticable””

An An ““impracticability determinationimpracticability determination”” is intended to be is intended to be used when a facility owner/operator is incapable of used when a facility owner/operator is incapable of installing secondary containment by any reasonable installing secondary containment by any reasonable methodmethod

Considerations include:Considerations include:Space and geographical limitationsSpace and geographical limitations

Local zoning ordinancesLocal zoning ordinances

Fire codesFire codes

SafetySafety

Other good engineering practice reasons that Other good engineering practice reasons that would allow for secondary containmentwould allow for secondary containment


Impracticability RequirementsImpracticability Requirements

The impracticability provision requires:The impracticability provision requires:Explanation in SPCC Plan of why secondary Explanation in SPCC Plan of why secondary containment methods are impracticablecontainment methods are impracticable

Periodic integrity testing of bulk storage Periodic integrity testing of bulk storage containers and periodic integrity testing and containers and periodic integrity testing and leak testing of the valves and piping associated leak testing of the valves and piping associated with the containerswith the containers

Unless facility has submitted a Facility Response Unless facility has submitted a Facility Response Plan (FRP) under Plan (FRP) under §§112.20:112.20:•• An oil spill contingency plan (per 40 CFR 109.5); andAn oil spill contingency plan (per 40 CFR 109.5); and

•• A written commitment of manpower, equipment, and materials A written commitment of manpower, equipment, and materials required to control and remove any quantity of oil discharged required to control and remove any quantity of oil discharged that may be harmfulthat may be harmful


Impracticability and Qualified FacilitiesImpracticability and Qualified Facilities

SelfSelf--certified SPCC Plans may certified SPCC Plans may notnotinclude any determinations that include any determinations that secondary containment is impracticablesecondary containment is impracticable

At all for Tier I qualified facilities At all for Tier I qualified facilities

At Tier II qualified facilities At Tier II qualified facilities –– only if the only if the determination and alternative provision is determination and alternative provision is reviewed and certified by a PE.reviewed and certified by a PE.

Secondary Containment and 'Impracticability'...2009/04/13 · •Mobile or portable bulk storage...

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