EPA Focus on Oil Spill Prevention Results in Three Settlements -Effort includes inspections of multi-facility companies
Release date: 01/15/2008
Contact Information: Paula Ballentine, (617) 918-1027
(Boston, Mass. - Jan. 15, 2008) - Under an ongoing EPA effort to prevent oil spills, three additional New England companies will pay penalties to resolve allegations that they violated federal regulations related to the storage of oil. The companies have operations in all six New England states, and two own and operate multiple oil storage facilities.
Mantrose-Haeuser Co. Inc., an Attleboro Mass. shellac-based coatings facility, will pay $34,000 following a 2006 EPA inspection of its oil tanks and its facility. EPA found the company to be in violation of federal Clean Water Act regulations by releasing an unknown quantity of oil into the nearby Ten Mile River and failing to prepare and implement an adequate Spill Prevention, Control, and Countermeasure (SPCC) plan.
Rice Oil Co. of Greenfield Mass. will pay a $157,500 penalty for alleged SPCC violations at four of its Massachusetts oil storage and distribution facilities and at a Vermont facility, where two oil spills occurred in 2003 and 2007. The company is affiliated with approximately 40 gas stations and convenience stores throughout New England.
Irving Oil Co., with U.S. operations based in Portsmouth N.H., will pay a $55,000 penalty for alleged violations at one of its facilities located in a drinking water protection area in Alton, N.H. In addition to the Alton facility, Irving owns and operates a total of twelve bulk oil storage facilities in New England, three of which are marine terminals with a combined storage capacity of over 100 million gallons.
Federal oil spill prevention regulations are designed to prevent pollution to waterways and to ensure that there will be an effective response to any oil discharges that do occur. Among other requirements, the SPCC plan must contain measures to prevent and control oil spills, including ensuring that there is adequate containment to prevent the spilled oil from reaching a waterway. Since meeting with EPA representatives, all three companies have been working cooperatively to update and fully implement SPCC plans at their New England facilities.
"Oil spills can do significant damage to the environment, so it is important to take steps to prevent them from occurring," said Robert Varney, regional administrator of EPA's New England Office. "Facilities that store and distribute oil have a responsibility to carefully follow established procedures to minimize risks of oil spills."
EPA continues to focus on oil spill prevention in New England. In 2007, EPA conducted inspections at over 100 facilities in New England to determine their compliance with the Oil Pollution Prevention regulations.
Additional Information on Mantrose-Haeuser
EPA had originally responded to a release of sulfuric acid at Mantrose-Haeuser in June 2006, and subsequently conducted an inspection of the facility's oil tanks one month later, during which the inspector observed another spill occurring, this time a release of diesel fuel. The second spill resulted from a leak in a diesel-powered high pressure washing device that had been staged on the facility's parking lot without any secondary containment to catch spills.
The leaked oil flowed into a nearby storm drain and into the Ten Mile River. EPA also noted that there was heavy oil staining and evidence of prior spillage throughout the delivery truck unloading area, directly adjacent to the river.
Upon EPA's observation that an oil sheen had developed on the river, Mantrose-Haeuser initiated steps to protect the storm drain with oil absorbent pads, shut down the leaking equipment and clean up the spilled oil. No environmental damage was evident from this release.
Additional Information on Rice Oil
On July 4, 2007, Rice Oil reported a 400-gallon discharge of oil from its Readsboro, Vt. facility. Emergency personnel from the Vermont Dept. of Environmental Conservation responded and oversaw the investigation and remediation of the discharge. Some of the oil was observed to have escaped the earthen berm surrounding the tanks, however, no impact to the Deerfield River was observed.
This was the second oil discharge from this site within the past five years. Previous to the July 4th spill, Rice Oil had a 300-gallon fuel oil release in October 2003. The oil was discharged from a tank into the Deerfield River, and no product was recovered from the river during subsequent response operations. Following this release, Rice Oil paid a $15,000 penalty to EPA for violations of the federal Clean Water Act. At that time, the company also agreed to upgrade the oil storage and distribution systems at the Readsboro facility, as well as its other Massachusetts bulk plants.
On November 28, 2006, representatives from EPA and the Mass. Dept. of Environmental Protection inspected three of Rice Oil's Massachusetts bulk plants in Greenfield and Shelburne Falls, and reviewed information related to an Orange, Mass. facility and the Vermont facility. The inspection revealed that the company had failed to upgrade its equipment as previously agreed to, including building sufficiently impervious and appropriately sized secondary containment for oil storage tanks, transfer areas, and loading racks.
Additional information on Irving Oil
A joint inspection by representatives from EPA's New England office and the N.H. Dept. of Environmental Services at the Alton bulk plant found that the company had failed to construct sufficiently impervious secondary containment around its aboveground storage tanks. The facility's oil storage included six aboveground bulk petroleum storage tanks ranging in size from 10,000 to 20,000 gallons, with an aggregate storage capacity of more than 100,000 gallons.
The Irving Oil facility also stores gasoline on-site and is located within the well radius of the Town of Alton's drinking water supply. This sensitive location means that spills at the bulk plant could lead to contamination of a public drinking water aquifer. In November 2005 the facility had a spill of over 5,000 gallons of No. 2 home heating oil, which impacted the groundwater beneath the tank farm
Friday, December 12, 2008
Maine Company Fined for Oil Spill Prevention (SPCC) Violations
Stonington, Maine Company Fined for Oil Spill Prevention Violations
U.S. EPA.gov (press release) - Washington,DC,USA
Release date: 10/28/2008
Contact Information: David Deegan, (617) 918-1017
(Boston, Mass. – Oct. 28, 2008) - An oil distribution company will pay $8,000 for failing to adequately prepare and implement Spill Prevention, Control and Countermeasure (SPCC) plans at two of its Stonington, Maine facilities.
An inspection by EPA and the Maine Dept. of Environmental Protection found that R.L. Greenlaw’s oil storage facilities in Stonington had failed to fully implement adequate SPCC plans for two sites – on Sea Breeze Avenue and Indian Point Road. The company failed to maintain sufficiently impervious secondary containment for its oil tanks at both locations and failed to construct adequate containment for the loading and off-loading areas at the Sea Breeze Avenue facility, which are adjacent to the harbor. The two facilities also lacked adequate security measures, which are required by the EPA regulations to prevent unauthorized access to oil storage containers.
Following EPA’s inspection and contacts with the company, R.L. Greenlaw submitted and has begun implementing corrective action plans for both facilities. These plans include liquid-tightness tests at the Sea Breeze Avenue site to identify leaking areas in the containment walls and floor, dike repairs, and construction of poured concrete spill containment areas for the oil transfer areas.
Spill prevention and control laws help ensure that a tank failure or spill does not lead to oil being released into surface waters, such as harbors, rivers or streams. The regulations require that certain spill prevention and response measures be implemented at facilities that store oil above threshold amounts. Both R.L. Greenlaw oil storage facilities are located directly adjacent to Penobscot Bay, thus posing a threat to the Bay if spills were to occur.
EPA continues to focus on oil spill prevention in New England. Since 2007, EPA has conducted inspections at well over 100 facilities in New England to determine their compliance with the Oil Pollution Prevention regulations. This action contributes to EPA's record-shattering enforcement results for the 2008 Fiscal Year. Nationwide this year, EPA has concluded enforcement actions requiring polluters to spend an estimated $11 billion on pollution controls, clean-up and environmental projects, an all time record for EPA. After these activities are completed, EPA expects annual pollution reductions of more than three billion pounds.
U.S. EPA.gov (press release) - Washington,DC,USA
Release date: 10/28/2008
Contact Information: David Deegan, (617) 918-1017
(Boston, Mass. – Oct. 28, 2008) - An oil distribution company will pay $8,000 for failing to adequately prepare and implement Spill Prevention, Control and Countermeasure (SPCC) plans at two of its Stonington, Maine facilities.
An inspection by EPA and the Maine Dept. of Environmental Protection found that R.L. Greenlaw’s oil storage facilities in Stonington had failed to fully implement adequate SPCC plans for two sites – on Sea Breeze Avenue and Indian Point Road. The company failed to maintain sufficiently impervious secondary containment for its oil tanks at both locations and failed to construct adequate containment for the loading and off-loading areas at the Sea Breeze Avenue facility, which are adjacent to the harbor. The two facilities also lacked adequate security measures, which are required by the EPA regulations to prevent unauthorized access to oil storage containers.
Following EPA’s inspection and contacts with the company, R.L. Greenlaw submitted and has begun implementing corrective action plans for both facilities. These plans include liquid-tightness tests at the Sea Breeze Avenue site to identify leaking areas in the containment walls and floor, dike repairs, and construction of poured concrete spill containment areas for the oil transfer areas.
Spill prevention and control laws help ensure that a tank failure or spill does not lead to oil being released into surface waters, such as harbors, rivers or streams. The regulations require that certain spill prevention and response measures be implemented at facilities that store oil above threshold amounts. Both R.L. Greenlaw oil storage facilities are located directly adjacent to Penobscot Bay, thus posing a threat to the Bay if spills were to occur.
EPA continues to focus on oil spill prevention in New England. Since 2007, EPA has conducted inspections at well over 100 facilities in New England to determine their compliance with the Oil Pollution Prevention regulations. This action contributes to EPA's record-shattering enforcement results for the 2008 Fiscal Year. Nationwide this year, EPA has concluded enforcement actions requiring polluters to spend an estimated $11 billion on pollution controls, clean-up and environmental projects, an all time record for EPA. After these activities are completed, EPA expects annual pollution reductions of more than three billion pounds.
Thursday, December 11, 2008
Common SPCC Violations at Colleges and Universities
Common Violations: SPCC
Common SPCC (Spill Prevention Controls & Countermeasures) Violations
This page provides useful information to help colleges and universities comply with some basic environmental regulatory requirements. This page, however, does not list all the applicable regulatory requirements that might apply to your campus. Please be sure to comply with all applicable requirements.
No Plan at all. [40 CFR 112.3 (a) or (b)]
Failure to prepare and implement SPCC plan, specifically failed to include all elements of a complete plan as required by SPCC regulations. [40 CFR 112.3 (c)]
Plan not PE certified. [40 CFR 112.3 (d)]
Plan not reviewed/updated every three years. [40 CFR 112.5 (b)]
Plan does not include all oil on facility, i.e., transformers, hydraulic systems, emergency generators, drum storage, etc. [40 CFR 112.7 (e)(2)]
Plan does not accurately identify, from each oil storage location, the detailed path spilled oil would take to reach a waterway, i.e., a typical campus is so wide, drainage may flow in different directions, to different receptors, especially in urban locations. Drains not traced out. [40 CFR 112.7 (e)(1)]
Designated staff do not conduct regular walk-through inspections of teaching and research locations to be aware of oil use by professors, TAs, graduate students, and other non-maintenance staff. [40 CFR 112.7 (e)(8)]
Small, scattered Above-ground Storage Tanks (ASTs), especially in dormitory locations, are not adequately protected from tampering/vandalism. A transient student population presents unique hazards not encountered with supervised adults in an industrial setting. Students are not employees, are not OSHA trained, and have no stake in paycheck protection through preservation of an employer's image or goodwill. [40 CFR 112.7 (e)(9)]
Common SPCC (Spill Prevention Controls & Countermeasures) Violations
This page provides useful information to help colleges and universities comply with some basic environmental regulatory requirements. This page, however, does not list all the applicable regulatory requirements that might apply to your campus. Please be sure to comply with all applicable requirements.
No Plan at all. [40 CFR 112.3 (a) or (b)]
Failure to prepare and implement SPCC plan, specifically failed to include all elements of a complete plan as required by SPCC regulations. [40 CFR 112.3 (c)]
Plan not PE certified. [40 CFR 112.3 (d)]
Plan not reviewed/updated every three years. [40 CFR 112.5 (b)]
Plan does not include all oil on facility, i.e., transformers, hydraulic systems, emergency generators, drum storage, etc. [40 CFR 112.7 (e)(2)]
Plan does not accurately identify, from each oil storage location, the detailed path spilled oil would take to reach a waterway, i.e., a typical campus is so wide, drainage may flow in different directions, to different receptors, especially in urban locations. Drains not traced out. [40 CFR 112.7 (e)(1)]
Designated staff do not conduct regular walk-through inspections of teaching and research locations to be aware of oil use by professors, TAs, graduate students, and other non-maintenance staff. [40 CFR 112.7 (e)(8)]
Small, scattered Above-ground Storage Tanks (ASTs), especially in dormitory locations, are not adequately protected from tampering/vandalism. A transient student population presents unique hazards not encountered with supervised adults in an industrial setting. Students are not employees, are not OSHA trained, and have no stake in paycheck protection through preservation of an employer's image or goodwill. [40 CFR 112.7 (e)(9)]
Wednesday, November 5, 2008
Shell Refinery To Pay $300000 Penalty For Spill
Shell pays fine for 2006 spill
San Jose Mercury News - CA, USA
By Mike Taugher
Contra Costa Times
Article Launched: 09/25/2008 06:41:45 PM PDT
Shell Oil Co. has agreed to pay more than $300,000 in fees and penalties for spilling about 420 gallons of oil into Carquinez Strait at its Martinez refinery in January 2006.
No injuries were reported at the time and no dead wildlife were found, though the spill did foul the marina and some boats.
"It's something we wish didn't happen and we have taken all steps to make sure it doesn't happen again," said Shell spokesman Steve Lesher, who also apologized to boat owners and others affected by the spill.
The accident occurred as refinery personnel were taking partially refined oil from a tanker into the refinery.
The slow leak led to oil contaminating the nearby water because a pump that was supposed to keep the containment system clear failed and an alarm that was supposed to alert workers did not work either, Lesher said.
The settlement, announced by the Contra Costa County district attorney's office, was approved Wednesday.
Deputy district attorney Lon Wixson said Shell made several improvements to help prevent similar spills.
"They were concerned when it happened and did some things on their own," Wixson said.
"They have a better system now."
The settlement calls for Shell to pay $250,000 in civil penalties, $50,000 to the city of Martinez for improvements to the city's marina or waterfront, and $10,000 to pay for the response by state oil spill cleanup crews.
Mike Taugher covers
natural resources. Reach him at 925-943-8257 or mtaugher@bayareanewsgroup.com.
San Jose Mercury News - CA, USA
By Mike Taugher
Contra Costa Times
Article Launched: 09/25/2008 06:41:45 PM PDT
Shell Oil Co. has agreed to pay more than $300,000 in fees and penalties for spilling about 420 gallons of oil into Carquinez Strait at its Martinez refinery in January 2006.
No injuries were reported at the time and no dead wildlife were found, though the spill did foul the marina and some boats.
"It's something we wish didn't happen and we have taken all steps to make sure it doesn't happen again," said Shell spokesman Steve Lesher, who also apologized to boat owners and others affected by the spill.
The accident occurred as refinery personnel were taking partially refined oil from a tanker into the refinery.
The slow leak led to oil contaminating the nearby water because a pump that was supposed to keep the containment system clear failed and an alarm that was supposed to alert workers did not work either, Lesher said.
The settlement, announced by the Contra Costa County district attorney's office, was approved Wednesday.
Deputy district attorney Lon Wixson said Shell made several improvements to help prevent similar spills.
"They were concerned when it happened and did some things on their own," Wixson said.
"They have a better system now."
The settlement calls for Shell to pay $250,000 in civil penalties, $50,000 to the city of Martinez for improvements to the city's marina or waterfront, and $10,000 to pay for the response by state oil spill cleanup crews.
Mike Taugher covers
natural resources. Reach him at 925-943-8257 or mtaugher@bayareanewsgroup.com.
Friday, September 26, 2008
SPCC Regulations Enforced on the Ice in Antarctica
July 25, 2008
Basic Concepts continues to have environmental spill containment products deployed on all seven continents with the most recent Sentry Quickberm installation at a scientific research site in Antarctica.
