F F e de ra l SPCC vs Sta te Stora g e e de ra l SPCC vs. Sta te Stora g e T a nk Environme nta l Re g ula tions Aisha Beaty Barr Engineering Company
purpo se • most industrial facilities utilize storage tanks in some capacity capacity • Federal and State regulations may apply to each tank • regulations are vastly different regulations are vastly different • permit holders cannot assume that compliance with one regulation applies to others • regulations can be confusing, hard to find, and may not be included in facility permits • compare the go erning bodies’ reg lations • compare the governing bodies’ regulations • identify key differences to help facilities achieve and document compliance with each regulation document compliance with each regulation
o utline • background background • SPCC • MN AST • MN AST • MN UST • comparison of i f the regulations • useful resources f l • summary
bac kgro und • two governing bodies concerning storage two governing bodies concerning storage tanks in Minnesota – USEPA Spill Prevention, Control and USEPA Spill Prevention Control and Countermeasures (SPCC) regulations – MPCA Regulations MPCA R l i • Above Ground Storage Tank (AST) • Underground Storage Tank (UST)
MPCA regulatio ns • facilities with one million gallons or more facilities with one million gallons or more must obtain MPCA storage tank permit (MN CH 7001) • applies to all liquids, not just oil • Aboveground Storage Tanks (ASTs) = Aboveground Storage Tanks (ASTs) Minnesota Rules, Chapter 7151, Statutes 116.47 and 116.48 • Underground Storage Tanks (USTs) = MN CH 7150
F ederal SPCC (40 CF R part 112) • purpose is to prevent oil discharges from pu pose s to p e e t o d sc a ges o reaching navigable waters or adjoining shorelines • applies to any facility over capacity threshold pp y y p y • any facility handling oil that could reasonably be expected to discharge oil into navigable water • applies to tanks containing oil (petroleum or non) • requires a written SPCC Plan • MOST USTs fall under a separate regulation (40 CFR part 280) only requirement is to label on map
applic ability MPCA SPCC owners and operators of ASTs any facility that stores oil products in general and USTs storing liquids tanks above the aggregate capacity applica ‐ threshold and has potential to discharge bility i t into navigable waters i bl t facility none 1,320 gal in AST capacity threshold container ‐ AST less than 1,100 gal 55 gallons in AST capacity unless it is above 500 gal and threshold within 500 feet of a Class 2 surface water ‐ UST less than 110 gal example equipment or machinery asphalt cement, wastewater tanks, exclusions including electrical milk product containers equipment, indoor tanks
ple ase no te : assumptions: – at a facility with <1 million gallons – permanent outdoor tank – permanent outdoor tank – over 1,100 gallons – further than 500 feet from a class II water – contains a substance that requires registration by MPCA and compliance with the construction and work practice standards
tank registratio n/ no tific atio n o f c hanges MPCA (statutes 116.47 and 116.48) SPCC ASTs no register each tank containing petroleum, registration • hazardous substances, and asphalt over 500 h d b t d h lt 500 or gallons (with exceptions) within 30 days notification update registration when tank status changes update registration when tank status changes required required • USTs register each tank over 110 gallons (with • exceptions) within 30 days update registration when tank status changes • 10 day advanced notifications 10 ‐ day advanced notifications • •
repo rting MPCA MPCA SPCC SPCC report discharges over 5 report discharges to • gallons immediately which, g y , navigable water within g if not recovered, could 60 days: o more than 1,000 gal pollute waters of the state o more than two (statute 115.061) discharges each over 42 gallons in a 12 42 gallons in a 12 ‐ month period
labeling MPCA MPCA SPCC SPCC • temporary tanks larger than 1,100 gal: no requirements o “temporary storage” p y g o date storage began on site • ASTs : o substance stored o substance stored o tank's capacity o a unique tank number • lines for loading and unloading li f l di d l di • sign with facility contact information if the site is not manned 24/7
