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SPCC Requirements for Electrical Utilities - February 1998 1

SPCC REQUIREMENTS AND POLLUTIONPREVENTION PRACTICES FOR ELECTRICALUTILITIES

OVERVIEW APPLICABILITY OF THE SPCC

This guide will assist electrical utilities withthe prevention and control of oil spills. Otherguides have been developed to assist otherindustry sectors in the regulated community. This guide discusses the equipment andoperating practices needed to meet therequirements of the Federal Oil PollutionPrevention Regulation found in Title 40 Codeof Federal Regulations (CFR) Part 112,which includes the Spill Prevention Controland Countermeasure (SPCC) Planrequirements and the Facility Response Plan(FRP) requirements. The SPCCrequirements are the focus of this guide;other guides are available for the facilityresponse planning requirements (40 CFR112.20 and 112.21) and general informationon the Oil Pollution Prevention Regulation.

Recommendedpractices for pollutionprevention and avoidingdischarges of oil arealso included in thisguide. These practicesmay also assist facilitiesin achieving compliancewith the SPCC

requirements and reduce the possibility ofproduct loss and a discharge.

* A discharge is essentially a spill that reaches anavigable water or adjoining shoreline. The legaldefinition can be found in 40 CFR 112.2(b).

REQUIREMENTS TO ELECTRICALUTILITIES

EPA’s SPCCrequirements (40 CFRPart 112.1 through 112.7)apply tonontransportation-relatedfacilities that couldreasonably be expected

to discharge oil into or upon the navigablewaters of the United States or adjoiningshorelines, and that have (1) a totalunderground buried storage capacity ofmore than 42,000 gallons; or (2) a totalaboveground oil storage capacity of morethan 1,320 gallons, or (3) an abovegroundoil storage capacity of more than 660 gallonsin a single container.

Some facilities may not be regulated if, dueto their location, they could not reasonablybe expected to discharge oil into navigablewaters of the U.S. or adjoining shorelines. SPCC-regulated facilities must also complywith other federal, state, or local laws, someof which may be more stringent.

This guide is intended for SPCC-regulatedfacilities engaged in the generation,transmission, and/or distribution of electricpower, and that use equipment (e.g.,transformers and circuit breakers) whichcontain dielectric fluid (mineral oil) forinsulation, compressor oil, and hydraulic oil. These facilities include power plants(including hydroelectric and cogeneration

SPCC Requirements for Electrical Utilities - February 19982

What are Navigable Waters of the U.S.?

The legal definition for navigable waters is definedgenerally under Clean Water Act (CWA) Section502(7). EPA’s regulatory definition can be found at40 CFR 110.1.

For the purposes of 40 CFR Part 112, the termnavigable waters means the waters of the UnitedStates, including the territorial seas, and includes:

All waters that are currently used, were used inthe past, or may be susceptible to use ininterstate or foreign commerce, including allwaters subject to the ebb and flow of the tide.All interstate waters, including interstatewetlands, mudflats, and sandflats;All other waters such as intrastate lakes,rivers, streams (including intermittentstreams), wetlands, mudflats, sandflats,sloughs, prairie potholes, wet meadows, playalakes, or natural ponds, the use, degradation,or destruction of which could affect interstateor foreign commerce including any waters thatcould be used for recreational purposes, orfrom which fish or shellfish could be taken andsold in interstate or foreign commerce; or thatare used or could be used for industrialpurposes by industries in interstate commerce.

The CWA has been interpreted to cover all surfacewaters, including any waterway within the U.S. Also included are normally dry creeks throughwhich water may flow and ultimately end up inpublic waters, such as a river, stream, tributary to ariver or stream, lake reservoir, bay, gulf, sea, orocean within or adjacent to the U.S. The CWA’sjurisdictional reach may also include groundwater if it is directly connected hydrologically withsurface waters.

facilities), substations, switching stations, equipment (e.g., transformers, oil circuitcustomer installations, test facilities, and breakers, capacitors, regulators). Someequipment storage and maintenance facilities are moving towards using sulfurfacilities. hexafluoride (SF ) gas for insulating circuit

Operations related to SPCC at thesefacilities include the transfer of oil formaintenance activities, the storage of fuel oilfor powering generators during emergenciesor for power plant startup, and the storage ofinsulation (dielectric) oil in electrical

6

breakers. These circuit breakers do notcontain oil for insulation purposes, but theydo contain small amounts (e.g., two gallons)of compressor oil.

Many electrical utilities are subject to theSPCC regulation, and some utilities may besubject to the Facility Response Plan (FRP)requirements under 40 CFR 112.20 and112.21 and associated appendices. Allowners or operators of SPCC-regulatedfacilities should determine whether thefacility poses a threat of substantial harm tothe environment. All facilities mustdocument this determination by completingthe “Certification of the Applicability of theSubstantial Harm Criteria Checklist,”provided as Attachment C-II in Appendix Cof 40 CFR 112. This certification should bekept with the facility’s SPCC Plan.