The spill berm pictured above was constructed of heavy-duty 32 oz. polyurethane with an 18” tall wall that is constructed to withstand the harsh environment and sub-freezing temperatures of the polar region. The Quickberm was designed to provide secondary spill containment for a 10,000 gallon fuel bladder. The site has two 10,000 gallon hydrocarbon bladders requiring two spill berms.
Mr. Taube, the original project manager for the site, commented upon deploying the two spill berms: “… the berms were a breeze to set up and looks like they are going to work out well.” After well over two years in service the spill berms have performed so well that additional spill berms have been purchased including the latest ordered July 24, 2008.
Lee Hill the territory sales manager for Basic Concepts stated:
“The berms that Basic Concepts has supplied for secondary containment in Antarctica remain a flagship example of our commitment to providing the highest quality, most durable secondary containment berms on the market. This project is a source of pride for our company and we are thankful to have the opportunity to demonstrate just how durable our products are.”
Basic Concepts’ Environmental Spill Containment Products have been proven in the harshest environments. The ecosystem of the polar region is vunerable to oil spills, so when the need arose Basic Concepts is who was entrusted. Basic Concepts’ engineered spill containment berms and related products can be customized to solve almost any customer requirement. Remember that Sentry is always on guard against environmental oil spills.
About Basic Concepts
Basic Concepts is a World War II veteran owned small business that manufactures environmental spill containment products. Founded in 1988, the company is celebrating its 20th year of serving a global market one customer at a time. Want to know more about Basic Concepts and its full line of secondary containment berms and oil spill products? Please contact Basic Concepts, Inc, 1310 Harris Bridge Rd, Anderson, SC 29621, telephone 1-800-285-4203 or visit the company website at www.basicconcepts.com.
Electric Utility Substation SPCC Compliance Products
Oil Containment Systems for Electric Utility Substations
Jun 29, 2008 5:58 PM
The Environmental Protection Agency’s deadline for compliance with Spill Prevention Control and Countermeasure Plans for utilities is July 2009. Containment is required by law for certain above-ground oil tanks and transformers located near navigable waters, and for many utilities addressing this issue is a monumental task.
Tony Picagli from United Illuminating and William Gannon from Solidification Products International teamed up to present a session on oil containment systems for substations, sharing their firsthand experiences and several options for SPCC.
Picagli, a principal electric system maintenance engineer at UI in New Haven, Connecticut, will present a few installations his company has made and the rationale behind each installation.
Gannon, president of SPI in Northford, Connecticut, will present several different designs of how SPI has helped companies with SPCC compliance “Today, every type of our product has been used in real-world spills with transformer oil, cable oil, # 6 oil, eiesel and most impressive, a fiery explosion,” Gannon said. “In all cases, no oil has ever been released.”
SPI has been installing passive oil containment systems for more than 10 years. Many companies have begun to address or are about start to comply with the SPCC regulations and need help in finding the best-suited system for their needs.
All SPI systems allow rain water to drain passively while filtering oil sheen from small drips and leaks and only seal in the event of an oil overload. SPI provides Petro-Barrier systems that drain directly into the ground in areas with good water percolation or can be drained off to a drainage area for use in poor draining soil. Petro-Pipes are used in areas with high water tables and are mounted directly into the containment wall allowing all the water on the containment floor to drain through the Petro-Pipe only sealing in the event of an oil spill.
“There are many different ways to address oil containment, and I will give options to companies that have built containment but have not addressed rainwater build up,” Gannon said.
Picagli’s work at UI concentrates on circuit breakers of all classes, gas-insulated substations and standby battery systems. Picagli is active on several Doble Engineering client committees and has been an IEEE member for over 30 years. He earned both his BSEE and MBA at The University of New Haven and is a registered professional engineer in Connecticut.
Gannon has been in the environmental industry since 1984 in different capacities, from pioneering polymer absorbent technology in 1986 to having developed SPI into a state-of-the-art oil spill containment company. He has three U.S. patents with other U.S. and foreign patents pending.
Jun 29, 2008 5:58 PM
The Environmental Protection Agency’s deadline for compliance with Spill Prevention Control and Countermeasure Plans for utilities is July 2009. Containment is required by law for certain above-ground oil tanks and transformers located near navigable waters, and for many utilities addressing this issue is a monumental task.
Tony Picagli from United Illuminating and William Gannon from Solidification Products International teamed up to present a session on oil containment systems for substations, sharing their firsthand experiences and several options for SPCC.
Picagli, a principal electric system maintenance engineer at UI in New Haven, Connecticut, will present a few installations his company has made and the rationale behind each installation.
Gannon, president of SPI in Northford, Connecticut, will present several different designs of how SPI has helped companies with SPCC compliance “Today, every type of our product has been used in real-world spills with transformer oil, cable oil, # 6 oil, eiesel and most impressive, a fiery explosion,” Gannon said. “In all cases, no oil has ever been released.”
SPI has been installing passive oil containment systems for more than 10 years. Many companies have begun to address or are about start to comply with the SPCC regulations and need help in finding the best-suited system for their needs.
All SPI systems allow rain water to drain passively while filtering oil sheen from small drips and leaks and only seal in the event of an oil overload. SPI provides Petro-Barrier systems that drain directly into the ground in areas with good water percolation or can be drained off to a drainage area for use in poor draining soil. Petro-Pipes are used in areas with high water tables and are mounted directly into the containment wall allowing all the water on the containment floor to drain through the Petro-Pipe only sealing in the event of an oil spill.
“There are many different ways to address oil containment, and I will give options to companies that have built containment but have not addressed rainwater build up,” Gannon said.
Picagli’s work at UI concentrates on circuit breakers of all classes, gas-insulated substations and standby battery systems. Picagli is active on several Doble Engineering client committees and has been an IEEE member for over 30 years. He earned both his BSEE and MBA at The University of New Haven and is a registered professional engineer in Connecticut.
Gannon has been in the environmental industry since 1984 in different capacities, from pioneering polymer absorbent technology in 1986 to having developed SPI into a state-of-the-art oil spill containment company. He has three U.S. patents with other U.S. and foreign patents pending.
Valero Refining Pay 2.0 Million in Clean Water Act Violation Fines
Valero agrees to pay nearly $2 million to settle environmental complaints
Wednesday, June 11, 2008
San Antonio Business Journal
Valero Refining Texas LP has reached a settlement with the Justice Department and Environmental Protection Agency to end allegations that the oil refiner violated the Clear Water Act two years ago.
The government alleged Valero spilled 3,400 barrels of oil into the Corpus Christi Ship Channel on June 1, 2006. The ship channel flows from Tule Lake into Corpus Christi Bay and ultimately the Gulf of Mexico. The channel is used heavily by barges and other commercial ships.
The EPA alleged that the oil spilled from a containment berm located on the edge of the ship channel at Valero's Corpus Christi Refinery West Plant. Valero has since removed the berm and the above-ground storage tank from the edge of the ship channel in order to prevent future spills.
Attorneys for Valero did not admit any wrongdoing in agreeing to the settlement, according to the consent decree.
Under the consent decree filed Tuesday in federal court in Corpus Christi, Valero has agreed to pay $1.65 million in civil penalties and invest in an additional environmental project that will cost the company $300,000. The penalty funds will be deposited in the government's Oil Spill Liability Trust Fund.
Valero also will design and construct a boat ramp that will aid emergency-response efforts in the vicinity of where the oil spill took place.
Valero Refining Texas is a wholly owned subsidiary of San Antonio-based Valero Energy Corp. (NYSE: VLO).
The consent decree filed with the court is subject to a 30-day public comment period and final court review. The Justice Department has posted a copy of the decree on its Web site (www.usdoj.gov/enrd/Consent_Decrees.html).
Wednesday, June 11, 2008
San Antonio Business Journal
Valero Refining Texas LP has reached a settlement with the Justice Department and Environmental Protection Agency to end allegations that the oil refiner violated the Clear Water Act two years ago.
The government alleged Valero spilled 3,400 barrels of oil into the Corpus Christi Ship Channel on June 1, 2006. The ship channel flows from Tule Lake into Corpus Christi Bay and ultimately the Gulf of Mexico. The channel is used heavily by barges and other commercial ships.
The EPA alleged that the oil spilled from a containment berm located on the edge of the ship channel at Valero's Corpus Christi Refinery West Plant. Valero has since removed the berm and the above-ground storage tank from the edge of the ship channel in order to prevent future spills.
Attorneys for Valero did not admit any wrongdoing in agreeing to the settlement, according to the consent decree.
Under the consent decree filed Tuesday in federal court in Corpus Christi, Valero has agreed to pay $1.65 million in civil penalties and invest in an additional environmental project that will cost the company $300,000. The penalty funds will be deposited in the government's Oil Spill Liability Trust Fund.
Valero also will design and construct a boat ramp that will aid emergency-response efforts in the vicinity of where the oil spill took place.
Valero Refining Texas is a wholly owned subsidiary of San Antonio-based Valero Energy Corp. (NYSE: VLO).
The consent decree filed with the court is subject to a 30-day public comment period and final court review. The Justice Department has posted a copy of the decree on its Web site (www.usdoj.gov/enrd/Consent_Decrees.html).
EPA Fines Warner Petroleum for SPCC Violations
U.S. EPA fines Chico, Calif. company $6,000 for oil spill prevention violations
Release date: 03/20/2008
Contact Information: Wendy Chavez, 415/947-4248, chavez.wendy@epa.gov
SAN FRANCISCO – The U.S. Environmental Protection Agency recently fined Warner Petroleum, Inc., $6,000 for oil spill prevention violations at its facility at 310 Nord Ave. in Chico, Calif.
During a routine inspection in April 2007, the EPA found that Warner Petroleum lacked secondary containment around its oil storage area needed to prevent oil from being discharged from the facility in the event of a tank or piping failure. Uncontained spills from the Warner Petroleum facility could potentially contaminate Big Chico Creek, which leads to the Sacramento River and eventually into the Pacific Ocean.
“It is critical that facilities such as Warner take the measures needed to prevent the release of oil into the environment,” said Keith Takata, the EPA’s Superfund Division director for the EPA’s Pacific Southwest region. “Discharges of oil into waterways can be prevented with proper planning and spill containment.”
The Warner Petroleum facility had incomplete secondary containment for four fixed above-ground storage containers, two 5,000 gallon portable storage containers, a 550-gallon waste oil tank, and a warehouse where approximately 80 55-gallon drums and 16 portable storage totes are located.
Oil spills and other contamination from onshore sources can pollute and harm ecosystems. The EPA requires oil storage facilities to have spill prevention plans and measures in place to prevent oil from being discharged into waterways. Warner Petroleum agreed to pay the penalty and has installed the necessary secondary containment within its facility.
For more information please visit http://www.epa.gov/oilspill
Release date: 03/20/2008
Contact Information: Wendy Chavez, 415/947-4248, chavez.wendy@epa.gov
SAN FRANCISCO – The U.S. Environmental Protection Agency recently fined Warner Petroleum, Inc., $6,000 for oil spill prevention violations at its facility at 310 Nord Ave. in Chico, Calif.
During a routine inspection in April 2007, the EPA found that Warner Petroleum lacked secondary containment around its oil storage area needed to prevent oil from being discharged from the facility in the event of a tank or piping failure. Uncontained spills from the Warner Petroleum facility could potentially contaminate Big Chico Creek, which leads to the Sacramento River and eventually into the Pacific Ocean.
“It is critical that facilities such as Warner take the measures needed to prevent the release of oil into the environment,” said Keith Takata, the EPA’s Superfund Division director for the EPA’s Pacific Southwest region. “Discharges of oil into waterways can be prevented with proper planning and spill containment.”
The Warner Petroleum facility had incomplete secondary containment for four fixed above-ground storage containers, two 5,000 gallon portable storage containers, a 550-gallon waste oil tank, and a warehouse where approximately 80 55-gallon drums and 16 portable storage totes are located.
Oil spills and other contamination from onshore sources can pollute and harm ecosystems. The EPA requires oil storage facilities to have spill prevention plans and measures in place to prevent oil from being discharged into waterways. Warner Petroleum agreed to pay the penalty and has installed the necessary secondary containment within its facility.
For more information please visit http://www.epa.gov/oilspill
Shipley Grouped Fined for Poor SPCC Adherence
RedOrbit - Dallas,TX,USA
Posted on: Friday, 21 March 2008, 06:00 CDT
By Brent Burkey, York Daily Record, Pa.
Mar. 21–State officials and the Shipley Group have reached an agreement on fines and monitoring after a 1,500-gallon heating oil spill in York County and violations at six other facilities, the Pennsylvania Department of Environmental Protection said.
The spill, according to a DEP news release, happened Jan. 18 at McCullough Oil Service in Springfield Township.
Shipley officials are looking at the site for “any environmental problems,” the statement said. About 1,500 gallons of fuel spilled, DEP said.
Sandy Roderick, spokeswoman for DEP, said a required containment basin was on site, but it was not working well enough to contain the spill. The state requires a basin be present at a fuel facility and be in good working order.
Between 900 and 1,000 gallons of fuel were recovered following the spill; the rest remains on the property, she said.
Roderick said most of the other violations were for Shipley not inspecting tanks and pipes or not inspecting tanks and pipes often enough.
According to the terms of the deal, Shipley will pay a $76,000 civil penalty and agree to strict monitoring of its fuel facilities.
In DEP’s release, the head of the agency’s southcentral office said she hopes the penalties will help bring Shipley in line with regulations.
Shipley operates 41 underground fuel sites and bulk fuel facilities in southcentral Pennsylvania. Violations occurred between October 2006 and January.
Roderick said DEP began investigating when Shipley’s
required paperwork did not show up in state records.
The state requires companies to get equipment inspected and to send results to DEP every year to every three years, depending on the inspection, Roderick said.
A representative from the Shipley Group did not return a phone call for comment Thursday afternoon. bburkey@ydr.com; 771-2035
Posted on: Friday, 21 March 2008, 06:00 CDT
By Brent Burkey, York Daily Record, Pa.
Mar. 21–State officials and the Shipley Group have reached an agreement on fines and monitoring after a 1,500-gallon heating oil spill in York County and violations at six other facilities, the Pennsylvania Department of Environmental Protection said.
The spill, according to a DEP news release, happened Jan. 18 at McCullough Oil Service in Springfield Township.
Shipley officials are looking at the site for “any environmental problems,” the statement said. About 1,500 gallons of fuel spilled, DEP said.
Sandy Roderick, spokeswoman for DEP, said a required containment basin was on site, but it was not working well enough to contain the spill. The state requires a basin be present at a fuel facility and be in good working order.
Between 900 and 1,000 gallons of fuel were recovered following the spill; the rest remains on the property, she said.
Roderick said most of the other violations were for Shipley not inspecting tanks and pipes or not inspecting tanks and pipes often enough.
According to the terms of the deal, Shipley will pay a $76,000 civil penalty and agree to strict monitoring of its fuel facilities.
In DEP’s release, the head of the agency’s southcentral office said she hopes the penalties will help bring Shipley in line with regulations.
Shipley operates 41 underground fuel sites and bulk fuel facilities in southcentral Pennsylvania. Violations occurred between October 2006 and January.
Roderick said DEP began investigating when Shipley’s
required paperwork did not show up in state records.
The state requires companies to get equipment inspected and to send results to DEP every year to every three years, depending on the inspection, Roderick said.
A representative from the Shipley Group did not return a phone call for comment Thursday afternoon. bburkey@ydr.com; 771-2035
SPCC Success Story at Electric Substation
March 25, 2008
Petro-Pipe™, Petro-Plug® and Petro-Barrier™ have been installed in the United States, Canada and other foreign countries in Oil containment systems around transformers in substations, oil tanks, Oil valves, storm drains and many other applications over the last ten years.Solidification Products International’s patented products and systems allow for rain water to discharge passively continuously while only reacting with hydrocarbons in a spill scenario. All SPI products have been used in actual customer spills with no oil being released from any of the containment areas or drains. Spills to date have included over 200 gallons of Hot 150° #6 oil, 1000’s of gallons of cable oil, numerous transformer oil spills, Diesel fuel, and hydraulic oil just to name a few. In all spills the product immediately sealed when contacted with the spilled hydrocarbon, totally containing any liquids from discharging.