se c o ndary c o ntainme nt MPCA SPCC • allows active OR passive ASTs • all ASTs must have secondary containment • must be able to contain 100% • must be able to contain 100% containment containment • substances sharing capacity of largest tank in containment must be containment plus freeboard p compatible for precipitation • oil ‐ filled operational • must be able to contain 100% capacity of largest tank in it f l t t k i equipment may use i t containment plus 10% where monitoring instead exposed to precipitation p p p • locate portable containers to p USTs ‐ reinforced double ‐ walled prevent a discharge tank and piping
o verfill pro tec tio n MPCA SPCC ASTs which are filled by >55 gal provide at least one of the at a time must have one: following: high ‐ level alarm high level alarm high level alarm high level alarm • • • • automatic shutoff automatic shutoff • • sight glass or gauge g g g g direct vision gauges g g • • manual dip stick • double walled tanks which are regularly test liquid level not located in secondary t l t d i d sensing devices to ensure i d i t containment must have high ‐ proper operation level or auto shutoff USTs – ensure that releases due regularly check interstitial space to overfilling do not occur on double ‐ walled tanks
re c o rdke e ping MPCA SPCC life of system e o syste three years three years maintenance and repair documents inspection • • third ‐ party certifications records • drawings drawings • • tank and containment design • soil classification used in secondary containment • permeability tests • hydraulic conductivity of soil • documents of corrosion protection p • internal and external inspections • three years service checks and equipment calibrations service checks and equipment calibrations • • records of periodic monitoring • compliance with out ‐ of ‐ service requirements •
c o rro sio n pro te c tio n MPCA SPCC ASTs: protect floor of steel tanks ASTs: protect floor of steel tanks buried piping buried piping elevate on supports • or tanks must rest on cement • have cathodic double walled double walled • • protection double bottomed with vacuum and cathodic protection • cathodically protect tank floor and have internal lining • install internal lining on tank floor and inspect install internal lining on tank floor and inspect • • USTs: metal tanks and piping without fiberglass reinforced plastic jacket impressed current – check rectifier every 60 days, test impressed current check rectifier every 60 days test • • annually sacrificial anodes – test every 3 years • internal lining – inspect after 10 years and every 5 i t l li i i t ft 10 d 5 • thereafter
inspe c tio ns MPCA MPCA SPCC SPCC ASTs create an inspection • every 72 hours – non ‐ double ‐ y and testing program g p g • walled tanks with inadequate certified by a secondary containment professional engineer weekly – non ‐ double ‐ walled inspections during • • tanks with adequate transfers secondary containment secondary containment inspect secondary inspect secondary • • monthly – all tanks containment prior to • USTs ‐ monitored every 30 days USTs monitored every 30 days discharge discharge
inspe c tio n iPad applic atio n • shows all SPCC inspection sites on an interactive map • fills out inspection form for fills out inspection form for each site electronically • adds new sites/changed • adds new sites/changed information in real ‐ time • populates l t spreadsheets/reports electronically l t i ll
o the r • personnel training – SPCC requires annually personnel training SPCC requires annually • substance transfer areas – MPCA: provide for all tanks, substance transfer safeguards such as spill tanks, substance transfer safeguards such as spill boxes, remote fill boxes, or containment areas unless the tank is filled with a hand ‐ held nozzle, through a pipeline, or a barge. At least one person must be present to monitor transfer. • tank car and tank truck loading/unloading rack – SPCC: design containment, prevent spills
c o mmo nly missed tanks subject to MPCA? subject to SPCC? no yes tote tanks portable tanks yes yes oil tanks for elevator oil tanks for elevator no no yes yes operations gas tanks on a generator no yes electrical equipment no yes tank truck or railroad car yes yes (if in place for 30 days or (if in place for 30 days or (if only operates within (if only operates within more) facility and is not DOT) substance transfer areas yes yes oil/water separators yes (but doesn’t require yes registration)
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