As outlined in 40 CFR 112.20(f)(1), a facilityhas the potential to cause substantial harmand, therefore, must prepare an FRP if:

The facility transfers oil over water to orfrom vessels and has a total oil storagecapacity, including both abovegroundstorage tanks (ASTs) and undergroundstorage tanks (USTs), greater than orequal to 42,000 gallons; or

The facility's total oil storage capacity,including both ASTs and USTs, isgreater than or equal to one milliongallons, and one of the following istrue:

The facility lacks secondarycontainment that is able to containthe capacity of the largest AST within


The SPCC Plan must:

Be kept onsite.Have the full understanding of allemployees involved in facilityoperations.Be certified by a RegisteredProfessional Engineer (PE).Have full management approval.Conform with all SPCC requirementsin 40 CFR 112.Discuss spill history.Discuss spill prediction (i.e., directionof flow).Be reviewed every three years bymanagement.Be amended/certified by a PE formodifications.

each storage area plus freeboard to CFR 112.7. The SPCC Plan must beallow for precipitation; reviewed and certified by a Registered

The facility is located at a distance SPCC and has examined the facility. To besuch that a discharge from the facility in compliance, the facility’s SPCC Plan mustcould cause injury to an satisfy all of the applicable requirements forenvironmentally sensitive area; drainage, bulk storage tanks (including oil-

The facility is located at a distance truck loading and unloading, transfersuch that a discharge from the facility operations (intrafacility piping), inspectionswould shut down a public drinking- and records, security, and training. Mostwater intake; or importantly, the facility must fully implement

The facility has had a reportable spill and facilities that make modifications mustgreater than or equal to 10,000 prepare or revise their SPCC Plan within sixgallons within the last five years. months. Modifications may include, for

Many power-generating facilities are located installation or removal of tanks.adjacent to or over water; so if theiraggregate storage (including oil-filledelectrical equipment, fixed and mobilestorage tanks, etc.) is more than one milliongallons, they are likely to be subject to theFRP requirements as well. These facilitiesare likely to be required to prepare an FRPbecause a discharge from the facility has ahigh potential to cause injury to anenvironmentally sensitive area or shut downa public drinking water intake.

SPCC AND SPECIFIC SPILLPREVENTION REQUIREMENTS FOR

ELECTRICAL UTILITIES

SPCC: Preparation and Certification[40 CFR 112.3]

The owner or operator of an SPCC-subjectfacility is required to have a written site-specific spill prevention plan, which detailshow a facility’s operations comply with therequirements of 40 CFR 112.

Requirements for specific elements to beincluded in the SPCC Plan are found in 40

Professional Engineer who is familiar with

filled electrical equipment), tank car and

the SPCC Plan. Newly constructed facilities

example, changes in piping arrangements or


What is an Oil?

Oils are defined under several statutesincluding the Clean Water Act (CWA) andthe Oil Pollution Act of 1990 (OPA). As aresult, overlapping regulatory interpretationsexist. For this reason, the U.S. EPA and theU.S. Coast Guard are currently developing anationally consistent program policy andmethodology for facilities to determinewhether a given substance is considered an oilunder the existing CWA.

Under the CWA, the definition of oil includesoil of any kind and any form, such aspetroleum and nonpetroleum oils. Generally,oils fall into the following categories: crudeoil and refined petroleum products, edibleanimal and vegetable oil, other oils of animalor vegetable origin, and other nonpetroleumoils.

Many substances are easily recognizable asoils (e.g., gasoline, diesel, jet fuel, kerosene,and crude oil). Under the CWA definition,many other substances are considered oils,which may not be easily recognizable byindustry, including mineral oil, the oils ofvegetable and animal origin and othernonpetroleum oils. Therefore, facilitiesshould work closely with the EPA and USCG(if applicable) to make determinations for thesubstances they store, transfer, and refine.

Containment and Diversionary StructuresAppropriate for Electrical Utilities [40CFR 112.7(c)]

SPCC requires containment of drainagefrom the operating areas of a facility toprevent oil spills and contaminated runofffrom reaching storm drains, streams(perennial or intermittent), ditches, rivers,bays, and other navigable waters.

Secondary containment ordiversionary structuresmust be in place to controloil-contaminated drainage(e.g., rainwater) or leaksaround electricalequipment and associated

pipelines, valves, and joints and storagetanks. For these purposes, facilities shoulduse dikes, berms, curbing, culverts, gutters,trenches, retention ponds, weirs, booms,and other barriers as appropriate.

SPCC requirements are performance-based,which permits facility owners and operatorsto substitute alternative forms of spillcontainment if the substitute providessubstantially equivalent protection againstdischarges to navigable waters to thatprovided by the systems listed in 40 CFR112.7(c).

To safeguard against potential electricalhazards associated with standing water inelectrical yards, facilities should use acontainment and diversionary system whichcontinuously directs water away fromelectrical equipment. Culverts and retentionponds can satisfy the requirements fordrainage control and containment. Cableconduit ditches with trays which extendabove the surface can serve as part of adiversionary system as well.

In accordance with industry safety codes forthe prevention of electrical and fire hazards,electrical substations surround electricalequipment with gravel beds, also known as“chipseal.” The subgrade beneath thegravel should be designed using goodengineering practices to prevent themigration of contaminants through the soil. These gravel beds also aid in the retentionof contaminants and help prevent spilleddielectric fluid from spreading. Facilitiesshould consider installing surface drainsbeneath the gravel or use other methods forcontrolling drainage (e.g., perimeter ditchesand swales).


Contingency Planning

If a facility determines that the installation of diversionary structures or equipment is not practicable,then this must be clearly demonstrated (40 CFR 112.7(d)). In addition, the facility must have:

a strong oil spill contingency plan following 40 CFR Part 109; and

a written commitment of manpower, equipment, and materials required to expeditiously control andremove any harmful quantity of oil which has the potential to be discharged from the facility.

The following is a sample outline containing essential elements of a contingency plan for the purposesof 40 CFR 112.7(d)(7).

Facility Specific Items:Name and location of substationCountyTelephoneLatitudeLongitudeNearest navigable waterwayTotal volume of storage capacity on siteMajor equipment with individual capacitiesPossible spill scenariosSite-specific considerations (e.g., location of cable troughs, adequate secondary containment)A diagram of each facility and the direction of flow to the navigable waterway.