San Diego Gas & Electric a customer of SPI Petro-Pipe™ since 2003 has installed them in hundreds of applications, providing water discharge during the rainy season and oil containment if needed from small spills to major failures. No fire had ever accompanied a spill with the use of the products until a transformer in Escondido, California exploded and all of the oil was discharged into the surrounding containment area. One Petro-Pipe™ was installed in the concrete containment area to provide drainage and oil containment. When the explosion took place the majority of the oil spilled into the containment area while also being on fire. The fire raged for over three hours and exposed the Petro-Pipe™ to extreme temperatures even laboratory testing could not have reproduced. The fire department responded, applying both water and foam. The fire extinguished itself after consuming the remaining oil.
Bill Gannon of SPI was contacted by SDG&E and asked to come to the site to evaluate how the Petro-Pipe™ performed under these conditions. The Petro-Pipe™ used in this application is two parts, a flanged 7” Diameter housing made of PVC and the actual 6” flanged Petro-Pipe™ also made of PVC that slides into the housing and is attached with 5 stainless steel screws. The housing is cast into the 8” thick concrete wall and then the Petro-Pipe™ is inserted into the housing.Upon viewing the pictures of the melted flange inside the containment area it was difficult to determine if the Petro-Pipe™ withstood the severe conditions it was exposed to.
While on site Gannon removed the Petro-Pipe™ by driving the housing through the concrete containment wall with a sledge hammer. The Petro-Pipe™ was removed and the melted flange examined. It appeared to be fused together where the two flanges were joined with the screws. With SDG&E personnel present Gannon started to disassemble the melted Petro-Pipe™. Only the flange area had melted. The inside of the Petro-Pipe™ was intact. The next stage is the media that filters the water and stops the oil. The media was absorbed and solidified and it was removed from the inside of the Petro-Pipe™. The oil had penetrated about 3-4 inches into the media and formed a solid jell material that binds to the Petro-Pipe™ wall and prevents any more oil or water from escaping. Underneath the solidified layer was discolored unused media for the next 2 – 3 inches. The inner walls of the Petro-Pipe™ were oil free and no oil had escaped down past the solidified portion of the media.
SDG&E’s other concern was if any oil escaped the area between the housing and the Petro-Pipe™ through the flanges. This area was also checked for oil with none present. The concrete containment wall had insulated the Petro-Pipe™. Even excessive temperature of a prolonged fire did not compromise the integrity of the Petro-Pipe™. The Petro-Pipe performed as it was designed, not allowing any oil to escape the containment area despite extreme conditions.
For More Information Contact
William J. Gannon
Ph:203-484-9494
Fa: 203-484-9492
BGannon@OilBarriers.com
More Mobile Refueler SPCC Confusion
Important Information for Aerial Firefighters
Posted on Friday, March 28, 2008
A number of HAI members under contract to the U.S. Forest Service (USFS) and the Department of the Interior (DOI) for aerial firefighting have expressed concern over new contractor environmental responsibilities and compliance with 40 CFR Part 112, oil pollution prevention, spill prevention, control and countermeasure plan requirements (SPCC).
New contract language requires an SPCC plan for each mobile fueler used on USFS and DOI contracts, regardless of bulk storage container (tank) size. HAI staff has been in contact with USFS and DOI officials at the National Interagency Fire Center (NIFC) to discuss this matter. An Example SPCC Plan provided to NIFC personnel by the Idaho EPA inspector should be of assistance to HAI members who must comply with this requirement. All operators are strongly encouraged to familiarize themselves with the example plan.
40 CFR Part 112 addresses fuel truck operators while the vehicle is stationary, and NIFC officials have acknowledged the need for operators to carry secondary containment when near a waterway if the fuel has potential to access the waterway. According to information provided to HAI, it is the vendor’s responsibility to judge whether or not the fuel could reach the waterway. NIFC has indicated to HAI that every effort will be made in the field to reduce that possibility. However, when this is not possible, secondary containment may be necessary. If operators are performing aerial firefighting under government contract, a helicopter manager will be ordered and it is anticipated that local officials will provide assistance with the deployment of the containment system.
Posted on Friday, March 28, 2008
A number of HAI members under contract to the U.S. Forest Service (USFS) and the Department of the Interior (DOI) for aerial firefighting have expressed concern over new contractor environmental responsibilities and compliance with 40 CFR Part 112, oil pollution prevention, spill prevention, control and countermeasure plan requirements (SPCC).
New contract language requires an SPCC plan for each mobile fueler used on USFS and DOI contracts, regardless of bulk storage container (tank) size. HAI staff has been in contact with USFS and DOI officials at the National Interagency Fire Center (NIFC) to discuss this matter. An Example SPCC Plan provided to NIFC personnel by the Idaho EPA inspector should be of assistance to HAI members who must comply with this requirement. All operators are strongly encouraged to familiarize themselves with the example plan.
40 CFR Part 112 addresses fuel truck operators while the vehicle is stationary, and NIFC officials have acknowledged the need for operators to carry secondary containment when near a waterway if the fuel has potential to access the waterway. According to information provided to HAI, it is the vendor’s responsibility to judge whether or not the fuel could reach the waterway. NIFC has indicated to HAI that every effort will be made in the field to reduce that possibility. However, when this is not possible, secondary containment may be necessary. If operators are performing aerial firefighting under government contract, a helicopter manager will be ordered and it is anticipated that local officials will provide assistance with the deployment of the containment system.
Questions about SPCC and Mobile Refuelers
Questions about SPCC and Mobile Refuelers
Sized Secondary Containment for Mobile Refuelers
Article by: Lee Hill
March 20, 2008 Industry continues to ask what the SPCC requirements are for mobile refuelers. Many believe that amendments to 40 CFR last year completely exempted mobile refuelers from all SPCC requirements. This is not true.
It is true that the sized secondary requirements were removed for mobile refuelers. However, the general regulations in 112.7(c) of 40 CFR still apply to mobile refuelers at SPCC regulated facilities.
A section taken directly from the EPA’s website should help to clarify. I have reposted it here:
“General secondary containment should be designed to address the most likely discharge from the container and from oil transfers into or from the mobile refueler. The general secondary containment requirements:
Do not prescribe a size for a secondary containment structure but require that the containment system prevent the spilled oil from escaping the system prior to clean up occurring
Require appropriate containment and/or diversionary structures or equipment to prevent a discharge to navigable waters or adjoining shorelines
Allow for the use of certain types of active containment measures that prevent a discharge to navigable waters or adjoining shorelines”
As you can see, the property owner is still responsible for containing the spill. Many see this regulation as nebulous at best and open to wide interpretations. Conservative facilities are finding that it is easier to proceed forward with sized containment because the EPA also states that refuelers that are unmanned for periods of time would be considered an above ground storage tank (AST). This statement brings the sized containment regulations back into play.
Why were these amendments proposed? The answer is simple, the Airport Industry lobbied Congress to get an exemption. Pressure was applied to the EPA and the sized restriction requiring spill berms was removed. What the industry does not fully realize is that in the event of a spill, the EPA has the authority via the general requirements to fine, hence the nebulous nature of the regulations.
The question asked is do you roll the dice and hope against the inevitable or do you consider taking a best management practices approach and protect your site against a catastrophic spill event. The answer is that it comes down to economics. An ounce of prevention is worth a pound of cure. It simply is not worth the negative impact to not prepare in advance.
In addition to this argument, it is often the case that the mobile refueler is engaged with loading racks. During this transfer process the sized containment regulations are enforced. Most sites deem it feasible to design their facility for sized containment at the loading racks and leave their mobile refuelers parked in that secondary containment area when not in use. When in use, spill kits are kept handily on board the vehicle as part of an active containment requirement.For more details on the rulings concerning mobile refuelers visit: http://www.epa.gov/OEM/content/spcc/factsheet_mobile_refuelers_dec06.htm
For more information on secondary containment contact Basic Concepts, Inc, 1310 Harris Bridge Rd, Anderson, SC 29621, telephone 1-800-285-4203 or visit the company website at www.basicconcepts.com
SPCC Violation Fine for Martha's Vineyard Oil Company
Martha’s Vineyard Oil Company Pays Penalty to Settle Clean Water …
Release date: 02/20/2008 U.S. EPA.gov (press release) - Washington,DC,USA
Contact Information: David Deegan, (617) 918-1017
(Boston, Mass. – Feb. 20, 2008) - A Vineyard Haven, Mass. petroleum storage and distribution company has agreed to pay a $78,000 fine for violating the federal Clean Water Act and Oil Pollution Prevention regulations.
RM Packer Inc. failed to adequately implement a “Spill Prevention, Control, and Countermeasure” (SPCC) plan and did not sufficiently maintain proper containment for its tanks and loading rack. Upgrades required by the facility’s SPCC plan had not been implemented, including installing high level alarms and level monitors on tanks, installing secondary tank bottoms with corrosion protection, and testing tanks for soundness. Because the facility is located directly across from Vineyard Sound Harbor, these violations presented a significant threat of an oil spill into navigable water.
Following the original EPA inspection, the company submitted a schedule for coming into compliance, including upgrading its tanks and containment areas. When RM Packer fell behind schedule, EPA sent a letter to the company notifying the company that its oil tanks on Beach Road were still out of compliance with the SPCC regulations. Due to the company’s continued noncompliance, EPA subsequently issued an Administrative Order to RM Packer, requiring the company to comply with the storage tank requirements of the SPCC rule. Following continued delays to comply with the SPCC requirements, EPA initiated the current penalty action against the company.
Spill prevention and control laws help ensure that a tank failure or spill does not lead to oil being released into drinking water wells, rivers or streams.
“Oil spills can do significant damage to the environment,” said Robert W. Varney, regional administrator of EPA’s New England office. “EPA will continue to ensure that facilities handling oils follow established procedures to minimize risks of oil spills.”
RM Packer has agreed to upgrade its facility and comply with the SPCC regulations. The company has poured concrete in the previously unpaved tank containment area, upgraded containment for other, smaller tanks, and installed high level alarms and corrosion protection for the active tanks. In addition, RM Packer is working with an engineer to update its SPCC plan.
EPA continues to focus on oil spill prevention in New England. In 2007, EPA conducted inspections at over 100 facilities in New England to determine their compliance with the Oil Pollution Prevention regulations.
More information:
- Federal oil spill prevention requirements (epa.gov/emergencies/content/spcc)
- Oil Spill prevention in New England (epa.gov/region1/superfund/er/oilstor.htm)
Release date: 02/20/2008 U.S. EPA.gov (press release) - Washington,DC,USA
Contact Information: David Deegan, (617) 918-1017
(Boston, Mass. – Feb. 20, 2008) - A Vineyard Haven, Mass. petroleum storage and distribution company has agreed to pay a $78,000 fine for violating the federal Clean Water Act and Oil Pollution Prevention regulations.
RM Packer Inc. failed to adequately implement a “Spill Prevention, Control, and Countermeasure” (SPCC) plan and did not sufficiently maintain proper containment for its tanks and loading rack. Upgrades required by the facility’s SPCC plan had not been implemented, including installing high level alarms and level monitors on tanks, installing secondary tank bottoms with corrosion protection, and testing tanks for soundness. Because the facility is located directly across from Vineyard Sound Harbor, these violations presented a significant threat of an oil spill into navigable water.
Following the original EPA inspection, the company submitted a schedule for coming into compliance, including upgrading its tanks and containment areas. When RM Packer fell behind schedule, EPA sent a letter to the company notifying the company that its oil tanks on Beach Road were still out of compliance with the SPCC regulations. Due to the company’s continued noncompliance, EPA subsequently issued an Administrative Order to RM Packer, requiring the company to comply with the storage tank requirements of the SPCC rule. Following continued delays to comply with the SPCC requirements, EPA initiated the current penalty action against the company.
Spill prevention and control laws help ensure that a tank failure or spill does not lead to oil being released into drinking water wells, rivers or streams.
“Oil spills can do significant damage to the environment,” said Robert W. Varney, regional administrator of EPA’s New England office. “EPA will continue to ensure that facilities handling oils follow established procedures to minimize risks of oil spills.”
RM Packer has agreed to upgrade its facility and comply with the SPCC regulations. The company has poured concrete in the previously unpaved tank containment area, upgraded containment for other, smaller tanks, and installed high level alarms and corrosion protection for the active tanks. In addition, RM Packer is working with an engineer to update its SPCC plan.
EPA continues to focus on oil spill prevention in New England. In 2007, EPA conducted inspections at over 100 facilities in New England to determine their compliance with the Oil Pollution Prevention regulations.
More information:
- Federal oil spill prevention requirements (epa.gov/emergencies/content/spcc)
- Oil Spill prevention in New England (epa.gov/region1/superfund/er/oilstor.htm)
SPCC Violation Results in Fine - Boston, MA
Oil Spill Preparedness Project Eases Clean Water Act Penalty Paid …
U.S. EPA.gov (press release) - Washington,DC,USA
Release date: 02/06/2008
Contact Information: David Deegan, (617) 918-1017
(Boston, Mass. – Feb. 6, 2008) - Fred’s Plumbing & Heating, Inc., a petroleum storage and distribution facility in Derby, Vt., will pay $21,250 in penalties and provide $14,000 for local oil spill equipment and response training following Clean Water Act Violations discovered by both the U.S. Environmental Protection Agency (EPA) and the Vermont Dept. of Environmental Conservation (VTDEC).
On February 27, 2007, approximately 5,000 gallons of gasoline was released from an above ground 25,000 gallon double-compartment storage tank at the company’s plant located on Route 5 in Derby. VTDEC emergency responders observed that gasoline had flowed beyond the containment surrounding the tank and had contaminated soil and ground water on the property. Since then, VTDEC has continued to oversee cleanup activities, including monitoring a nearby stream and a neighboring drinking water well.
EPA determined that the company violated the Clean Water Act by failing to have an adequate “Spill Prevention, Control, and Countermeasure” (SPCC) plan in place at its facility, as required by Oil Pollution Prevention requirements. Facilities storing oil above specific amounts are required to take certain measures to ensure that a tank failure or accidental spill does not lead to oil contamination of surface waters, such as rivers or streams, which could harm human and ecological health.
Both EPA and VTDEC found upon inspection of the Derby facility that in addition to failing to fully implement an adequate SPCC plan, the company failed to construct sufficiently impervious secondary containment for its oil storage containers, loading rack, and other fuel transfer areas.
“Oil spills can severely impact the environment, including surface waters and drinking water supplies,” said Robert W. Varney, Regional Administrator of EPA’s New England office. “EPA will continue to ensure that facilities handling oils follow established procedures to minimize risks of oil spills.”
The penalties to resolve this Clean Water violation were lessened by the company’s willingness to fund a “Supplemental Environmental Project,” under which $14,000 will go to the Local Emergency Planning Committee (“LEPC”) District #10, to boost local oil spill response capabilities. These funds will help the LEPC provide up-to-date oil spill training techniques and equipment for local responders. FP&H has been responsive to EPA’s inspection and has agreed to comply with the SPCC regulations and update its SPCC plan.
For more information:
New England oil spill prevention (epa.gov/region1/superfund/oilstor.htm)
National oil spill prevention www.epa.gov/emergencies/content/spcc/index.htm
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Posted in Links to News on Oil Spills | Tags: Secondary Containment, SPCC
U.S. EPA.gov (press release) - Washington,DC,USA
Release date: 02/06/2008
Contact Information: David Deegan, (617) 918-1017
(Boston, Mass. – Feb. 6, 2008) - Fred’s Plumbing & Heating, Inc., a petroleum storage and distribution facility in Derby, Vt., will pay $21,250 in penalties and provide $14,000 for local oil spill equipment and response training following Clean Water Act Violations discovered by both the U.S. Environmental Protection Agency (EPA) and the Vermont Dept. of Environmental Conservation (VTDEC).
