Integrity of Secondary Containment for Crude Oil Storage Tanks at VMT PWSRCAC Staff Tom Kuckertz Linda Swiss TOEM and OSPR Committees 1/16/13 Integrity of Secondary Containment • Discovery of initial integrity issue • More integrity issues • Secondary containments • Regulatory actions • Corrective actions • Planning for more corrective action • Questions 1/16/13 1
Alyeska Discovers and Reports Catch Basin Integrity Iss ue • July 7, 2008 • Catch basin in Tanks 9/10 containment unable to hold water above steel liner • Determination of repair options • Indefinite timeline for inspection and repair of remaining catch basins 1/10/2013 Secondary Containment Issues • Manhole and catch basin integrity • Drainage system integrity • Liner system 1/16/13 2
1/16/13 9 Crude Oil Secondary Containments 1/16/13 3
Catch basin and nearby manhole 1/16/13 Secondary containment contains oil that might leak from primary containment (crude oil storage tank). All water is removed from secondary containment by drainage system and processed at Ballast Water Treatment Facility. 1/16/13 4
Occasionally, secondary containment prevents oil from leaking into the environment as it did for the spill at PS-9 1/16/13 ADEC Issues Notice of Violation • July 31, 2008 • NOV for failure to comply with C-plan requirements – breach of secondary containment • Directed “prompt action” to remedy catch basin integrity issues • Alluded to possible Attorney General referral 1/10/2013 5
BLM/OPM Issues Expectations Letter • August 1, 2008 • Concerns expressed regarding Alyeska letter of July 7, 2008 • Cites federal regulatory requirements from Grant of Right-of-Way for TAPS • Directs action “as soon as possible” 1/10/2013 A new (2009) manhole has just been installed. Inlet/outlet piping is visible 1/16/13 6
Manhole is leak tested. Less than 0.25 inch per hour leak-by deemed acceptable 1/16/13 Alyeska Discovers and Reports Secondary Containment Integrity (Drainage System)Issue • November 25, 2009 reported to PWSRCAC • Piping between manholes in secondary containment for Tanks 5/6 and 7/8 unable to hold water • Regulators deem secondary containment regulations applicable 7
Affected Drainage System Piping 1/16/13 Secondary Containment Integrity (Liner System) Issues • Liner System: – Membrane (above ground and at penetrations) – Catalytically blown asphalt (CBA) (buried) – Penetrations (catch basins, manholes) • Susceptible to damage and deterioration – Membrane – wind driven tears, UV degradation?, etc. – CBA – victim of the “Super Sucker” and other excavators. – Not systematically inspected since construction 1/16/13 8
Above-ground portion of the liner is a membrane 1/16/13 1/16/13 9
Damage to the CBA portion of a liner immediately before repair 1/16/13 Completed repair to CBA portion of liner prior to replacing gravel overburden 1/16/13 10
Status of Catch Basin and Manhole Repairs • New and repaired manholes and catch basins • Testing deemed successful by Alyeska and regulators? – Plug, water fill, and level decrease (<= 0.25 in/ hour) – Recent use of ASTM sewer piping standard to determine testing success 1/16/13 Status of Drainage System (IWWS) 2008 – Notice of Violation issued Originally manholes and catch basins IWWS included when drainage problems became known 2009 – Repair plan for manholes developed Completion of repairs anticipated November 2009 Additional leaks in IWWS discovered. Deadline for repairs extended to October 2010 2010 – Life cycle repair plan developed. Temporary repairs using lay-flat liners. ADEC deadline extended to October 2012 11
Status of Drainage System (IWWS) 2011 – Life cycle repair plan approved Cured-in-place pipe liners selected Series of “slipped” deadlines Pipe liner rips during installation late in year 2012 – Permanent repairs attempted Repairs failed pressure testing Material for cured-in-place liners incorrect thickness and diameter October deadline for completion of repairs slipped Wintertime water management ( ad hoc ) 2013 – ADEC 2008 NOV still pending resolution 1/16/13 Status of Liner System • Occasional tears and compromise of CBA fixed promptly upon occurrence and/or discovery • No systematic inspection otherwise • No verification of permitted permeability being planned or attempted 1/16/13 12
Questions 1/16/13 End of Presentation 1/16/13 13
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