Introduction:Purpose of plan, revision and distribution, management approval, spill prevention, control andcountermeasures, training of personnel.

Responsibilities:Labs, Safety, Manager, Services, On-Scene Coordinators, Operators.

Spill Reporting:Emergency contacts, written reports.

Spill Response & Cleanup Procedures:Discovery and notification, control and containment, regulatory reporting, sampling and testing, cleanupand waste packaging, PCB fire incidences.

Health & Safety:Types of PPE, when to wear and not wear chemical PPE, personal safety procedures.

Manpower & Equipment:Extensive list of what departments and who is available when and where and what materials andequipment are stored.

Contractors/Disposal Facilities

Forms Used

Laboratory Analysis


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

Diked Areas

Facilities most often use poured concretewalls or earthen berms to contain drainageand provide secondary containment forstorage tanks and curbing and catchmentbasins for truck loading/unloading areas. These contained areas are considered dikedareas. Concrete and earthen dikecontainment structures around storage tanksmay accumulate significant amounts ofwater. Drain lines, which must bewatertight, are usually installed through thedike walls and are used to drainaccumulated stormwater from the dikedarea. These lines should be fitted withvalves or other positive means of closurethat are normally sealed closed and lockedto prevent any oil discharges from escapingthe diked area. These valves must be open-close manual valves; flapper valves are notacceptable.

These valves must be opened to drainrainwater and resealed following drainage bytrained andauthorized facilitypersonnel only. Adequate recordsmust be kept ofsuch drainageevents (i.e., date,time, personnelnames) and made part of the SPCC Plan. The accumulated rainwater must beexamined and determined to be free of oilcontamination before diked areas aredrained. If any oil sheen or accumulation ofoil is observed, an alternate method ofdraining the diked area must be employed. The contaminated water may be diverted toan onsite treatment plant or oil-waterseparator; however, the adequacy of thesesystems is determined on a case-by-case

basis for each one’s adherence to goodengineering practices and ability to retain aspill in the event of a system malfunction.

Another alternative is to pump out dikedareas with a manual pump or vacuum truck. Any oil-contaminated water must betransported to an appropriate waste-handling facility for disposal or treated onsite.

Undiked Areas

Other operating areas of an electrical utilitiesfacility which are not contained by dike wallsare considered undiked areas. Drainagemust be controlled for these areas whichmay include electrical yards with oil-filledelectrical equipment and associatedpipelines and valves, truck loading andunloading areas, and drum storage areas. All undiked areas can be designed to controldrainage through a combination of curbing,trenches, catchbasins, and oil-waterseparators as necessary to retain a spill.

For example, some electrical yards aregraded to drain to swales which directdrainage to concrete retention pondsrestrained by valves. Other electrical yardsmay be designed with containment curbingwhich directs drainage through drain inlets tounderground piping systems which empty todrainage retention structures. In eithercase, the contents of the drainage retentionstructure must be examined forcontamination prior to discharge.

Facilities must document this examinationnoting the appearance of the rainwater andthe time of opening and closing of the valveassociated with the retention structure.

Other facilities may use a completely orpartially buried oil-water separator systemequipped with an inlet valve and a weir and


baffle system, which directs the oil to one conform with relevant portions of industrycompartment and the water to another. The standards, such as American Petroleumoil-water separator must never automatically Institute (API), National Fire Protectiondischarge treated water to a sanitary sewer Association (NFPA), Underwritersor anywhere outside a contained area. Laboratory (UL), or American Society of

Diversionary structures should be examined be required in the application of goodfor their integrity and effectiveness. If a engineering practices or by state or localpaved area is improperly graded or if a curb regulations.is deteriorating, contaminated water mayescape from the facility. For this reason, aprofessional engineer must certify yourSPCC Plan to ensure that the drainagesystem is adequately designed and properlymaintained in accordance with goodengineering practices.

Whatever techniques are used, the facility’sdrainage systems should be adequatelyengineered to prevent oil from reachingnavigable waters in the event of equipmentfailure or human error at the facility.

Oil Storage: Bulk Storage Tanks, PortableTanks, Drums, and Oil-ContainingEquipment [40 CFR 112.7(e)(2)]

Tank Material

No tank or other equipment should be usedfor the storage of oil unless its constructionmaterial is compatible with the materialstored and conditions of storage such aspressure, physical and chemical properties,and temperatures.

It is recommended that the construction,materials, installation, and use of tanks

Mechanical Engineers (ASME), which may

For assistance with the preparation for naturaldisasters contact the Federal EmergencyManagement Agency (FEMA) at (202) 646-FEMA.

Secondary Containment

All equipment containing oil or oil-contaminated water must have secondarycontainment for the entire contents of thelargest single container within thecontainment area, plus sufficient freeboardto allow for precipitation. For electrical yardsan alternative system could consist of acomplete drainage trench or culvertarranged so that a spill could terminate andbe safely confined in a catchment basin orretention pond. The containmentstructure(s) must be sufficiently imperviousto the types of oil products stored at afacility. Diked areas should be free ofpooled oil; spills should be removedpromptly.

The volume of freeboardshould be based onregional rainfall patterns. Facilities in states withlarge amounts of rainfall(e.g., Washington, Alaska,and Hawaii, and theCommonwealth of Puerto Rico) will requiresecondary containment to accommodategreater amounts of water.


Precipitation data is available from the The following table describes the mostNational Oceanic and Atmospheric common secondary containment systems forAdministration’s (NOAA) National Climatic diked areas (e.g., storage tank areas).Data Center (NCDC). The NCDC can bereached by telephone at (704) 271-4800 andat http://www.ncdc.noaa.gov/ol/climate onthe worldwide web.

