Aboveground Petroleum Storage Act Requirements

1
Aboveground Petroleum Storage Act Requirements
2
Overview

• Background and Scope of APSA
• Definitions
• APSA Facility Types
• SPCC plan Requirements
• Facility Diagram, Procedures, Training,
  Recordkeeping, Maintenance
• Inspection Timeframe what to expect

3
APSA Background

• Aboveground Petroleum Storage Act is now part of
  CA HSC, Chapter 6.67
• Gives local CUPAs authority over APSA
• Federal Oil Spill Prevention Program is part of
  40 CFR 112
• Federal EPA still has authority
• Requirements of each program are similar but not
  identical

4
Scope of APSA

• Feds Navigable Waters
• CUPA greater than 1,320 gallons

5
Regulated Chemicals

• Petroleum crude oil fraction, liquid at room
  temperature and pressure
• Includes fuels, lubricants, solvents, biodiesel
• But NOT propane, LPG, LNG, or 100 biodiesel or
  synthetics or corn ethanol, some waxes, tars, or
  asphalts

6
Aboveground Tank

• 55 gallon or more capacity
• Substantially or totally above ground

7
NOT Aboveground Tanks

• NOT
• Permanently Closed tanks, Boiler, Haz Waste at
  TSD facility, crude oil production tank,
  oil-filled electrical equipment, UST, or a DOT
  regulated tank

8
Permanently Closed Tanks

• All liquid and sludge removed from tank and
  connecting lines
• All pipes and lines disconnected and blind
  flanged/blanked
• All valves closed and locked out (except vent
  valves)
• Tagged as permanently closed with closure date

9
(No Transcript)
10
(No Transcript)
11
(No Transcript)
12
Transportation Related?
13
(No Transcript)
14
(No Transcript)
15
APSA Facilities

• 1,320 gallons or more of aggregate aboveground
  petroleum storage capacity
• Based on Rated Design Capacity...
• Modified overflow, vent, etc. does not always
  count
• Procedural means of limiting capacity do not
  count

16
APSA Exempt Facilities

• A tank facility at a Farm, Nursery, Logging site,
  or Construction site is exempt if..
• No tank exceeds 20,000 gallons
• AND total storage is less than 100,000 gallons
• APSA Exempt facilities must still
• Conduct daily inspections
• Allow CUPA to inspect periodically
• Provide Secondary Containment if required by CUPA
• Comply with applicable Federal rules

17
(No Transcript)
18
(No Transcript)
19
(No Transcript)
20
(No Transcript)
21
What is an SPCC plan?

• Spill Prevention, Control, and Countermeasure
  (SPCC) plan
• Spill Prevention
• Training, procedures, awareness
• Control
• Containment, immediate response
• Countermeasure
• Cleanup, notifications

22
Three types of APSA facilities

• Tier I Qualified Facility
• - Can use Template SPCC and self-certify
• Tier II Qualified Facility
• - Can self-certify own SPCC plan
• Non-qualified Facility
• - Must have SPCC plan certified by a Professional
  Engineer

23
Qualified Facilities

• To be a Qualified Facility
• Less than or equal to10,000 gallons of any
  aboveground oil storage not just petroleum
• No discharge greater than 1,000 gallons in past 3
  years
• No two discharges greater than 42 gallons within
  any 12 month period in the past 3 years

24
Tier I Qualified Facilities

• Less than or equal to10,000 gallon total
  aboveground oil storage capacity
• No single tank more than 5,000 gallons
• You must
• Complete and self-certify the Template SPCC Plan

25
Tier II Qualified Facilities

• Less than or equal to10,000 gallon total
  aboveground oil storage capacity
• Individual aboveground tank more than 5,000
  gallons
• You must
• Prepare a self-certified SPCC plan

26
Non-Qualified Facilities

• Greater than 10,000 gallons total aboveground oil
  storage capacity
• You must
• Have an SPCC plan certified by a Professional
  Engineer

27
SPCC Plan Elements

• Elements required in an SPCC plan include
• - Facility description and diagram
• - Description of each storage location, and
  containment
• - Likely discharge scenarios
• - Tank inspection and testing program
• - Oil handler training
• - Security
• - Response and notifications
• - Plan must be reviewed at least every 5 years.
  Must be updated within 6 month of any significant
  change