On February 27, 2007, approximately 5,000 gallons of gasoline was released from an above ground 25,000 gallon double-compartment storage tank at the company’s plant located on Route 5 in Derby. VTDEC emergency responders observed that gasoline had flowed beyond the containment surrounding the tank and had contaminated soil and ground water on the property. Since then, VTDEC has continued to oversee cleanup activities, including monitoring a nearby stream and a neighboring drinking water well.
EPA determined that the company violated the Clean Water Act by failing to have an adequate “Spill Prevention, Control, and Countermeasure” (SPCC) plan in place at its facility, as required by Oil Pollution Prevention requirements. Facilities storing oil above specific amounts are required to take certain measures to ensure that a tank failure or accidental spill does not lead to oil contamination of surface waters, such as rivers or streams, which could harm human and ecological health.
Both EPA and VTDEC found upon inspection of the Derby facility that in addition to failing to fully implement an adequate SPCC plan, the company failed to construct sufficiently impervious secondary containment for its oil storage containers, loading rack, and other fuel transfer areas.
“Oil spills can severely impact the environment, including surface waters and drinking water supplies,” said Robert W. Varney, Regional Administrator of EPA’s New England office. “EPA will continue to ensure that facilities handling oils follow established procedures to minimize risks of oil spills.”
The penalties to resolve this Clean Water violation were lessened by the company’s willingness to fund a “Supplemental Environmental Project,” under which $14,000 will go to the Local Emergency Planning Committee (“LEPC”) District #10, to boost local oil spill response capabilities. These funds will help the LEPC provide up-to-date oil spill training techniques and equipment for local responders. FP&H has been responsive to EPA’s inspection and has agreed to comply with the SPCC regulations and update its SPCC plan.
For more information:
New England oil spill prevention (epa.gov/region1/superfund/oilstor.htm)
National oil spill prevention www.epa.gov/emergencies/content/spcc/index.htm
No Comments yet...
Posted in Links to News on Oil Spills | Tags: Secondary Containment, SPCC
EPA SPCC Oil Spill Reporting Requirements
EPA Reporting Requirements
The top priority of EPA’s Emergency Management program is to eliminate any danger to the public and the environment posed by hazardous substance releases and oil spills. Any person or organization responsible for a release or spill is required to notify the federal government when the amount reaches a federally-determined limit. Separate reporting requirements exist for:
Oil spills
Hazardous substance releases
States also may have separate reporting requirements. However, anybody who discovers a hazardous substance release or oil spill is encouraged to contact the federal government, regardless of whether they are the responsible party. All it takes is a single telephone call to the National Response Center at (800) 424-8802.
Oil Spills
EPA has established requirements to report spills to navigable waters or adjoining shorelines. EPA has determined that discharges of oil in quantities that may be harmful to public health or the environment include those that:
Violate applicable water quality standards;
Cause a film or “sheen” upon, or discoloration of the surface of the water or adjoining shorelines; or
Cause a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines.
Any person in charge of vessels or facilities that discharge oil in such quantities is required to report the spill to the federal government. EPA provides several exemptions from the oil spill reporting requirements.
The requirement for reporting oil spills stems from the Discharge of Oil Regulation, known as the “sheen rule.” Under this regulation, oil spill reporting does not depend on the specific amount of oil spilled, but on the presence of a visible sheen created by the spilled oil. Reporting an oil discharges may also be required under the Spill Prevention, Control, and Countermeasure (SPCC) Rule. For more information on reporting oil discharges, please see:
Oil Discharge Reporting Requirements: How to Report to the National Response Center and EPA
Hazardous Substances
For releases of hazardous substances, the federal government has established Superfund Reportable Quantities (RQs). If a hazardous substance is released to the environment in an amount that equals or exceeds its RQ, the release must be reported to federal authorities, unless certain reporting exemptions for hazardous substance releases also apply.
Under the Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986, the federal government has designated several hundred substances as “extremely hazardous substances” based on their acute lethal toxicity. Under the law, releases of these extremely hazardous substances trigger reporting requirements to state and local authorities, as well as the federal authorities. The owner or operator of a facility that releases an extremely hazardous substance in an amount greater than its established RQ must follow requirements on how to report to the appropriate authorities (in many cases, the State Emergency Response Commission (SERC) and the Local Emergency Planning Committee (LEPC)) for the location where the incident occurs.
The top priority of EPA’s Emergency Management program is to eliminate any danger to the public and the environment posed by hazardous substance releases and oil spills. Any person or organization responsible for a release or spill is required to notify the federal government when the amount reaches a federally-determined limit. Separate reporting requirements exist for:
Oil spills
Hazardous substance releases
States also may have separate reporting requirements. However, anybody who discovers a hazardous substance release or oil spill is encouraged to contact the federal government, regardless of whether they are the responsible party. All it takes is a single telephone call to the National Response Center at (800) 424-8802.
Oil Spills
EPA has established requirements to report spills to navigable waters or adjoining shorelines. EPA has determined that discharges of oil in quantities that may be harmful to public health or the environment include those that:
Violate applicable water quality standards;
Cause a film or “sheen” upon, or discoloration of the surface of the water or adjoining shorelines; or
Cause a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines.
Any person in charge of vessels or facilities that discharge oil in such quantities is required to report the spill to the federal government. EPA provides several exemptions from the oil spill reporting requirements.
The requirement for reporting oil spills stems from the Discharge of Oil Regulation, known as the “sheen rule.” Under this regulation, oil spill reporting does not depend on the specific amount of oil spilled, but on the presence of a visible sheen created by the spilled oil. Reporting an oil discharges may also be required under the Spill Prevention, Control, and Countermeasure (SPCC) Rule. For more information on reporting oil discharges, please see:
Oil Discharge Reporting Requirements: How to Report to the National Response Center and EPA
Hazardous Substances
For releases of hazardous substances, the federal government has established Superfund Reportable Quantities (RQs). If a hazardous substance is released to the environment in an amount that equals or exceeds its RQ, the release must be reported to federal authorities, unless certain reporting exemptions for hazardous substance releases also apply.
Under the Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986, the federal government has designated several hundred substances as “extremely hazardous substances” based on their acute lethal toxicity. Under the law, releases of these extremely hazardous substances trigger reporting requirements to state and local authorities, as well as the federal authorities. The owner or operator of a facility that releases an extremely hazardous substance in an amount greater than its established RQ must follow requirements on how to report to the appropriate authorities (in many cases, the State Emergency Response Commission (SERC) and the Local Emergency Planning Committee (LEPC)) for the location where the incident occurs.
SPCC and How it Applies to Rail Road Containment SPCC Regulations
January 22, 2008
SPCC and How it Applies to Rail Road Containment SPCC Regulations
Many facilities with railroad transloading racks are required to have a Spill Prevention, Control and Countermeasure (SPCC) Plan. This plan is a part of the Environmental Protection Agency’s Protection Rule published under the authority of Section 311(j)(i)(c) of the Federal Water pollution Control Act (Clean Water Act). This prevention rule calls for facilities subject to the rule to prepare and implement a plan to prevent discharge of oil into or upon navigable waters in the United States or adjoining shorelines. The regulation may be found at Title 40, Code of Federal Regulations, Part 112 (40CFR112). Enacted in July 2002, the regulations have been extended several times to provide sufficient time for facilities subject to the regulation to plan, prepare and implement an SPCC plan. Some issues regarding the Spill, Prevention, Control and Countermeasures Plan regulations have been involved in litigation causing extensions to final implementation and enforcement. The new compliance deadlines for SPCC plans are as follows:
EPA – SPCC Extension, May 16, 2007 Federal Register, pp. 27443-48, 40 CFR 112, Rule – Extends the dates by which facilities must prepare or amend Spill Prevention, Control, and Countermeasure (SPCC) Plans, and implement those plans. An owner or operator of a facility that was in operation on or before August 16, 2002, must make any necessary amendments to the SPCC plan, and implement that plan, on or before July 1, 2009. An owner or operator of a facility that came into operation after August 16, 2002, through July 1, 2009, must prepare and implement an SPCC plan on or before July 1, 2009. EPA expects to propose further revisions to the SPCC rule later this year. The effective date is May 16, 2007. Fur further information, contact Mark Howard at 202-564-1964.
Features & Benefits:
A facility may be required to implement the SPCC regulations if it meets the following criteria:
It handles Petroleum and/or Non-Petroleum oils.
It must be non-transportation related.
It must have aggregate above ground storage capacity greater than 1,320 gallons or a completely buried storage capacity greater then 42,000 gallons.
There must be a reasonable expectation of a discharge into or upon navigable waters of the United States or adjoining shorelines.
Many facilities such as oil refineries, power generation stations, ports, railroad transloading facilities, food processing facilities and petro chemical complexes are required to have an SPCC plan. What is considered oil by the Environmental Protection Agency? The term “oil” means “oil of any kind or in any form, including but not limited to - petroleum; fuel oil; sludge; oil mixed with wastes other than dredge spoil; fats; oils; greases of animal, fish, or marine mammal origin; vegetable oils, including oil from seeds, nuts, fruits, or kernels; and other oils and greases, including oils and mineral oils.”Note that the list and definition of oil is a dynamic document and has changed over the years and one should expect that there will be additional products added over time. If your facility handles a product which you think may be considered an oil click on the link below to verify if it is considered an oil by the EPA. Should you have other questions concerning SPCC regulations one should contact their regional EPA office and ask for the person in charge of SPCC regulations.What determines whether a facility could reasonably discharge oil into or upon navigable waters or adjoining shorelines? The location of your facility geographically and aspects of the facility in relation to navigable waters is one of the main factors that determine whether you must have an SPCC plan. Is there a reasonable chance that if you have an accidental discharge of oil and that it could find its way into a ditch, storm drain or sanitary sewer that leads to a wetland, mudflat, stream, river, bay and/or ocean then your facility may require an SPCC plan.How does the SPCC regulations relate to railroad tank cars and railroad transloading facilities? The SPCC regulations CFR 112.7(h)(l) states “Facility tank car and tank truck loading/unloading rack (excluding offshore facilities); (1) Where loading/unloading area drainage does not flow into a catchment basin or treatment facility designed to handle discharges, use a quick drainage system for tank car or tank truck loading/unloading areas. You must design a containment system to hold at least the maximum capacity of any single compartment of a tank car or tank truck loaded/unloaded at the facility.”
Below are excerpts and comments regarding “SPCC Guidance For Regional Inspectors” published by the EPA.
“Sufficiently Impervious” Requirements set forth in Section 112.7(c) which states that the entire secondary containment system “including walls and floors, must be capable of containing oil and must be constructed so that any discharge from a primary containment system will not escape before cleanup occurs”.
The purpose of the secondary containment requirement is to prevent discharges as described in 112.1(b); therefore, effectively secondary containment methods must be able to contain oil until the oil is cleaned up. EPA does not specify permeability or retention time performance criteria for these provisions.
The HDPE Enviropan® in most all cases meets the EPA SPCC “Sufficiently Impervious”. Because the Century Enviropan system is manufactured out of one of the most durable high-density polyethylene compounds in which many fuel and storage tanks are manufactured, in most every case the HDPE Enviropan® system will overwhelmingly meet the sufficiently impervious criteria. Normally the Enviropans are a part of the total secondary containment plan to sufficiently contain the accidental spillage of a railroad tank car. In most cases the Enviropan system is piped to a secondary containment system whose aggregate containment capacity including the HDPE railroad spill collection pans meets or exceeds SPCC regulations. “Impracticability”
In some cases owners and operators of facilities which handle oil products in railroad transloading operations, fueling and rail carwash operations will claim that its impractical to provide secondary containment of railroad tank cars and locomotives in transloading, fueling and carwash facilities.
The Enviropan system is widely used across North America for railroad spill containment and is considered the best available technology among engineers, railroads, industry and the military because its durable, economical and easy to install. Because of the track record and reasons mentioned above, the use of the Century railroad spill collection pans as part of secondary containment at railroad transloading racks, etc… negates the argument of “impracticability”.
“Transfer Operation”
Regulation 112.7(c) applies to both loading and unloading areas. A transfer operation is one in which oil is moved from or into some form of transportation, storage, equipment, or other device, into or from some other or similar form of transportation, such as a pipeline, truck, tank car or other storage, equipment or device (67 FR 47130).
Secondary containment size should be based on the magnitude of a most likely discharge, taking into consideration the specific features of the facility and operation. Specific features of different loading/unloading operations include the hardware, procedures and personnel who are able to take action to limit the volume of a discharge.
In regard to railroad transloading racks, the Century Enviropans alone in most cases will provide the necessary containment required to capture the volume of material spilled until the necessary emergency action takes place to stop the discharge.
A large majority of accidental spills in railroad transloading racks occur due to the following:
Failure of hose connection, valve
Accidental overfill of tank car
Residual fluid spills from hoses, valves, covers and other equipment disconnected
Leaking tank car valve
When designing secondary spill containment at a railroad loading/unloading rack, EPA recommends that a determination of adequate secondary containment consider:
The reasonably expected sources and causes of a discharge. This could be a failed hose connection; failed valve; overfill of a railroad tank car or breach of the tank car itself.
The reasonably expected maximum rate of discharge. This will be dependent on the mode of failure. It may be the maximum rate of transfer or the hypothetical leakage rate from a breached tank car.
The ability to detect and react to the discharge. This will be dependent on the availability of monitoring instrumentation for prompt detection of a discharge and/or the proximity of personnel to detect and respond to the discharge.
The reasonably expected duration of the discharge. This will be dependent on the availability of manual or automatic valves, the proximity of qualified personnel to the operations and other factors that may limit the volume of the discharge.
The time it would take a discharge to impact navigable waters and adjourning shorelines. This could depend on the proximity to waterways and storm drains and the slope of the ground surface between the loading area and the waterway or drain.
Century Service
If your facility meets the criteria for a SPCC plan and you have a railroad tank car transloading rack then you most probably need a railroad spill collection system. This is where Century Group Inc. can assist engineers, planners and EH & S personnel in developing a system that provides the most innovative, cost-effective and user friendly railroad spill collection and secondary containment at your railroad transloading or fueling area.
Commonly referred to as railroad drip pans or spill pans, the Century Enviropan® system is far more than just a pan in the railroad tracks when it comes to secondary containment and spill collection. The Century Enviropan® system was designed by our highly experienced staff with extensive experience in designing and constructing railroad spill containment systems. The Enviropans were developed to overcome many of the short comings that were encountered constructing poured-in-place concrete secondary containment systems and/or using other types of railroad spill collection equipment.
Over the past two decades Century Group Inc. has assisted engineers, Environmental, Health & Safety personnel and facility managers in developing a railroad spill collection system that is a key part of SWPP (Stormwater Pollution Prevention Plans) and the new SPCC regulations. Century’s goal is not only compliance, but making sure that the spill containment system being installed is compatible with the materials being handled, easy to install, is safe and will provide the maximum service life.
Century’s experienced and innovative staff is committed to making sure that your railroad spill collection and containment project minimizes railroad track downtime, runs smoothly and meets all expectations. Some of the services that we offer are:
Consultation regarding rehabilitation of the existing railroad tracks to accept the HDPE Enviropan® systems. If new track construction is required, we can assist with track construction specifications for materials such as crossties, rail, ballast, etc… Century can also recommend construction procedures to be adhered to such as welding of rail, surfacing and final ballast dressing of the railroad tracks.
Century also offers pre-construction inspection of the project site to make sure that there is proper clearances to allow for installation of the spill collection pans and make recommendations if the railroad track requires upgrading of rail, etc…
Customization of your spill containment system to fit around loading platforms, piping and other obstructions
Century can also provide written specifications, CAD shop and as-built drawings of our spill collection systems to be incorporated into your project plans and specifications. These shop drawings will also become a valuable piece of information when putting together safety, quality control and environmental compliance plans and documentation.