SECONDARY CONTAINMENT SYSTEMS

Type of System Description

Poured Concrete Walls Poured concrete walls are strong, fairly watertight, and resistant topetroleum penetration if adequately designed and maintained according togood engineering practices.

Limitations:

conventional concrete is not totally impervious to petroleum;any spill left inside a containment area may eventuallypenetrate the concrete and could contaminate groundwatersources. Therefore, spills inside diked areas should becleaned up as soon as possible.

the expansion and contraction of piping which runs throughcontainment walls create potential areas of weakness.

grouting in expansion joints requires maintenance to preventweak points, which may allow petroleum penetration.

Containment Curbs Containment curbs are similar to speed bumps and are often used wherevehicles 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 or trenches are belowgrade containment structures, which may bePits/Trenches covered with metal grates and lined with concrete.

Limitations:

earthen structures have the potential for groundwater contaminationunless 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 notproperly maintained.

SECONDARY CONTAINMENT SYSTEMS



Earthen Berms Earthen berms containing clay or bentonite mixtures are commonly used atvery large oil storage facilities.

Limitations:

earthen berms are subject to water and wind erosion and requirefrequent rebuilding;

sandy soil does not effectively contain oil spills; groundwatercontamination may result. Impervious liners of clay or syntheticmembranes may be required to contain oil spills; and

vegetation inside bermed areas is a fire hazard and restricts theoperator's ability to detect spills or defective equipment. In addition, theroot systems of plants, such as trees, shrubs or bushes, could degradethe 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 theintegrity of the wall.

concrete blocks are very porous therefore they do not form liquid-tightseals between mortared joints.

water and ice penetrate the blocks and eventually break them apart dueto the different phases of water.

Tank Integrity - Inspections and Testing

Oil-filled electrical equipment and ASTsshould be properly maintained to prevent oilleaking from bolts, gaskets, rivets, seams,and any other part of the tank. Personnelshould note visible oil leaks on an inspectionform and report them to the person incharge of spill prevention. Leaks should berepaired immediately. In some cases, theproduct in the tank will require removal.

Oil leaks from compressors and other unitsare a common problem. Leaks must becorrected immediately and the surfaces ofcontainment areas should be kept clean.

Electrical equipment can have low-levelalarms or failure alarms installed to detectleakage. Electrical equipment control casescan be equipped with catchpans to preventcompressor oil from leaking into the electricyard.

An area of concern for ASTs is tank bottomdeterioration. Tank bottoms may be subjectto extensive corrosion, which may not beevident during visual inspections. Measuresmust be taken to prevent this corrosionbased on the type of tank installation andtank foundation. Corrosion protection canbe provided by dielectric coatings andcarefully engineered cathodic protection. Some facilities have installed double-bottomtanks to reduce the corrosion factor.


Corrosion of a tank’s surface may also result The steam return or exhaustin tank failure. Corrosion that is lines from internal heating coilsconcentrated in small areas of a tank’s that discharge into an open watersurface or “pitting” creates a high potential course should be monitored forfor tank failure. If tanks are rusty, holes may contamination or routed to aform causing the tank to leak. Tank settling tank, skimmer, or othersupports and foundations should also be separation system to remove oil;inspected for cracks, crumbling,deterioration, and seepage. Consider using external heating

ASTs should be subjected to periodic the tank if necessary. Becauseintegrity testing. Some of the accepted of the problems encountered withmethods for testing are the following: internal steam-heating coils,

X-ray or radiographic analysis away from their use to moremeasures wall thickness and modern external heat-exchangerdetects cracks and crevices in systems.metal.

Ultrasonic analysis measuresshell metal thickness.

Hydrostatic testing shows leakscaused by pressure.

Visual inspection detects somecracks, leaks, or holes.

Magnetic flux eddy current testused in conjunction withultrasonic analysis detectspitting.

Internal Heating Coils

Internal steam-heating coils are often usedin fuel oil tanks to maintain the oil in a fluid,less viscous state in cold weather. Thedeterioration of the steam-heating coils frominternal corrosion can result in productleakage when oil drains through a corrodedcoil to discharge into a nearby waterway. Tocontrol leakage through defective internalheating coils, the following factors should beapplied:

coils and insulating the sides of

there has been a movement

Fail-Safe Devices - Level GaugingSystems and Alarms

When filling tanks or electrical equipment,facilities must take precautions to ensurethat the equipment is not overfilled.

When transferring insulating oil to electricalequipment, great care must be exercised toensure that an overfill does not occur. Some electrical equipment can be equippedwith high-level alarms (many are equippedwith low-level alarms to detect leakage).Facilities should ensure that the capacitiesof the equipment are accurately accountedfor, and transfers should be continuouslymonitored.

For ASTs, level gaugingsystems must be selected inaccordance with goodengineering practices basedon the size and complexity of

operations at a facility. It is not adequate toonly “stick” a tank. A second overfillprotection measure should be used as abackup. Some trucks have automaticshutoff systems, which shut off the pump


once the meter reaches the volume ofproduct that has been determined to be asafe fill level (e.g., 90% of capacity). Largertanks may be designed with gauges, high-level alarms, and high-high level alarms tosatisfy this requirement. The following tableprovides examples of some acceptablesystems.

LEVEL GAUGING SYSTEMS AND ALARMS


Direct Sight Level In the simplest case, the gauge is a small-diameter glass or plasticGauges 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 ontop of the liquid in the tank and moves a marker attached to a cableor chain on the outside of the tank. The marker moves up or downwith the product level in the tank.