28
Inspection

• Plan prepared properly?
• Plan implemented as described?
• Workers know about plan?
• Plan vs. Real World
• CUPA only inspecting APSA subject items
• Plan must be implemented by Nov 10, 2010

29
Sized Secondary Containment

• Contents of largest container plus precipitation
• Applies to
• Loading/unloading Racks
• Storage tanks and containers
• Includes portable totes and drums while stored
  (must also be located properly)
• Non-transportation related tank trucks (i.e.
  mobile refuelers) during storage

30
Sized Secondary Containment
31
Sized Secondary Containment
32
Secondary Containment (Drainage)

• Water inside secondary containment must be
  inspected for oil contamination prior to
  discharge
• Records should be kept for at least 3 years

33
(No Transcript)
34
(No Transcript)
35
(No Transcript)
36
(No Transcript)
37
(No Transcript)
38
General Containment

• Most likely discharges ? spill kits, drain
  covers, spill buckets, etc.
• Applies to
• Piping, oil-filled equipment, (non-rack) transfer
  areas, non-transportation related tank trucks
  (i.e. mobile refuelers) during use

39
POOR General Containment
40
General Containment
41
General Containment
42
(No Transcript)
43
(No Transcript)
44
Overfill Prevention

• Describe Procedures and Hardware

45
(No Transcript)
46
(No Transcript)
47
Overfill Prevention

• High liquid level alarms/shutoffs
• Liquid level indicators
• Alarm should be heard or electronically sent to
  pumping station

48
(No Transcript)
49
(No Transcript)
50
Loading Racks

• Permanent Structure w/ piping, loading arm,
  valves, pumps, shut-offs, etc

51
Loading Racks

• Must have
• Anti drive-off devices
• Physical barriers, warning lights/signs, wheel
  chocks, brake interlock system, etc.
• Secondary containment method for largest tank or
  railcar filled
• Catchment basin or quick drainage system
• Records of Inspections

52
Security

• Fences, locks, guarded entrance, etc. around
  whole facility
• Lighting to
• See discharges at night
• Prevent vandalism

53
Security
54
Security

• Locks on Tanks, Pump Controls accessible only to
  authorized personnel

55
Tank Inspections

• in accordance with industry standards
• Up to facility and certifying P.E.
• Many standards for different tank types
• Frequency and Methods of inspection must be
  referenced in the SPCC plan
• Qualifications of testing inspection personnel
  must be referenced in SPCC plan

56
Tank Inspections

• Integrity testing may include visual inspection,
  hydrostatic testing, radiographic testing,
  ultrasonic testing, acoustic emissions testing,
  or other non-destructive testing methods

57
Training

• SPCC Plan must identify person accountable for
  discharge prevention
• All oil-handling personnel must receive training
  in
• OM to prevent discharges
• Applicable pollution control laws and regs
• Discharge procedure protocols
• General facility operations
• Contents of the SPCC plan

58
Refresher Training

• All oil handling personnel must receive annual
  training updates
• Any new procedures
• Any new equipment
• Any malfunctioning or out of service equipment
• Known discharges to Navigable Waters

59
Summary

• 1,320 gallons of aboveground aggregate petroleum
  storage
• 10,000 gallons total oil storage, no tank larger
  than 5,000 ? E-Z template
• 10,000 gallons total, single tank gt 5,000 ?
  self-certify
• gt10,000 gallons ? P.E. Certified Plan

60
Summary

• Spill Prevention Control and Countermeasure
• Methods, Descriptions, Trainings, Tank
  Inspections, Records
• Reviewed every 5 years
• Amended and Certified within 6 months of any
  change

61
Resources

• Madera County Env Health / CUPA
• 2037 W Cleveland Ave
• Madera, Ca 93637
• envhealth_at_madera-county.com
• [phone]
• www.calepa.ca.gov/CUPA/Aboveground/
• www.epa.gov/OEM/content/spcc/index.htm
• www.epa.gov/emergencies/content/spcc/index.htm
• www.epa.gov/oilspill/spcc.htm

62
(No Transcript)
63
(No Transcript)
64
(No Transcript)
65
(No Transcript)
66
(No Transcript)
67
(No Transcript)
68
(No Transcript)
69
(No Transcript)