Once Century manufactures and delivers the railroad spill collection system, we offer technical personnel to assist your railroad contractor in installing the railroad spill collection pans to insure that you are totally satisfied with the Century HDPE Enviropan® system.
Century Group Inc. can also assist your company in providing documentation and even meeting with state or federal environmental regulators to insure that your railroad spill containment project satisfies all mandated regulations.
With over five decades of railroad construction and maintenance experience, the Century technical staff can be a valuable working partner in assisting industry in developing a railroad spill collection system that is compliant with SPCC and other environmental regulations. Our record working with Class I and shortline railroads, industry, light rail transit authorities and U. S. military facilities across North America allows us to provide the most advanced and unparalleled expertise in railroad spill collection systems.We’re committed in providing you with a full range of railroad spill collection and secondary containment technology that will be compliant and will assist your company in meeting its environmental objectives and demonstrate its commitment to being a good steward of the environment.
For more information, please visit: http://www.centurygrp.com/spill_detail.asp?id=8
SPCC and How it Applies to Rail Road Containment SPCC Regulations
Many facilities with railroad transloading racks are required to have a Spill Prevention, Control and Countermeasure (SPCC) Plan. This plan is a part of the Environmental Protection Agency’s Protection Rule published under the authority of Section 311(j)(i)(c) of the Federal Water pollution Control Act (Clean Water Act). This prevention rule calls for facilities subject to the rule to prepare and implement a plan to prevent discharge of oil into or upon navigable waters in the United States or adjoining shorelines. The regulation may be found at Title 40, Code of Federal Regulations, Part 112 (40CFR112). Enacted in July 2002, the regulations have been extended several times to provide sufficient time for facilities subject to the regulation to plan, prepare and implement an SPCC plan. Some issues regarding the Spill, Prevention, Control and Countermeasures Plan regulations have been involved in litigation causing extensions to final implementation and enforcement. The new compliance deadlines for SPCC plans are as follows:
EPA – SPCC Extension, May 16, 2007 Federal Register, pp. 27443-48, 40 CFR 112, Rule – Extends the dates by which facilities must prepare or amend Spill Prevention, Control, and Countermeasure (SPCC) Plans, and implement those plans. An owner or operator of a facility that was in operation on or before August 16, 2002, must make any necessary amendments to the SPCC plan, and implement that plan, on or before July 1, 2009. An owner or operator of a facility that came into operation after August 16, 2002, through July 1, 2009, must prepare and implement an SPCC plan on or before July 1, 2009. EPA expects to propose further revisions to the SPCC rule later this year. The effective date is May 16, 2007. Fur further information, contact Mark Howard at 202-564-1964.
Features & Benefits:
A facility may be required to implement the SPCC regulations if it meets the following criteria:
It handles Petroleum and/or Non-Petroleum oils.
It must be non-transportation related.
It must have aggregate above ground storage capacity greater than 1,320 gallons or a completely buried storage capacity greater then 42,000 gallons.
There must be a reasonable expectation of a discharge into or upon navigable waters of the United States or adjoining shorelines.
Many facilities such as oil refineries, power generation stations, ports, railroad transloading facilities, food processing facilities and petro chemical complexes are required to have an SPCC plan. What is considered oil by the Environmental Protection Agency? The term “oil” means “oil of any kind or in any form, including but not limited to - petroleum; fuel oil; sludge; oil mixed with wastes other than dredge spoil; fats; oils; greases of animal, fish, or marine mammal origin; vegetable oils, including oil from seeds, nuts, fruits, or kernels; and other oils and greases, including oils and mineral oils.”Note that the list and definition of oil is a dynamic document and has changed over the years and one should expect that there will be additional products added over time. If your facility handles a product which you think may be considered an oil click on the link below to verify if it is considered an oil by the EPA. Should you have other questions concerning SPCC regulations one should contact their regional EPA office and ask for the person in charge of SPCC regulations.What determines whether a facility could reasonably discharge oil into or upon navigable waters or adjoining shorelines? The location of your facility geographically and aspects of the facility in relation to navigable waters is one of the main factors that determine whether you must have an SPCC plan. Is there a reasonable chance that if you have an accidental discharge of oil and that it could find its way into a ditch, storm drain or sanitary sewer that leads to a wetland, mudflat, stream, river, bay and/or ocean then your facility may require an SPCC plan.How does the SPCC regulations relate to railroad tank cars and railroad transloading facilities? The SPCC regulations CFR 112.7(h)(l) states “Facility tank car and tank truck loading/unloading rack (excluding offshore facilities); (1) Where loading/unloading area drainage does not flow into a catchment basin or treatment facility designed to handle discharges, use a quick drainage system for tank car or tank truck loading/unloading areas. You must design a containment system to hold at least the maximum capacity of any single compartment of a tank car or tank truck loaded/unloaded at the facility.”
Below are excerpts and comments regarding “SPCC Guidance For Regional Inspectors” published by the EPA.
“Sufficiently Impervious” Requirements set forth in Section 112.7(c) which states that the entire secondary containment system “including walls and floors, must be capable of containing oil and must be constructed so that any discharge from a primary containment system will not escape before cleanup occurs”.
The purpose of the secondary containment requirement is to prevent discharges as described in 112.1(b); therefore, effectively secondary containment methods must be able to contain oil until the oil is cleaned up. EPA does not specify permeability or retention time performance criteria for these provisions.
The HDPE Enviropan® in most all cases meets the EPA SPCC “Sufficiently Impervious”. Because the Century Enviropan system is manufactured out of one of the most durable high-density polyethylene compounds in which many fuel and storage tanks are manufactured, in most every case the HDPE Enviropan® system will overwhelmingly meet the sufficiently impervious criteria. Normally the Enviropans are a part of the total secondary containment plan to sufficiently contain the accidental spillage of a railroad tank car. In most cases the Enviropan system is piped to a secondary containment system whose aggregate containment capacity including the HDPE railroad spill collection pans meets or exceeds SPCC regulations. “Impracticability”
In some cases owners and operators of facilities which handle oil products in railroad transloading operations, fueling and rail carwash operations will claim that its impractical to provide secondary containment of railroad tank cars and locomotives in transloading, fueling and carwash facilities.
The Enviropan system is widely used across North America for railroad spill containment and is considered the best available technology among engineers, railroads, industry and the military because its durable, economical and easy to install. Because of the track record and reasons mentioned above, the use of the Century railroad spill collection pans as part of secondary containment at railroad transloading racks, etc… negates the argument of “impracticability”.
“Transfer Operation”
Regulation 112.7(c) applies to both loading and unloading areas. A transfer operation is one in which oil is moved from or into some form of transportation, storage, equipment, or other device, into or from some other or similar form of transportation, such as a pipeline, truck, tank car or other storage, equipment or device (67 FR 47130).
Secondary containment size should be based on the magnitude of a most likely discharge, taking into consideration the specific features of the facility and operation. Specific features of different loading/unloading operations include the hardware, procedures and personnel who are able to take action to limit the volume of a discharge.
In regard to railroad transloading racks, the Century Enviropans alone in most cases will provide the necessary containment required to capture the volume of material spilled until the necessary emergency action takes place to stop the discharge.
A large majority of accidental spills in railroad transloading racks occur due to the following:
Failure of hose connection, valve
Accidental overfill of tank car
Residual fluid spills from hoses, valves, covers and other equipment disconnected
Leaking tank car valve
When designing secondary spill containment at a railroad loading/unloading rack, EPA recommends that a determination of adequate secondary containment consider:
The reasonably expected sources and causes of a discharge. This could be a failed hose connection; failed valve; overfill of a railroad tank car or breach of the tank car itself.
The reasonably expected maximum rate of discharge. This will be dependent on the mode of failure. It may be the maximum rate of transfer or the hypothetical leakage rate from a breached tank car.
The ability to detect and react to the discharge. This will be dependent on the availability of monitoring instrumentation for prompt detection of a discharge and/or the proximity of personnel to detect and respond to the discharge.
The reasonably expected duration of the discharge. This will be dependent on the availability of manual or automatic valves, the proximity of qualified personnel to the operations and other factors that may limit the volume of the discharge.
The time it would take a discharge to impact navigable waters and adjourning shorelines. This could depend on the proximity to waterways and storm drains and the slope of the ground surface between the loading area and the waterway or drain.
Century Service
If your facility meets the criteria for a SPCC plan and you have a railroad tank car transloading rack then you most probably need a railroad spill collection system. This is where Century Group Inc. can assist engineers, planners and EH & S personnel in developing a system that provides the most innovative, cost-effective and user friendly railroad spill collection and secondary containment at your railroad transloading or fueling area.
Commonly referred to as railroad drip pans or spill pans, the Century Enviropan® system is far more than just a pan in the railroad tracks when it comes to secondary containment and spill collection. The Century Enviropan® system was designed by our highly experienced staff with extensive experience in designing and constructing railroad spill containment systems. The Enviropans were developed to overcome many of the short comings that were encountered constructing poured-in-place concrete secondary containment systems and/or using other types of railroad spill collection equipment.
Over the past two decades Century Group Inc. has assisted engineers, Environmental, Health & Safety personnel and facility managers in developing a railroad spill collection system that is a key part of SWPP (Stormwater Pollution Prevention Plans) and the new SPCC regulations. Century’s goal is not only compliance, but making sure that the spill containment system being installed is compatible with the materials being handled, easy to install, is safe and will provide the maximum service life.
Century’s experienced and innovative staff is committed to making sure that your railroad spill collection and containment project minimizes railroad track downtime, runs smoothly and meets all expectations. Some of the services that we offer are:
Consultation regarding rehabilitation of the existing railroad tracks to accept the HDPE Enviropan® systems. If new track construction is required, we can assist with track construction specifications for materials such as crossties, rail, ballast, etc… Century can also recommend construction procedures to be adhered to such as welding of rail, surfacing and final ballast dressing of the railroad tracks.
Century also offers pre-construction inspection of the project site to make sure that there is proper clearances to allow for installation of the spill collection pans and make recommendations if the railroad track requires upgrading of rail, etc…
Customization of your spill containment system to fit around loading platforms, piping and other obstructions
Century can also provide written specifications, CAD shop and as-built drawings of our spill collection systems to be incorporated into your project plans and specifications. These shop drawings will also become a valuable piece of information when putting together safety, quality control and environmental compliance plans and documentation.
Once Century manufactures and delivers the railroad spill collection system, we offer technical personnel to assist your railroad contractor in installing the railroad spill collection pans to insure that you are totally satisfied with the Century HDPE Enviropan® system.
Century Group Inc. can also assist your company in providing documentation and even meeting with state or federal environmental regulators to insure that your railroad spill containment project satisfies all mandated regulations.
With over five decades of railroad construction and maintenance experience, the Century technical staff can be a valuable working partner in assisting industry in developing a railroad spill collection system that is compliant with SPCC and other environmental regulations. Our record working with Class I and shortline railroads, industry, light rail transit authorities and U. S. military facilities across North America allows us to provide the most advanced and unparalleled expertise in railroad spill collection systems.We’re committed in providing you with a full range of railroad spill collection and secondary containment technology that will be compliant and will assist your company in meeting its environmental objectives and demonstrate its commitment to being a good steward of the environment.
For more information, please visit: http://www.centurygrp.com/spill_detail.asp?id=8
Regional EPA Inspectors SPCC Checklist
Regional EPA Inspectors SPCC Checklist
January 22, 2008
I wanted to remind you of what the SPCC regional inspectors are instructed to evaluate facilities and spill prevention plans against. The material in this entry comes from the below link. Additional information may be found there:
http://www.epa.gov/emergencies/docs/oil/spcc/guidance/2_Applicability.pdf
Tank Trucks EPA regulates tank trucks as “mobile/portable containers” under the SPCC rule if they operate exclusively within the confines of a non-transportation-related facility. For example, a tank truck that moves around within the facility and only leaves the facility to obtain more fuel (oil) would be considered to distribute fuel exclusively at one facility. This tank truck would be subject to the SPCC rule if it, or the facility, contained above the regulatory threshold amount and there was a reasonable expectation of discharge to navigable waters or adjoining shorelines. Similarly, an airport refueler or construction refueler that fuels exclusively at one site would be subject to the SPCC rule. However, if the tank truck distributed fuel to multiple off-site facilities, the tank truck would be transportation-related, and regulated by DOT.
Tank trucks that are used in interstate or intrastate commerce can also be regulated if they are operating in a fixed, non-transportation mode. For example, if a home heating oil truck makes its deliveries, returns to the facility, and parks overnight with a partly filled fuel tank, it is subject to the SPCC rule if it, or the facility has a capacity above the threshold amount, and there is a reasonable expectation of discharge to navigable waters or shorelines. However, if the home heating oil truck’s fuel tank contains no oil when it is parked at the facility, other than any residual oil present in an emptied vehicle, it would be regulated only by DOT.
Any Loading/Unloading Activities
EPA regulates the activity of loading or unloading oil in bulk into storage containers (such as those on tank trucks or railroad cars), as well as all equipment involved in this activity (e.g., a hose or loading arm attached to a storage tank system). A “loading/unloading area” is any area of a facility where oil is transferred between bulk storage containers and tank trucks or railroad cars. These areas are subject to the general secondary containment requirements in §112.7(c). If a “loading/unloading rack” is present, the requirements of §112.7(h) apply to the loading/unloading rack area.
Motive Power
Motive power containers are located in or on a motor vehicle, such as on-board bulk oil storage containers used solely to power the movement of a motor vehicle, or ancillary on-board, oil-filled operational equipment used solely to facilitate its operation. A motive power container can be considered non-transportation-related and subject to the SPCC rule. However, EPA does not believe that the intent of the SPCC rule was to regulate motive power containers, including oil-filled tanks used to fuel the propulsion of vehicles, such as buses, sport utility vehicles, construction vehicles, and farm equipment.
1 Is the facility or part of the facility considered non-transportation-related and engaged in one of the following activities? Drilling, producing, gathering, storing, processing, refining, transferring, distributing,using, or consuming oil.
Yes. Go to question 2.No. The facility is not subject to the SPCC rule.
2 Could the facility reasonably be expected to discharge oil in quantities that may be harmfulinto navigable waters or adjoining shorelines?
Note: This determination must be based solely upon consideration of the geographical and locationaspects of the facility (such as proximity to navigable waters or adjoining shorelines, land contour,drainage, etc.) and must exclude consideration of manmade features such as dikes, berms,equipment or other structures, which may serve to restrain, hinder, contain, or otherwise prevent a discharge. Yes. Go to question 3.No. The facility is not subject to the SPCC rule.3a Is the total aggregate capacity of aboveground oil storage containers greater than 1,320 gallons? Note: Exclude containers less than 55 gallons, permanently closed containers, and storage containers used exclusively in wastewater treatment.Yes. The facility is subject to the SPCC rule.No. Go to question 3b.
3b Is the total aggregate capacity of completely buried storage tanks greater than 42,000 gallons?
Note: Do not include completely buried tanks subject to all technical requirements of 40 CFR part 280or 281, containers less than 55 gallons, permanently closed containers, or storage containers usedexclusively in wastewater treatment.Yes. The facility is subject to the SPCC rule.No. The facility is not subject to the SPCC rule.
January 22, 2008
I wanted to remind you of what the SPCC regional inspectors are instructed to evaluate facilities and spill prevention plans against. The material in this entry comes from the below link. Additional information may be found there:
http://www.epa.gov/emergencies/docs/oil/spcc/guidance/2_Applicability.pdf
Tank Trucks EPA regulates tank trucks as “mobile/portable containers” under the SPCC rule if they operate exclusively within the confines of a non-transportation-related facility. For example, a tank truck that moves around within the facility and only leaves the facility to obtain more fuel (oil) would be considered to distribute fuel exclusively at one facility. This tank truck would be subject to the SPCC rule if it, or the facility, contained above the regulatory threshold amount and there was a reasonable expectation of discharge to navigable waters or adjoining shorelines. Similarly, an airport refueler or construction refueler that fuels exclusively at one site would be subject to the SPCC rule. However, if the tank truck distributed fuel to multiple off-site facilities, the tank truck would be transportation-related, and regulated by DOT.