Digital Computers or Telepulse is a simple and accurate system for remote supervision ofTelepulse storage tank liquid levels and temperatures. The unit consists of a

transmitter and receiver to relay and receive tank temperature andproduct level readings. Digital computers can be tied in to displaydata at more than one location. Portable fill alarm systems are alsoavailable that can be used while liquid cargoes are transferred froma storage container into a transportation vehicle. Many variations ofthese systems are in use.

High Liquid Level High liquid level alarms are usually tied into a float gauge or levelAlarms gauging system. The alarms produce an audible or visual signal

when the liquid level in the tank reaches a predetermined height. Inolder systems, a simple sound is produced by air motion; this iscalled an audible air vent.

High Liquid Level This consists of a fill-level alarm connected to a pump control thatPump Cutoffs automatically shuts down the pump when a preset liquid level is

reached. This system eliminates the possibility of human failure andis effective at stopping overfilling of tanks.

Direct Audible/Code This system consists of communication between the tank gaugerSignal Communication and pumping station and relies on human perception of liquid levels

in the tanks and pumping rates to avoid overfilling tanks. Humanerror could cause a spill if the tank gauger or pumping stationmisreads an audible or code signal to start or stop pumping. Communication between the gauger and pump station is usuallythrough two-way radio.

LEVEL GAUGING SYSTEMS AND ALARMS



REMEMBER

Regardless of the system employed,all equipment must be inspected,calibrated and tested regularly.

Even if a tank is leased from the oilsupplier, it is ultimately the facility’sresponsibility if a spill occurs. Therefore, facilities must ensure thatleased tanks are also engineered toprevent overfilling.

Additional Safety Relief valves and overflow lines are part of safety and level controlFeatures systems on most petroleum storage tanks. Valves for pressure and

vacuum relief will prevent tank damage but may result in a spill ordischarge of liquid. Excess liquid may be allowed to flow intoanother tank through an overflow line. Vacuum vents prevent a tankfrom collapsing when liquid is pumped out of the tank.

Underground Storage Tanks

When compared to ASTs, USTs have someadvantages for storing petroleum products,such as reduced vapor loss, increasedsafety, efficient land use and greatersecurity. The obvious disadvantages areundetected leaks and higher corrosionfactors for metal tanks. Fiberglass-reinforced plastic tanks are commonly usedfor storing petroleum products underground. They have a distinct advantage over metaltanks in being corrosion-free. Corrosion-resistant coatings are also available.

Steel USTs should be protected fromcorrosion by coatings, cathodic protection, orother effective methods compatible withlocal soil conditions. Undergroundcorrosion of metal surfaces is a direct resultof an electric current that is generated by the

reaction between the metal surfaces andchemicals present in the soil and water. Theflow of current from one portion of the tankto another causes metal ions to leave thesurface of the metal, creating pits. The rateof destruction of the metal is directly relatedto soil moisture and chemical makeup.

All USTs should also be subjected to regularpressure testing and adequate records mustbe kept of such tests. These records mustbe made part of the SPCC Plan and kept forat least three years.

The Federal UST regulations found in 40CFR Part 280 have technical requirementsconsistent with the underlying regulatorypurposes of the SPCC program and areequally protective for purposes of preventingdischarges of oil into waters of the UnitedStates. These regulations containprovisions for corrosion protection, leakdetection, tank overfill and spill preventionequipment, and tank tightness testing. Facilities should refer to the full text of 40CFR Part 280 when making determinationsof compliance.


For More Information On CathodicProtection Consult:

American Petroleum Institute (API)Recommended Practice 1632: CathodicProtection of Underground PetroleumStorage Tanks and Piping SystemsPhone (202) 682-8000.

National Association of CorrosionEngineers (NACE) InternationalRecommended Practice RP-0285-85:Control of External Corrosion on MetallicBuried, Partially Buried, or SubmergedLiquid Storage SystemsPhone (713) 492-0535

NACE International RecommendedPractice RP-0169-92: Control andCorrosion on External Underground orSubmerged Metallic Piping SystemsPhone (713) 492-0535

Steel Tank Institute (STI) R892-91:Recommended Practice for CorrosionProtection of Underground PipingNetworks Associated with Liquid Storageand Dispensing SystemsPhone (202) 682-8000.


Partially Buried Storage Tanks

Partially buried metallic storage tanks usedfor petroleum storage should be avoidedunless the buried section of the shell isadequately coated. Partial burial in dampearth can cause rapid corrosion of metallicsurfaces due to water collecting at the soilsurface. Protective corrosion-resistantcoatings and cathodic protection should beused to prevent corrosion. Partially buriedtanks are considered to be abovegroundtanks and are subject to the samerequirements as other aboveground tanksunder the provisions of 40 CFR Part 112 dueto their potential threat to surface waters.

Portable Oil Storage Containers

Mobile or portable oil at the transfer point be capped or blank-storage tanks flanged and marked as(including trucks to origin for a pipelinecontaining product), that is not in service or55-gallon drums, and in standby service for another small containers should be positioned extended time. or located so as to prevent spilled oil from Aboveground pipereaching navigable waters. A secondary supports should bemeans of containment, such as dikes, designed and spaced inbasins, or spill pallets, must be provided. order to prevent sagging, minimize abrasionThe containment area must hold the and corrosion, and allow for expansion andcontents of the largest container stored in contraction.the area. Many facilities keep drums andportable oil tanks inside covered, contained Buried piping must have a protectivewarehouse storage areas. It is best to have wrapping and coating, and should bea covered area to reduce exposure to the cathodically protected if used in corrosiveelements so that the containers remain in soil conditions. If any section of buriedgood condition and runoff is eliminated. piping is exposed for any reason, it must be

These storage areas must be located where repaired, if necessary. Obviously, buriedthey will not be subject to periodic flooding piping cannot be visually examined and mustor washout. be subjected to periodic pressure testing,

Containment for drums and other small Plastic or fiberglass-reinforced pipes do notcontainers does not have to be expensive. require protective coatings or cathodicIf there are a small number of drums, a protection.facility may purchase spill pallets or portable

containment devices (e.g., overpack drums)designed for drum containment.