Tank trucks that are used in interstate or intrastate commerce can also be regulated if they are operating in a fixed, non-transportation mode. For example, if a home heating oil truck makes its deliveries, returns to the facility, and parks overnight with a partly filled fuel tank, it is subject to the SPCC rule if it, or the facility has a capacity above the threshold amount, and there is a reasonable expectation of discharge to navigable waters or shorelines. However, if the home heating oil truck’s fuel tank contains no oil when it is parked at the facility, other than any residual oil present in an emptied vehicle, it would be regulated only by DOT.
Any Loading/Unloading Activities
EPA regulates the activity of loading or unloading oil in bulk into storage containers (such as those on tank trucks or railroad cars), as well as all equipment involved in this activity (e.g., a hose or loading arm attached to a storage tank system). A “loading/unloading area” is any area of a facility where oil is transferred between bulk storage containers and tank trucks or railroad cars. These areas are subject to the general secondary containment requirements in §112.7(c). If a “loading/unloading rack” is present, the requirements of §112.7(h) apply to the loading/unloading rack area.
Motive Power
Motive power containers are located in or on a motor vehicle, such as on-board bulk oil storage containers used solely to power the movement of a motor vehicle, or ancillary on-board, oil-filled operational equipment used solely to facilitate its operation. A motive power container can be considered non-transportation-related and subject to the SPCC rule. However, EPA does not believe that the intent of the SPCC rule was to regulate motive power containers, including oil-filled tanks used to fuel the propulsion of vehicles, such as buses, sport utility vehicles, construction vehicles, and farm equipment.
1 Is the facility or part of the facility considered non-transportation-related and engaged in one of the following activities? Drilling, producing, gathering, storing, processing, refining, transferring, distributing,using, or consuming oil.
Yes. Go to question 2.No. The facility is not subject to the SPCC rule.
2 Could the facility reasonably be expected to discharge oil in quantities that may be harmfulinto navigable waters or adjoining shorelines?
Note: This determination must be based solely upon consideration of the geographical and locationaspects of the facility (such as proximity to navigable waters or adjoining shorelines, land contour,drainage, etc.) and must exclude consideration of manmade features such as dikes, berms,equipment or other structures, which may serve to restrain, hinder, contain, or otherwise prevent a discharge. Yes. Go to question 3.No. The facility is not subject to the SPCC rule.3a Is the total aggregate capacity of aboveground oil storage containers greater than 1,320 gallons? Note: Exclude containers less than 55 gallons, permanently closed containers, and storage containers used exclusively in wastewater treatment.Yes. The facility is subject to the SPCC rule.No. Go to question 3b.
3b Is the total aggregate capacity of completely buried storage tanks greater than 42,000 gallons?
Note: Do not include completely buried tanks subject to all technical requirements of 40 CFR part 280or 281, containers less than 55 gallons, permanently closed containers, or storage containers usedexclusively in wastewater treatment.Yes. The facility is subject to the SPCC rule.No. The facility is not subject to the SPCC rule.
Key Information on Attaining SPCC Compliance
Key Information on Attaining SPCC Compliance
Article by Lee Hill January 23, 2008
After spending the last three years working on SPCC compliancy issues, I have had the unique opportunity to visit industrial, commercial and military sites requiring SPCC plans and I have met industry experts and government inspectors. One of the best product offerings that I have come across for managing stormwater in secondary containment areas is from Solidification Products International.
The Petro-Plug, Petro-Pipe and Petro-Barrier Systems are virtually maintenance free and do exactly what they claim. The systems exhaust rainwater from containment areas without the risk of releasing oils and other hydrocarbons to the environment.
How this is accomplished is by packing the drain with a hydrophobic polymer median that undergoes a physical reaction when it comes into contact with hydrocarbons. What this means is that when oil comes into contact with the filter median, it creates a gelatin material that blocks all fluid flow. While oil reacts with the median, water passes straight through it.
This gelatin blockage can happen slowly over time in the case where only oil sheen is present or in the event of a catastrophic spill where a large volume is released the sealing is immediate.
The products are utilized at Electric Companies, major Universities, industrial sites and military bases. For an informative video presentation on the products and SPI please visit:
http://www.oilbarriers.com/promo.html
Article by Lee Hill January 23, 2008
After spending the last three years working on SPCC compliancy issues, I have had the unique opportunity to visit industrial, commercial and military sites requiring SPCC plans and I have met industry experts and government inspectors. One of the best product offerings that I have come across for managing stormwater in secondary containment areas is from Solidification Products International.
The Petro-Plug, Petro-Pipe and Petro-Barrier Systems are virtually maintenance free and do exactly what they claim. The systems exhaust rainwater from containment areas without the risk of releasing oils and other hydrocarbons to the environment.
How this is accomplished is by packing the drain with a hydrophobic polymer median that undergoes a physical reaction when it comes into contact with hydrocarbons. What this means is that when oil comes into contact with the filter median, it creates a gelatin material that blocks all fluid flow. While oil reacts with the median, water passes straight through it.
This gelatin blockage can happen slowly over time in the case where only oil sheen is present or in the event of a catastrophic spill where a large volume is released the sealing is immediate.
The products are utilized at Electric Companies, major Universities, industrial sites and military bases. For an informative video presentation on the products and SPI please visit:
http://www.oilbarriers.com/promo.html
Applicability of the SPCC Requirements to Electrical Utilities
Applicability of the SPCC Requirements to Electrical Utilities
reposted from EPA region 6 website January 23, 2008
EPA’s SPCC requirements (40 CFR Part 112.1 through 112.7) apply to nontransportation-related facilities that could reasonably be expected to discharge oil into or upon the navigable waters of the United States or adjoining shorelines, and that have (1) a total underground buried storage capacity of more than 42,000 gallons; or (2) a total aboveground oil storage capacity of more than 1,320 gallons, or (3) an aboveground oil storage capacity of more than 660 gallons in a single container.
Some facilities may not be regulated if, due to their location, they could not reasonably be expected to discharge oil into navigable waters of the U.S. or adjoining shorelines. SPCC-regulated facilities must also comply with other federal, state, or local laws, some of which may be more stringent.
This guide is intended for SPCC-regulated facilities engaged in the generation, transmission, and/or distribution of electric power, and that use equipment (e.g., transformers and circuit breakers) which contain dielectric fluid (mineral oil) for insulation, compressor oil, and hydraulic oil. These facilities include power plants (including hydroelectric and cogeneration facilities), substations, switching stations, customer installations, test facilities, and equipment storage and maintenance facilities.
Operations related to SPCC at these facilities include the transfer of oil for maintenance activities, the storage of fuel oil for powering generators during emergencies or for power plant startup, and the storage of insulation (dielectric) oil in electrical equipment (e.g., transformers, oil circuit breakers, capacitors, regulators). Some facilities are moving towards using sulfur hexafluoride (SF6) gas for insulating circuit breakers. These circuit breakers do not contain oil for insulation purposes, but they do contain small amounts (e.g., two gallons) of compressor oil.
Many electrical utilities are subject to the SPCC regulation, and some utilities may be subject to the Facility Response Plan (FRP) requirements under 40 CFR 112.20 and 112.21 and associated appendices. All owners or operators of SPCC-regulated facilities should determine whether the facility poses a threat of substantial harm to the environment. All facilities must document this determination by completing the “Certification of the Applicability of the Substantial Harm Criteria Checklist,” provided as Attachment C-II in Appendix C of 40 CFR 112. This certification should be kept with the facility’s SPCC Plan.
As outlined in 40 CFR 112.20(f)(1), a facility has the potential to cause substantial harm and, therefore, must prepare an FRP if:
The facility transfers oil over water to or from vessels and has a total oil storage capacity, including both aboveground storage tanks (ASTs) and underground storage tanks (USTs), greater than or equal to 42,000 gallons; or
The facility’s total oil storage capacity, including both ASTs and USTs, is greater than or equal to one million gallons, and one of the following is true:
The facility lacks secondary containment that is able to contain the capacity of the largest AST within each storage area plus freeboard to allow for precipitation;
The facility is located at a distance such that a discharge from the facility could cause injury to an environmentally sensitive area;
The facility is located at a distance such that a discharge from the facility would shut down a public drinking-water intake; or
The facility has had a reportable spill greater than or equal to 10,000 gallons within the last five years.
Many power-generating facilities are located adjacent to or over water; so if their aggregate storage (including oil-filled electrical equipment, fixed and mobile storage tanks, etc.) is more than one million gallons, they are likely to be subject to the FRP requirements as well. These facilities are likely to be required to prepare an FRP because a discharge from the facility has a high potential to cause injury to an environmentally sensitive area or shut down a public drinking water intake.
To read further on this subject please visit:
http://www.epa.gov/earth1r6/6sf/sfsites/oil/elecutil.htm
reposted from EPA region 6 website January 23, 2008
EPA’s SPCC requirements (40 CFR Part 112.1 through 112.7) apply to nontransportation-related facilities that could reasonably be expected to discharge oil into or upon the navigable waters of the United States or adjoining shorelines, and that have (1) a total underground buried storage capacity of more than 42,000 gallons; or (2) a total aboveground oil storage capacity of more than 1,320 gallons, or (3) an aboveground oil storage capacity of more than 660 gallons in a single container.
Some facilities may not be regulated if, due to their location, they could not reasonably be expected to discharge oil into navigable waters of the U.S. or adjoining shorelines. SPCC-regulated facilities must also comply with other federal, state, or local laws, some of which may be more stringent.
This guide is intended for SPCC-regulated facilities engaged in the generation, transmission, and/or distribution of electric power, and that use equipment (e.g., transformers and circuit breakers) which contain dielectric fluid (mineral oil) for insulation, compressor oil, and hydraulic oil. These facilities include power plants (including hydroelectric and cogeneration facilities), substations, switching stations, customer installations, test facilities, and equipment storage and maintenance facilities.
Operations related to SPCC at these facilities include the transfer of oil for maintenance activities, the storage of fuel oil for powering generators during emergencies or for power plant startup, and the storage of insulation (dielectric) oil in electrical equipment (e.g., transformers, oil circuit breakers, capacitors, regulators). Some facilities are moving towards using sulfur hexafluoride (SF6) gas for insulating circuit breakers. These circuit breakers do not contain oil for insulation purposes, but they do contain small amounts (e.g., two gallons) of compressor oil.
Many electrical utilities are subject to the SPCC regulation, and some utilities may be subject to the Facility Response Plan (FRP) requirements under 40 CFR 112.20 and 112.21 and associated appendices. All owners or operators of SPCC-regulated facilities should determine whether the facility poses a threat of substantial harm to the environment. All facilities must document this determination by completing the “Certification of the Applicability of the Substantial Harm Criteria Checklist,” provided as Attachment C-II in Appendix C of 40 CFR 112. This certification should be kept with the facility’s SPCC Plan.
As outlined in 40 CFR 112.20(f)(1), a facility has the potential to cause substantial harm and, therefore, must prepare an FRP if:
The facility transfers oil over water to or from vessels and has a total oil storage capacity, including both aboveground storage tanks (ASTs) and underground storage tanks (USTs), greater than or equal to 42,000 gallons; or
The facility’s total oil storage capacity, including both ASTs and USTs, is greater than or equal to one million gallons, and one of the following is true:
The facility lacks secondary containment that is able to contain the capacity of the largest AST within each storage area plus freeboard to allow for precipitation;
The facility is located at a distance such that a discharge from the facility could cause injury to an environmentally sensitive area;
The facility is located at a distance such that a discharge from the facility would shut down a public drinking-water intake; or
The facility has had a reportable spill greater than or equal to 10,000 gallons within the last five years.
Many power-generating facilities are located adjacent to or over water; so if their aggregate storage (including oil-filled electrical equipment, fixed and mobile storage tanks, etc.) is more than one million gallons, they are likely to be subject to the FRP requirements as well. These facilities are likely to be required to prepare an FRP because a discharge from the facility has a high potential to cause injury to an environmentally sensitive area or shut down a public drinking water intake.
To read further on this subject please visit:
http://www.epa.gov/earth1r6/6sf/sfsites/oil/elecutil.htm
Questions about SPCC and Mobile Refuelers
Questions about SPCC and Mobile Refuelers
by Lee Hill
January 25, 2008
It is often asked what the requirements are for mobile refuelers. Many believe that amendments to 40 CFR last year completely exempted mobile refuelers from all SPCC requirements. This is not true.
It is true that the sized secondary requirements were removed for mobile refuelers. However, the general regulations in 112.7(c) of 40 CFR still apply to mobile refuelers at SPCC regulated facilities.
A section taken directly from the EPA’s website should help to clarify. I have posted it here:
“General secondary containment should be designed to address the most likely discharge from the container and from oil transfers into or from the mobile refueler. The general secondary containment requirements:
Do not prescribe a size for a secondary containment structure but require that the containment system prevent the spilled oil from escaping the system prior to clean up occurring
Require appropriate containment and/or diversionary structures or equipment to prevent a discharge to navigable waters or adjoining shorelines
Allow for the use of certain types of active containment measures that prevent a discharge to navigable waters or adjoining shorelines”
As you can see, the property owner is still responsible for containing the spill. Many see this regulation as nebulous at best and open to wide interpretations. Conservative facilities are finding that it is easier to proceed forward with sized containment because the EPA also states that refuelers that are unmanned for periods of time would be considered an above ground storage tank (AST). This statement brings the sized containment regulations back into play.
Why were these amendments proposed? The answer is simple, the Airport Industry lobbied Congress to get an exemption. Pressure was applied to the EPA and the sized restriction requiring spill berms was removed. What the industry does not fully realize is that in the event of a spill, the EPA has the authority via the general requirements to fine. Hence the nebulous nature of the regulations.
The question asked is do you roll the dice and hope against the inevitable or do you consider taking a best management practices approach and protect your site against a catastrophic spill event. The answer is that it comes down to economics. Hopefully, I have demonstrated throughout this blog that an “ounce of prevention is worth a pound of cure…” As a responsible individual for an area, I would not want to jeapordize my career by cutting a corner. Quite often this is the case that we see in industry. It simply is not worth the negative impact to not prepare in advance.
In addition to this argument, it is often the case that the mobile refueler is engaged with loading racks. During this transfer process the sized containment regulations are enforced. Most sites deem it feasible to design their facility for sized containment at the loading racks and leave their mobile refueler parked in that containment when not in use. When in use, spill kits are kept handily on board the vehicle as part of an active containment requirement.
For more details on the rulings concerning mobile refuelers visit:
http://www.epa.gov/OEM/content/spcc/factsheet_mobile_refuelers_dec06.htm
Alaska State Oil Spill Prevention Regulations Outlined
Web posted Wednesday, December 20, 2006
Oil spill prevention regs outlined
By PHIL HERMANEK
Peninsula Clarion
New state oil spill prevention regulations were spelled out for oil and gas industry representatives meeting in Kenai on Tuesday.
Lydia Miner, manager for the Alaska Department of Environmental Conservation’s exploration, production and refineries section, told members of the support industry Alliance that the changes are not in direct response to recent spills and pipeline corrosion detected on the North Slope, but rather are the second of a four-phase DEC regulation review and update.
Miner said the seven staff members in her section manage regulations for four refineries in Alaska, 12 production facilities, 19 exploration facilities and two crude oil pipeline terminals.
“Our mission is to keep oil in the container,” she said.
Changes to the regulations include increased oil spill prevention training and documentation requirements as well as new and revised regulations for flow lines, above-ground oil storage tanks and facility piping, Miner said.
The oil spill prevention training requirements have now been moved into a section by themselves, she said, and require that personnel who inspect, maintain or operate oil storage and transfer equipment must be trained in company and state spill prevention measures. Training records must be kept for five years.
For the sake of the regulations, piping is defined in the revised regulations as “piping that carries oil between a well pad or offshore platform and a production facility,” she said.
Flow lines are required to have either leak detection devices in place or a documented preventive maintenance program.
Regarding portable storage tanks, Miner said vaulted, self-diked and double-wall shop-fabricated tanks — as defined in the regulations — are exempted from some secondary containment requirements.
Effective dates for the new regulations vary.
Regulations covering design and construction go into effect in 2009; regulations covering operations and maintenance go into effect in 2008; and remaining regulations are effective at the end of this year.
“I can’t come to the Kenai Peninsula and not talk about natural gas,” Miner said.
“All exploration wells must have an approved c-plan (Oil Discharge Prevention and Contingency Plan) and financial responsibility ... insurance ... in place,” she said.
If it is determined a well will not encounter liquid hydrocarbons that can flow to the surface, an exemption can be obtained from the c-plan and financial responsibility requirements.
Miner said all the changes in the DEC regulations can be found on the department’s Web site at www.dec.state.ak. us/spar/ipp.
“These regulations haven’t changed since 1992,” Miner said.
“We know you want consistency in the regulations — we do too. We also want to involve ourselves in continuous improvement,” she said.
During a question-and-answer session following her presentation, Miner said the next part of the regulatory review would involve crude oil transmission lines.
Phase one of the review resulted in changes to the c-plan requirements made in 2000.
Oil spill prevention regs outlined
By PHIL HERMANEK
Peninsula Clarion
New state oil spill prevention regulations were spelled out for oil and gas industry representatives meeting in Kenai on Tuesday.
Lydia Miner, manager for the Alaska Department of Environmental Conservation’s exploration, production and refineries section, told members of the support industry Alliance that the changes are not in direct response to recent spills and pipeline corrosion detected on the North Slope, but rather are the second of a four-phase DEC regulation review and update.
Miner said the seven staff members in her section manage regulations for four refineries in Alaska, 12 production facilities, 19 exploration facilities and two crude oil pipeline terminals.
“Our mission is to keep oil in the container,” she said.
Changes to the regulations include increased oil spill prevention training and documentation requirements as well as new and revised regulations for flow lines, above-ground oil storage tanks and facility piping, Miner said.
The oil spill prevention training requirements have now been moved into a section by themselves, she said, and require that personnel who inspect, maintain or operate oil storage and transfer equipment must be trained in company and state spill prevention measures. Training records must be kept for five years.
For the sake of the regulations, piping is defined in the revised regulations as “piping that carries oil between a well pad or offshore platform and a production facility,” she said.
Flow lines are required to have either leak detection devices in place or a documented preventive maintenance program.
Regarding portable storage tanks, Miner said vaulted, self-diked and double-wall shop-fabricated tanks — as defined in the regulations — are exempted from some secondary containment requirements.
Effective dates for the new regulations vary.
Regulations covering design and construction go into effect in 2009; regulations covering operations and maintenance go into effect in 2008; and remaining regulations are effective at the end of this year.
“I can’t come to the Kenai Peninsula and not talk about natural gas,” Miner said.
“All exploration wells must have an approved c-plan (Oil Discharge Prevention and Contingency Plan) and financial responsibility ... insurance ... in place,” she said.
If it is determined a well will not encounter liquid hydrocarbons that can flow to the surface, an exemption can be obtained from the c-plan and financial responsibility requirements.
Miner said all the changes in the DEC regulations can be found on the department’s Web site at www.dec.state.ak. us/spar/ipp.
“These regulations haven’t changed since 1992,” Miner said.
“We know you want consistency in the regulations — we do too. We also want to involve ourselves in continuous improvement,” she said.
During a question-and-answer session following her presentation, Miner said the next part of the regulatory review would involve crude oil transmission lines.
Phase one of the review resulted in changes to the c-plan requirements made in 2000.
Draper Energy Fined by EPA for SPCC Violations
Posted Wednesday, October 3, 2007
Draper Energy Fined by EPA
Failed to Plan for and Guard against Oil Spills
By Peter Bragdon
Milford Observer Publisher
Draper Energy Company, the Wilton-based oil and gas company with a storage and distribution facility on Nashua Street in Milford, has been fined $9,045 by the EPA, resolving an issue first reported in the Milford Observer in June. At the time, Draper was accused of failing to plan for and guard against oil spills at its Wilton and Milford facilities, as required by the federal Clean Water Act (CWA). The company faced a maximum fine of $150,000.
The CWA fines stem from a complaint filed by the EPA's New England Office that Draper Energy failed to prepare a Spill Prevention, Control, and Countermeasure (SPCC) plan for its Wilton facility and failed to fully implement its SPCC plan for the Milford facility. At its Wilton facility, according to the EPA, Draper Energy "failed to construct sufficiently impervious secondary containment around its oil storage containers" and failed to keep records of container inspections and staff training. In Milford, it is alleged that Draper Energy did not fully implement the SPCC plan by, "failing to promptly correct visible oil discharges caused by leaking pumps and worn tank manhole seals and failing to secure unlocked pump starter controls," and that the company failed to maintain records of formal facility inspections and staff training at the location.
In June, the EPA described the Milford facility as a "sensitive location" since it stores gasoline and is within the well radius of Town of Milford's drinking water supply. Spills at the facility could lead to the contamination of a public drinking water aquifer, according to the EPA. “Oil spills can do significant damage to the environment, including to neighboring drinking water wells and public drinking water supplies,” said Robert W. Varney, Regional Administrator of EPA's New England office at the time. “EPA will continue to ensure that facilities handling oils must follow established procedures to minimize risks of oil spills.”
It is still unclear whether or not further action will be pursued against the company for allegedly failing to file chemical inventory forms with local and state emergency planning authorities, as required by the federal Emergency Planning and Community Right to Know Act (EPCRA). According to EPCRA, any facility that stores greater than 10,000 gallons of gasoline or oil is required to properly notify state and local authorities about the storage of these products so they can properly prepare for accidents or releases from the facility. Draper had been facing fines of up to $32,500 per day for the EPCRA violations.
Draper Energy Fined by EPA
Failed to Plan for and Guard against Oil Spills
By Peter Bragdon
Milford Observer Publisher
Draper Energy Company, the Wilton-based oil and gas company with a storage and distribution facility on Nashua Street in Milford, has been fined $9,045 by the EPA, resolving an issue first reported in the Milford Observer in June. At the time, Draper was accused of failing to plan for and guard against oil spills at its Wilton and Milford facilities, as required by the federal Clean Water Act (CWA). The company faced a maximum fine of $150,000.
The CWA fines stem from a complaint filed by the EPA's New England Office that Draper Energy failed to prepare a Spill Prevention, Control, and Countermeasure (SPCC) plan for its Wilton facility and failed to fully implement its SPCC plan for the Milford facility. At its Wilton facility, according to the EPA, Draper Energy "failed to construct sufficiently impervious secondary containment around its oil storage containers" and failed to keep records of container inspections and staff training. In Milford, it is alleged that Draper Energy did not fully implement the SPCC plan by, "failing to promptly correct visible oil discharges caused by leaking pumps and worn tank manhole seals and failing to secure unlocked pump starter controls," and that the company failed to maintain records of formal facility inspections and staff training at the location.
In June, the EPA described the Milford facility as a "sensitive location" since it stores gasoline and is within the well radius of Town of Milford's drinking water supply. Spills at the facility could lead to the contamination of a public drinking water aquifer, according to the EPA. “Oil spills can do significant damage to the environment, including to neighboring drinking water wells and public drinking water supplies,” said Robert W. Varney, Regional Administrator of EPA's New England office at the time. “EPA will continue to ensure that facilities handling oils must follow established procedures to minimize risks of oil spills.”
It is still unclear whether or not further action will be pursued against the company for allegedly failing to file chemical inventory forms with local and state emergency planning authorities, as required by the federal Emergency Planning and Community Right to Know Act (EPCRA). According to EPCRA, any facility that stores greater than 10,000 gallons of gasoline or oil is required to properly notify state and local authorities about the storage of these products so they can properly prepare for accidents or releases from the facility. Draper had been facing fines of up to $32,500 per day for the EPCRA violations.
Derby, Vermont Company Faces Fine for SPCC Oil Spill Prevention Violations
Derby, Vermont Company Faces Fine for Oil Spill Prevention Violations
Release date: 10/24/2007
Contact Information: Paula Ballentine, (617) 918-1027
(Boston, Mass. – Oct. 24, 2007) - A plumbing and heating company that stores and distributes oil from its bulk storage facility in Derby, Vermont faces fines of up to $157,500 for allegedly failing to adequately plan for and guard against oil spills at its facility.
Earlier this year on Feb. 27, approximately 5,000 gallons of gasoline was released from a 25,000 gallon double-compartment above-ground storage tank at the Fred’s Plumbing & Heating bulk plant located on Route 5 in Derby. During the clean-up response, it was revealed that spilled gasoline had migrated beyond the secondary containment walls and floor surrounding the tank and contaminated soil and groundwater on the facility grounds.
The Vermont Dept. of Environmental Conservation (VTDEC) responded to the spill and is continuing to oversee the ongoing remediation and investigation to categorize the extent of the release and recover the discharged oil. Efforts continue to evaluate the threat posed by the release to a tributary of the John’s River, located approximately 200 feet southwest of the spill area, and to two nearby drinking water wells, which are located within 1,000 feet of bulk plant.
EPA’s Administrative Complaint alleges that the company violated the federal Clean Water Act by failing to have an adequate "Spill Prevention, Control, and Countermeasure" plan in place at its facility. EPA’s Oil Pollution Prevention regulations require that certain spill prevention and response measures be implemented at facilities that store oil above threshold amounts. The rule helps ensure that a tank failure or spill does not lead to oil being released into surface waters, such as rivers or streams, or groundwater.
An inspector from EPA’s New England office and a representative from VTDEC inspected the Derby facility and found that the company had failed to fully implement an adequate spill prevention plan for the site. In particular, the company failed to construct sufficiently impervious secondary containment for the oil storage containers, loading rack, and other fuel transfer areas.
“Oil spills can do significant damage to the environment, including to surface waters and drinking water supplies,” said Robert W. Varney, regional administrator of EPA's New England office. “EPA will continue to ensure that facilities handling oils follow established procedures to minimize risks of oil spills.”
EPA has been focusing on oil spill prevention in New England. The complaint against Fred’s Plumbing & Heating is one of many undertaken by EPA during the past 18 months to ensure that facilities that store oil have fully implemented SPCC plans at their facilities.
More information:
- New England oil spill prevention (epa.gov/ne/superfund/er/oilstor.htm)
- National oil spill prevention (epa.gov/oilspill)
Release date: 10/24/2007
Contact Information: Paula Ballentine, (617) 918-1027
(Boston, Mass. – Oct. 24, 2007) - A plumbing and heating company that stores and distributes oil from its bulk storage facility in Derby, Vermont faces fines of up to $157,500 for allegedly failing to adequately plan for and guard against oil spills at its facility.
Earlier this year on Feb. 27, approximately 5,000 gallons of gasoline was released from a 25,000 gallon double-compartment above-ground storage tank at the Fred’s Plumbing & Heating bulk plant located on Route 5 in Derby. During the clean-up response, it was revealed that spilled gasoline had migrated beyond the secondary containment walls and floor surrounding the tank and contaminated soil and groundwater on the facility grounds.
The Vermont Dept. of Environmental Conservation (VTDEC) responded to the spill and is continuing to oversee the ongoing remediation and investigation to categorize the extent of the release and recover the discharged oil. Efforts continue to evaluate the threat posed by the release to a tributary of the John’s River, located approximately 200 feet southwest of the spill area, and to two nearby drinking water wells, which are located within 1,000 feet of bulk plant.
EPA’s Administrative Complaint alleges that the company violated the federal Clean Water Act by failing to have an adequate "Spill Prevention, Control, and Countermeasure" plan in place at its facility. EPA’s Oil Pollution Prevention regulations require that certain spill prevention and response measures be implemented at facilities that store oil above threshold amounts. The rule helps ensure that a tank failure or spill does not lead to oil being released into surface waters, such as rivers or streams, or groundwater.
An inspector from EPA’s New England office and a representative from VTDEC inspected the Derby facility and found that the company had failed to fully implement an adequate spill prevention plan for the site. In particular, the company failed to construct sufficiently impervious secondary containment for the oil storage containers, loading rack, and other fuel transfer areas.
“Oil spills can do significant damage to the environment, including to surface waters and drinking water supplies,” said Robert W. Varney, regional administrator of EPA's New England office. “EPA will continue to ensure that facilities handling oils follow established procedures to minimize risks of oil spills.”
EPA has been focusing on oil spill prevention in New England. The complaint against Fred’s Plumbing & Heating is one of many undertaken by EPA during the past 18 months to ensure that facilities that store oil have fully implemented SPCC plans at their facilities.
More information:
- New England oil spill prevention (epa.gov/ne/superfund/er/oilstor.htm)
- National oil spill prevention (epa.gov/oilspill)
TEPPCO to Pay $2.8M to Settle Clean Water SPCC Violations
TEPPCO to Pay $2.8M to Settle Clean Water SPCC Violations
Author: RP news wires
December 6, 2007
TE Products Pipeline Company LLC and TEPPCO Crude Pipeline LLC (collectively “TEPPCO”) will pay a $2.865 million penalty to resolve violations of the Clean Water Act, the Environmental Protection Agency announced on August 16.
In addition, the Houston-based oil and gas distributor will be required to make modifications to its pipeline operations that involve performing corrosion control surveys, installing surveillance cameras, and updating its computer system to better detect leaks and spills.
“It is imperative that business and industry do their part to minimize the risks of oil and fuel spills,” said EPA regional administrator Richard E. Greene. “Keeping our waters clean must be a priority and must be viewed as a fundamental responsibility. EPA and our state partners will continue to ensure that companies make conscientious efforts to follow environmental laws.”
TEPPCO discharged approximately 6,470 barrels (271,740 gallons) of jet fuel, gasoline and crude oil on four different occasions into waters of the United States between November 2001 and May 2005 at locations in Arkansas, Oklahoma and Texas. The following describes each discharge:
A release of approximately 2,575 barrels (108,150 gallons) of Jet A Kerosene, or jet fuel, into the Neches River and its tributaries near Vidor, Texas, on November 27, 2001. This spill resulted from disbonded coating and external corrosion on the pipeline.
A release of approximately 500 barrels (21,000 gallons) of unleaded gasoline into an unnamed tributary of the Moro Creek, which flows into the Ouachita River, near the Fordyce Pump Station in Cleveland County, Ark., on March 12, 2004. This spill resulted from corrosion of a half-inch bleeder line that was part of a pipeline block valve used to equalize pressure across the valve.
A release of approximately 2,497 barrels (104,874 gallons) of Jet A Kerosene, a portion of which escaped containment and reached Big Cow Creek, a tributary of the Sabine River, near Newton, Texas, on February 28, 2005. This spill was caused by an operator error that involved the over-tightening of a coupling at a cooling line at the top of a mainline pump.
A release of approximately 898 barrels (37,716 gallons) of crude oil on May 13, 2005, into Eastman Creek, which is a tributary of the Red River, and an unnamed tributary of Eastman Creek near Colbert, Okla. This spill was caused by a longitudinal seam split on a pipeline that resulted from a stress crack that may have been induced by conditions occurring during rail transport and enlarged by pressure-cycle-induced stresses over the years of the pipe’s operation.
Under the terms of the consent decree, TEPPCO will pay a total of $2,865,000 and be required to:
perform a close internal survey of the segment of the pipeline system from Beaumont, Texas, to Many, La. The Vidor spill occurred on this segment. For each nonconforming location, corrective action must be taken to bring the cathodic protection into compliance.