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

Piping may be used at an electrical utility forremoving insulation oil from equipmentwhich requires maintenance, for refillingequipment, and/or for filling storage tanks.

Underground cables or partially undergroundcables (often housed in a “cable tray”) areinsulated by mineral oil and can be a sourceof an oil discharge due to a joint failure orother failure. Careful monitoring andmaintenance of the insulation are needed.

SPCC requires that the terminal connection

examined for deterioration and corrosion and

regardless of materials of construction.


Inspections of Aboveground Pipes,Valves, and Pumps

All aboveground pipes and valves should beregularly examined on a scheduled basis byoperating personnel. Flange joints,expansion joints, valve glands and bodies,and metal surfaces should be evaluated. Piping in high spill probability areas shouldbe periodically subjected to pressure testing. Pipes, valves, and connecting joints shouldbe free of leaks, drips, and oil-saturated soilunderneath. Defective or leaking equipmentshould be replaced or repaired, andadequate records should be made of suchrepairs. All records should be made part ofthe SPCC Plan and kept for at least threeyears.

Pumps, valves, and gauges are coveredunder the same regulations as piping. Theymust be regularly examined by facilitypersonnel. They should be free of leaks,drips, or any defects which could lead to aspill. Soil underneath pumps, valves, andconnections should be free of oil stains orpooled oil. Flow valves must be periodicallypacked with grease to prevent leakage, andgaskets must be replaced periodically. Pumps require periodic rebuilding andconnecting lines need to be resealed toprevent leaks.

Warning Signs for Aboveground Pipes

Drivers granted entry into a facility must beverbally cautioned or warned by appropriatesigns to assure that their vehicle, because ofits size, will not endanger abovegroundpiping or hosing. Tank truckloading/unloading areas should haveappropriate protection for abovegroundpipes (e.g., bumper poles) and adequatesigns posted to warn drivers of the presenceof aboveground pipes in traffic areas.

Tank Car and Tank Truck Loading andUnloading Procedures [40 CFR112.7(e)(4)]

Electricalutilities mayrequire theuse of atank car ortruck for collecting used insulation oil(loading) from holding tanks or for fillingtanks which store new insulation oil(unloading).

Electrical utilities may receive product fromtanker trucks which may have three 3,000-gallon compartments (sizes vary) or fromother smaller trucks.

DOT Procedures

Regardless of the types of tank cars ortrucks servicing a facility, all drivers mustfollow loading/ unloading proceduresestablished by the Department ofTransportation (DOT) in 49 CFR Parts 171,173, 174, 177, and 179. Training programsshould thoroughly address theserequirements and procedures should beincorporated into a Standard OperatingProcedures (SOP) manual for producttransfer. Moreover, facilities shouldconsider ways to ensure that othercommercial drivers or contractors arecompetent in these procedures (e.g., issuedriver certifications).

Secondary Containment

Due to their function, tank car and truckloading/ unloading areas have a highprobability for spills. Secondary containmentsystems must be designed specifically for afacility’s topography configuration and thesize of the tank car/truck loading orunloading at the site.


Loading/unloading areas typically aredesigned to permit vehicle access, so thedesign must incorporate a secondarycontainment system. The most commonloading area containment system is acovered, curbed, and graded area thatdrains to a sump. Drainage should flow intoponds, lagoons, catchment basins, ortreatment systems designed to retain oil orreturn it to the facility. A system thatincorporates good engineering practicesminimizes the volume of water, ice andsnow that enters the containment area.

The containment system must be designedto hold the maximum capacity of the largestcompartment of a tank car or truck loaded orunloaded at the facility. If there are separateareas for different unloading or loadingoperations, each area should be designedspecifically to hold the capacity of the largestcarrier anticipated to conduct operations inthat area. An engineer must look at theentire facility as a unit to determine theadequacy of the spill containment systems inplace.

Warning or Barrier System

An interlocked warning light or physicalbarrier system (such as a brake-interlocksystem), or warning signs should beprovided in loading/unloading areas toprevent a vehicle from leaving before beingcompletely disconnected from the fueltransfer lines.

Prior to filling and departure of a tank car ortruck, the lowermost drain and all outlets ofsuch vehicles should be closely examinedfor leakage. If necessary, valves should betightened, adjusted, or replaced to preventleaking in transit.

Inspections and Records [40 CFR112.7(e)(8)]

Inspections are an important part ofpreventing spills due to equipment orcontainment system failure. Adequateinspection and maintenance programs are acritical component of a spill preventionprogram. Inspection and maintenancerecords provide the only real evidence ofcompliance testing of storage tanks, piping,level gauging systems, alarms and relatedequipment.

Records of inspection procedures (includingfrequencies of inspections), maintenance,and draining of diked areas should beincluded in the facility’s SPCC Plan.

Records of drainage of diked areas areimportant in determining a facility’scompliance, especially when drainage flowsdirectly into a navigable waterway andbypasses in-plant treatment systems.

The following table includes the types ofrecords that should be maintained at afacility. Such records must be kept for aminimum of three years.


INSPECTION AND MAINTENANCE PROGRAM RECORDS

Aboveground Regular visual inspections and/or tank integrity testing (e.g., shellStorage Tanks, thickness testing).Piping, and OtherOil-Filled Pipe supports, pipes, valves and pumps (regular visual inspections).Equipment

Piping in high risk spill areas (periodic pressure testing).

Storage tank flow valves, supports, foundations (regular visualinspections).

Storage tank level gauges and alarms (regular mechanical functiontesting/visual inspections).

Underground Pressure testing of tanks and piping.Storage Tanks andPiping Inventory monitoring for leaks.

Testing of cathodic protection system.

Dikes, Berms, Containment dikes and berm integrity (regular visual inspections).SecondaryContainment Records of drainage of rainwater from diked containment areasSystems (must be recorded whenever areas are drained).

Rainwater must be free of oil sheen.

Date, time, and signature of employee who performed drainageand/or manager.

Security [40 CFR 112.7(e)(9)]

Security is critical to preventing accidentalreleases or vandalism by the public. Thesecurity measures required under SPCC aresimple precautionsthat greatly reducethe risks ofvandalism andundetected spills.

The perimeter of afacility should be protected with goodlighting, fencing, and locked gates. Motiondetectors and video cameras may be usedfor added security. Access to the facilityshould be restricted during nonbusinesshours. Starter controls for fuel pumpsshould be locked. Any valves that will allow

the direct outflow of product are alsorequired to be locked (e.g., water draw-off,sampling, and sparge valves). It isrecommended that tanks and pipelines belabeled and kept out of public access areas. Loading/ unloading connections andpipelines should be capped or blank-flangedwhen they are not in service.

Spill Prevention Training [40 CFR112.7(e)(10)]

A large number of spills is caused byoperator error; therefore, training andbriefings are important for the safe andproper functioning of a facility. Trainingencourages up-to-date planning for thecontrol and response to a spill and anunderstanding of the facility’s spill prevention

Spill

Prevention


Owner/Operator Relationship

Both the owner and operator, whether privateindividuals, corporations, or other entities,must take responsibility for ensuringcompliance with the SPCC requirements.

An owner who leases property should ensurethat the operator has adequately engineeredhis/her operations to meet the SPCC Planrequirements and that the SPCC Plan isadequate and being properly implemented(through monitoring). To that end, the ownermay wish to include language in the leasethat states clearly that the operator isresponsible for promptly providing to theowner true, accurate and complete copies ofany and all documents relating to the SPCCand FRP requirements.

To facilitate compliance, owners and theiroperators should keep each other informed. It is important to remember, however, thatresponsibilities required by law cannot bechanged by contract. Therefore, the ownermay be held liable for an operator’sfailure to prepare and/or implement anSPCC Plan which is consistent with therequirements of 40 CFR Part 112.

controls and SPCC Plan. Regular safetyand spill prevention briefings should be heldto facilitate discussions of spill events orfailures, malfunctioning equipment, andrecently developed precautionary measures. Also, one person must be designatedaccountable for spill prevention at thefacility.

Owners and operators are responsible forproperly instructing drivers, tank gaugers,pumpers, and any other operating personnelinvolved in oil operation systems in theoperation and maintenance of equipment toprevent the discharge of oil and applicablepollution control laws, rules and regulations. All employees should be familiar with theSPCC Plan and where it is kept or have acopy of the Plan available for their use.

Records of employee training and spillprevention briefings for personnel should beincluded in the SPCC Plan and kept for aminimum of three years.

Troubleshooting

Facilities should considercurrent operations and howthey can be improved toprevent spills and meet the regulatoryrequirements by conforming with goodengineering practices. To this end, thequestions and answers appearing below arebased on practices observed at vehicleservice facilities by federal, state, and localregulatory agencies. Some of the issuesand practices discussed are bestmanagement practices (BMPs) and may besupplemental to the regulatory requirements. Others may be essential to achieving


EPA’s Chemical EmergencyPreparedness and Prevention Office hasprepared an “Alert” entitled LightningHazard to Facilities Handling FlammableSubstances. For a copy, phone (800)424-9346 or (703) 412-9810.

compliance with the SPCC requirements orstate regulations.

What types of procedures or equipment arein place at the facility to prevent andcontrol a product discharge in the event ofa human error or equipment malfunction?

Some facilities have simple systems inplace, such as ditches completelysurrounding the facility, that can hold allof the surface runoff from rain and oilthat may spill. Others may havecomplex operations which continuouslyrely on equipment, such as oil-waterseparators, for preventing dischargeswhile draining rainwater. Equipmentshould be closely monitored to ensureproper operation. Oil-water separatorsand outfalls should not automaticallydischarge to a waterway and should beequipped with block valves.

Make sure that all valves are workingproperly. Shutoff valves that do not workproperly may result in spills.

How does the facility prevent pipelineruptures?

Monitor pressure in piping systems,especially in the summer whentemperatures may be high. Regulatepumping pressure so that the pipingpressure does not exceed its pressurerating. Couplings and connectionsshould have pressure ratings compatiblewith piping systems. Pressure-testpiping before returning it to service andat regular intervals while in service.

How is equipment protected from vehicleimpact?

All electrical equipment, tanks, pipelines, and cable trays should be

protected by installing bumper poles andother physical barriers and warningsigns, including signs identifying truckclearances.

Has your facility considered the possibilityof lightning causing oil spills?

Lightning can strike transformers, tanks,and other equipment containing oil. When it does, it frequently results in acombination of fire and spilled oil. Thechance of lightning striking equipmentcan be significantly decreased by properlightning protection.

What is the facility’s protocol formaintaining equipment and correctingvisible oil leaks?

Institute a regular preventivemaintenance program to prevent leaks,equipment malfunctions, and spills. Replace worn seals, fittings, and otherparts before they leak or break. Wastewater or stormwater treatmentsystem equipment, including oil-waterseparators, must be regularly maintainedto prevent clogging and other problemsthat may lead to equipment failure.


Is the facility’s training program adequateto maintain personnel awareness of thespill prevention techniques described in theSPCC Plan and correct operatingprocedures?

Owners or operators are responsible forinstructing their personnel in theoperations and maintenance ofequipment to prevent the discharges ofoil and applicable pollution control laws,rules, and regulations.

Refresher training should be conductedat regular intervals. Training shouldinclude testing to ensure that personnel,especially new hires, have anunderstanding of the conceptsdiscussed.

Is spill control equipment strategicallylocated and is the storage area adequatelystocked based on the facility’s needs?

Keep spill kits containing absorbentpads, booms, disposal containers orbags, an emergency responseguidebook, and a fire extinguisher in acabinet or locker near the storage andloading/unloading areas. Regularlyinspect the cabinet where emergencyspill response supplies are kept toensure the cabinet is properly stocked.

Does the facility have a spill response plan?

For those facilities not required toprepare a facility response plan under 40CFR Part 112.20, it is still recommendedto develop a spill response plan. Provide this plan to the fire departmentand local response agencies. Havefrequent drills and invite local respondersto participate.

Facility Construction and Design

There are a variety of ways for a facility tobe designed and constructed to achievecompliance with the SPCC requirements. Facilities may differ greatly in the types ofdiversionary structures and spill controlequipment employed. Small facilities mayutilize simple yet effective methods whilelarge facilities may employ state-of-the-arttechnologies to treat contaminated drainage,achieve overfill protection on tanks and tanktrucks, conduct integrity testing, providefacility security, and train employees. Facilities should also consult industryassociations, which specifically identifytechnical and engineering standards for thedesign and construction of tanks andpipelines; cathodic protection of tanks andpipelines; AST tank bottom liners; tankinspection, repair, alteration, andreconstruction; tank cleaning; and tankoverfill protection. These standards mayassist the facility in identifying goodengineering practices and achievingcompliance with the SPCC requirements.


SUMMARY OF COMMON INDUSTRY STANDARDS

Underwriters Laboratory (UL)Standard 142Steel Aboveground Tanks forFlammable and CombustibleLiquids

This standard applies to steel atmospheric tanks intendedfor aboveground storage of noncorrosive, stable,flammable, and combustible liquids that have a specificgravity not exceeding that of water. The standard does notapply to API Standard 650, 12D, and 12F tanks.

National Fire ProtectionAssociation (NFPA) Code 30AAutomotive and Marine ServiceStation Code, Chapters 1 and 2

This standard applies to automotive and marine servicestations and to service stations located inside buildings(special enclosures). The code does not apply to servicestations that dispense liquefied petroleum gas, liquefiednatural gas, or compressed natural gas as motor fuels.

National Fire ProtectionAssociation (NFPA) Code 30Flammable and CombustibleLiquids Code, Chapter Two

This standard applies to all flammable and combustibleliquids, including waste liquids (except those that are solidat 100 degrees Fahrenheit or above and those that areliquefied gases or cryogenic). Chapter Two, Tank Storage,applies to aboveground and indoor storage of liquids infixed tanks and portable tanks with storage capacities ofmore than 660 gallons.

American Petroleum Institute(API) Standard 620Design and Construction ofLarge, Welded, Low-PressureStorage Tanks

This standard addresses large field-assembled storagetanks that have a single vertical axis of revolution andcontain petroleum intermediates and finished products, aswell as other liquid products handled and stored by thepetroleum industry.

API Standard 650Welded Steel Tanks for OilStorage

This standard provides material, design, fabrication,erection, and testing requirements for vertical, cylindrical,aboveground, closed- and open-top, welded steel storagetanks in various sizes and capacities.

API Recommended Practice651Cathodic Protection of ASTs

This recommended practice describes the corrosionproblems characteristic in steel ASTs and associated pipingsystems and provides a general description of the twomethods used to provide cathodic protection.

API Recommended Practice652Lining AST Tank Bottoms

This recommended practice describes the procedures forachieving effective corrosion control in ASTs by applicationof tank bottom linings to existing and new storage tanks.

API Standard 653Tank Inspection, Repair,Alteration, and Reconstruction

This standard pertains to carbon and low alloy steel tanksbuilt in conformance with API Standard 650 or 12C andprovides criteria for the maintenance, inspection, repair,alteration, relocation and reconstruction of welded orriveted, nonrefrigerated, atmospheric pressure ASTs afterthey have been placed in service.

API Recommended Practice920Prevention of Brittle Fracture

This recommended practice addresses toughness levels forpressure vessels to prevent failure by brittle fracture.

API Standard 2015Safe Entry and Cleaning ofTank

This standard provides guidelines for the development ofsafety practices for planning, managing, and conductingwork in atmospheric and low pressure storage tanks.

OIL

SUMMARY OF COMMON INDUSTRY STANDARDS


NOTICE

The statements in this document are intended solely as guidance. This document is notintended and cannot be relied upon to create rights, substantive or procedural, enforceableby any party in litigation with the United States.

API Recommended Practice2350Overfill Protection for PetroleumTanks

This recommended practice provides guidelines forestablishing operating procedures and for selectingequipment to assist in the reduction of overfills.

API Standard 2610Design, Construction,Operation and Maintenanceand Inspection of Terminal andTank Facilities

This standard compiles various standards, specifications,and recommended practices developed by API and otherentities for managing terminals and tanks.

ACKNOWLEDGMENTS

We would like to acknowledge Regina Starkey of U.S. EPA Region III for her valuable assistancein the preparation of this guide. The following publications also provided valuable assistance:

USDA REA, 1993. Design Guide for Oil Spill Prevention and Control at Substations , Bulletin1724-302.

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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