Install remote surveillance cameras at the Newton, Texas, and Many, La., pump stations. The cameras will provide around-the-clock site surveillance of pump stations by the Houston Pipeline Control Center and the field operation centers located in Beaumont, Texas, and El Dorado, Ark.
update its Supervisory Control and Data Acquisition system on the pipeline by installing leak detection functionality based on a computational pipeline model software system. The objective of the update is to enable TEPPCO to more precisely monitor and balance the volume of product in the pipeline with the integration of pressure and temperature data to monitor pipeline pressure deviations, which can be indicators of leaks or spills from the pipeline.
submit various reports to EPA on the status and completion of the injunctive relief requirements.
The complaint and agreement for the TEPPCO violations were filed in the Federal District Court for the Eastern District of Texas, located in Beaumont, Texas.
To learn more about enforcement activities in EPA Region 6, please visit www.epa.gov/region6.
Author: RP news wires
December 6, 2007
TE Products Pipeline Company LLC and TEPPCO Crude Pipeline LLC (collectively “TEPPCO”) will pay a $2.865 million penalty to resolve violations of the Clean Water Act, the Environmental Protection Agency announced on August 16.
In addition, the Houston-based oil and gas distributor will be required to make modifications to its pipeline operations that involve performing corrosion control surveys, installing surveillance cameras, and updating its computer system to better detect leaks and spills.
“It is imperative that business and industry do their part to minimize the risks of oil and fuel spills,” said EPA regional administrator Richard E. Greene. “Keeping our waters clean must be a priority and must be viewed as a fundamental responsibility. EPA and our state partners will continue to ensure that companies make conscientious efforts to follow environmental laws.”
TEPPCO discharged approximately 6,470 barrels (271,740 gallons) of jet fuel, gasoline and crude oil on four different occasions into waters of the United States between November 2001 and May 2005 at locations in Arkansas, Oklahoma and Texas. The following describes each discharge:
A release of approximately 2,575 barrels (108,150 gallons) of Jet A Kerosene, or jet fuel, into the Neches River and its tributaries near Vidor, Texas, on November 27, 2001. This spill resulted from disbonded coating and external corrosion on the pipeline.
A release of approximately 500 barrels (21,000 gallons) of unleaded gasoline into an unnamed tributary of the Moro Creek, which flows into the Ouachita River, near the Fordyce Pump Station in Cleveland County, Ark., on March 12, 2004. This spill resulted from corrosion of a half-inch bleeder line that was part of a pipeline block valve used to equalize pressure across the valve.
A release of approximately 2,497 barrels (104,874 gallons) of Jet A Kerosene, a portion of which escaped containment and reached Big Cow Creek, a tributary of the Sabine River, near Newton, Texas, on February 28, 2005. This spill was caused by an operator error that involved the over-tightening of a coupling at a cooling line at the top of a mainline pump.
A release of approximately 898 barrels (37,716 gallons) of crude oil on May 13, 2005, into Eastman Creek, which is a tributary of the Red River, and an unnamed tributary of Eastman Creek near Colbert, Okla. This spill was caused by a longitudinal seam split on a pipeline that resulted from a stress crack that may have been induced by conditions occurring during rail transport and enlarged by pressure-cycle-induced stresses over the years of the pipe’s operation.
Under the terms of the consent decree, TEPPCO will pay a total of $2,865,000 and be required to:
perform a close internal survey of the segment of the pipeline system from Beaumont, Texas, to Many, La. The Vidor spill occurred on this segment. For each nonconforming location, corrective action must be taken to bring the cathodic protection into compliance.
Install remote surveillance cameras at the Newton, Texas, and Many, La., pump stations. The cameras will provide around-the-clock site surveillance of pump stations by the Houston Pipeline Control Center and the field operation centers located in Beaumont, Texas, and El Dorado, Ark.
update its Supervisory Control and Data Acquisition system on the pipeline by installing leak detection functionality based on a computational pipeline model software system. The objective of the update is to enable TEPPCO to more precisely monitor and balance the volume of product in the pipeline with the integration of pressure and temperature data to monitor pipeline pressure deviations, which can be indicators of leaks or spills from the pipeline.
submit various reports to EPA on the status and completion of the injunctive relief requirements.
The complaint and agreement for the TEPPCO violations were filed in the Federal District Court for the Eastern District of Texas, located in Beaumont, Texas.
To learn more about enforcement activities in EPA Region 6, please visit www.epa.gov/region6.
Items to Consider in SPCC and FRP Plans
Items to Consider in SPCC and FRP Plans
By Brian Wanzenried
August 2007 Ethanol Producer Magazine
The U.S. EPA has spent decades developing and enforcing regulations intended to protect human health and the environment. The regulations affecting the ethanol industry continue to evolve, largely due to the industry's relative youth. While fuel ethanol facilities produce what is generally considered an environmentally friendly fuel, there is inherent risk of spillage in any industrial-scale processing facility. Therefore, the EPA continues to update the regulations affecting ethanol and similar industries.
The EPA recently amended the Spill Prevention Control and Countermeasure (SPCC) regulation so that all subjected facilities must have an updated SPCC plan by Oct. 31, 2007, although at press time the agency proposed extending SPCC compliance dates to July 1, 2009. While updating, preparing, reviewing and implementing SPCC and Facility Response Plans (FRP), it's easy to overlook materials and items subject to these regulations.
The SPCC regulation requires the development of a SPCC plan that is reviewed and certified by a licensed professional engineer. Soliciting the assistance of professional engineering consultants during the development of a plant's SPCC plan can help ethanol facility owners and managers prevent mistakes and avoid roadblocks to meeting EPA standards while avoiding fines and costly changes.
The EPA promulgated the SPCC regulation in 1974 and designed it to prevent releases of oils to navigable waterways. The SPCC regulation requires certain preventive measures such as secondary containment around storage tanks, and the development and implementation of an SPCC plan describing the preventive measures. The SPCC regulation applies to non-transportation facilities with certain quantities of on-site oils (e.g., 1,320 gallons of aboveground aggregate capacity) and a reasonable expectation of having a spill impact a navigable waterway.
The EPA promulgated the FRP regulation in 1991 and designed it to provide improved responses to oil spills in navigable waterways. Several other federal agencies have similar regulations with different applicability criteria. The EPA's version applies to non-transportation facilities with certain quantities of oils on-site (e.g., greater than 1 million gallons, or over 42,000 gallons if the facility transfers oil over water) and a risk of causing substantial harm to the environment.
Materials Considered as Oils
The purpose of the SPCC and FRP regulations is to prevent and mitigate oil spills in navigable waterways. According to Section 112.2 of Title 40 of the Code of Federal Regulations, "Oil means oil of any kind or in any form... ." Although the EPA hasn't provided a more specific technical interpretation or definition of "oils" subject to these regulations, it's identified specific materials (e.g., in the Federal Register preambles to the various SPCC and FRP regulations) that are "oils" including:
› Animal fats and oils
› Crude oil
› Diesel fuel
› Fuel oil
› Leaded and unleaded gasoline
› Hydraulic oils
› Jet fuel
› Kerosene
› Lubricating oils
› Nut oils
› Vegetable oils
The EPA recently interpreted that ethanol denatured with gasoline is an oil under the Clean Water Act. The interpretation was explained in a Nov. 6, 2006, letter from EPA Assistant Administrator Susan Parker Bodine to Renewable Fuels Association President Bob Dinneen. Based on this interpretation, an ethanol plant must include the denatured ethanol in its SPCC plan, and provide control and containment measures for the denatured ethanol. Additionally, the ethanol plant may be subject to the FRP requirements depending on the facility's total oil storage capacity.
The SPCC applicability may also apply if the ethanol is denatured with kerosene and pyronate. However, straight ethanol and ethanol denatured with methyl isobutyl ketone, nitropropane, methyl n-butyl ketone, acetaldol and heptane are unlikely to be considered oils since these denaturants are hazardous substances and not oils.
Items Covered Under the SPCC Regulation
As a good rule of thumb, any equipment containing "oil" is covered by the SPCC regulation. This includes, but is not limited to:
› Storage tanks
› Portable containers (e.g., drums and tote tanks)
› Mixers
› Pipes
› Oil-filled electrical equipment
› Oil-filled operating equipment
› Tanker trucks, and
› Railcars.
An exception to this rule includes items, such as barrels, with a capacity less than 55 gallons. However, it's important to emphasize that this exception is for capacity and not the actual volume of oil in the item.
Oil-filled operating and electrical equipment is often overlooked by facilities preparing and implementing SPCC plans. Oil-filled operating equipment includes hydraulic and lubricating oil reservoirs, and vessels, that are processing oils. such as a mixing tank. Oil-filled electrical equipment includes transformers, breakers and reclosers that have insulating oils, but doesn't include dry transformers and transformers with sulfur hexafluoride.
An interpretation communicated by the EPA indicates that if the ethanol plant doesn't own on-site, oil-filled electrical equipment, then the facility's oil storage capacity doesn't need to include that equipment. Therefore, the SPCC plan doesn't have to address that equipment. However, it's recommended that the SPCC plan identifies the oil-filled electrical equipment on the plant site diagrams with a note explaining the equipment isn't owned by the ethanol plant.
The SPCC plan should also include tank trucks and railcars loaded or unloaded on-site. This is based on information provided in an undated letter from Stephen F. Heare, acting deputy director for the Office of Emergency and Remedial Response of the EPA, to Melissa Young, of the Government Affairs Council of the Petroleum Marketers Association of America. Additionally, when determining oil storage capacity for the FRP regulation, the facility should estimate the maximum number of tank trucks and railcars on-site and include this volume when determining the facility's storage capacity. Tank trucks and railcars incidentally on-site (i.e., not loaded or unloaded on-site) don't need to be counted towards the facility's capacity. They're considered transportation-related and aren't subject to the EPA's jurisdiction. A tank truck or railcar may be incidentally on-site if it's parked on-site overnight or brought on-site by the rail line as long as the tank truck or railcar is not loaded or unloaded while on-site.
By Brian Wanzenried
August 2007 Ethanol Producer Magazine
The U.S. EPA has spent decades developing and enforcing regulations intended to protect human health and the environment. The regulations affecting the ethanol industry continue to evolve, largely due to the industry's relative youth. While fuel ethanol facilities produce what is generally considered an environmentally friendly fuel, there is inherent risk of spillage in any industrial-scale processing facility. Therefore, the EPA continues to update the regulations affecting ethanol and similar industries.
The EPA recently amended the Spill Prevention Control and Countermeasure (SPCC) regulation so that all subjected facilities must have an updated SPCC plan by Oct. 31, 2007, although at press time the agency proposed extending SPCC compliance dates to July 1, 2009. While updating, preparing, reviewing and implementing SPCC and Facility Response Plans (FRP), it's easy to overlook materials and items subject to these regulations.
The SPCC regulation requires the development of a SPCC plan that is reviewed and certified by a licensed professional engineer. Soliciting the assistance of professional engineering consultants during the development of a plant's SPCC plan can help ethanol facility owners and managers prevent mistakes and avoid roadblocks to meeting EPA standards while avoiding fines and costly changes.
The EPA promulgated the SPCC regulation in 1974 and designed it to prevent releases of oils to navigable waterways. The SPCC regulation requires certain preventive measures such as secondary containment around storage tanks, and the development and implementation of an SPCC plan describing the preventive measures. The SPCC regulation applies to non-transportation facilities with certain quantities of on-site oils (e.g., 1,320 gallons of aboveground aggregate capacity) and a reasonable expectation of having a spill impact a navigable waterway.
The EPA promulgated the FRP regulation in 1991 and designed it to provide improved responses to oil spills in navigable waterways. Several other federal agencies have similar regulations with different applicability criteria. The EPA's version applies to non-transportation facilities with certain quantities of oils on-site (e.g., greater than 1 million gallons, or over 42,000 gallons if the facility transfers oil over water) and a risk of causing substantial harm to the environment.
Materials Considered as Oils
The purpose of the SPCC and FRP regulations is to prevent and mitigate oil spills in navigable waterways. According to Section 112.2 of Title 40 of the Code of Federal Regulations, "Oil means oil of any kind or in any form... ." Although the EPA hasn't provided a more specific technical interpretation or definition of "oils" subject to these regulations, it's identified specific materials (e.g., in the Federal Register preambles to the various SPCC and FRP regulations) that are "oils" including:
› Animal fats and oils
› Crude oil
› Diesel fuel
› Fuel oil
› Leaded and unleaded gasoline
› Hydraulic oils
› Jet fuel
› Kerosene
› Lubricating oils
› Nut oils
› Vegetable oils
The EPA recently interpreted that ethanol denatured with gasoline is an oil under the Clean Water Act. The interpretation was explained in a Nov. 6, 2006, letter from EPA Assistant Administrator Susan Parker Bodine to Renewable Fuels Association President Bob Dinneen. Based on this interpretation, an ethanol plant must include the denatured ethanol in its SPCC plan, and provide control and containment measures for the denatured ethanol. Additionally, the ethanol plant may be subject to the FRP requirements depending on the facility's total oil storage capacity.
The SPCC applicability may also apply if the ethanol is denatured with kerosene and pyronate. However, straight ethanol and ethanol denatured with methyl isobutyl ketone, nitropropane, methyl n-butyl ketone, acetaldol and heptane are unlikely to be considered oils since these denaturants are hazardous substances and not oils.
Items Covered Under the SPCC Regulation
As a good rule of thumb, any equipment containing "oil" is covered by the SPCC regulation. This includes, but is not limited to:
› Storage tanks
› Portable containers (e.g., drums and tote tanks)
› Mixers
› Pipes
› Oil-filled electrical equipment
› Oil-filled operating equipment
› Tanker trucks, and
› Railcars.
An exception to this rule includes items, such as barrels, with a capacity less than 55 gallons. However, it's important to emphasize that this exception is for capacity and not the actual volume of oil in the item.
Oil-filled operating and electrical equipment is often overlooked by facilities preparing and implementing SPCC plans. Oil-filled operating equipment includes hydraulic and lubricating oil reservoirs, and vessels, that are processing oils. such as a mixing tank. Oil-filled electrical equipment includes transformers, breakers and reclosers that have insulating oils, but doesn't include dry transformers and transformers with sulfur hexafluoride.
An interpretation communicated by the EPA indicates that if the ethanol plant doesn't own on-site, oil-filled electrical equipment, then the facility's oil storage capacity doesn't need to include that equipment. Therefore, the SPCC plan doesn't have to address that equipment. However, it's recommended that the SPCC plan identifies the oil-filled electrical equipment on the plant site diagrams with a note explaining the equipment isn't owned by the ethanol plant.
The SPCC plan should also include tank trucks and railcars loaded or unloaded on-site. This is based on information provided in an undated letter from Stephen F. Heare, acting deputy director for the Office of Emergency and Remedial Response of the EPA, to Melissa Young, of the Government Affairs Council of the Petroleum Marketers Association of America. Additionally, when determining oil storage capacity for the FRP regulation, the facility should estimate the maximum number of tank trucks and railcars on-site and include this volume when determining the facility's storage capacity. Tank trucks and railcars incidentally on-site (i.e., not loaded or unloaded on-site) don't need to be counted towards the facility's capacity. They're considered transportation-related and aren't subject to the EPA's jurisdiction. A tank truck or railcar may be incidentally on-site if it's parked on-site overnight or brought on-site by the rail line as long as the tank truck or railcar is not loaded or unloaded while on-site.
Well Designed Plant Concerning SPCC
Asphalt Batch Plant to Operate in Whitefield Gravel Pit
Story date: 07/25/2007
By Lucy L. Martin
A temporary asphalt batch plant in Crooker & Sons' Whitefield gravel pit will rely on a state-of-the-art containment system that was put in place five years ago.
In addition, under a water quality monitoring program developed in 1995, three wells will be sampled prior to startup in mid-August to establish baseline data.
Practices of 20 years ago, when the Topsham based company operated unlicensed asphalt plants in the Whitefield pit with small, inadequate containment berms, prompted opposition and a legal challenge in 1994, initially by the town of Whitefield and then by neighbors and conservationists fearing fuel leaks. They demanded a spill contingency plan, assurances that the buried liner of the spill containment system wouldn't break, and additional test wells to track groundwater movement.
The Sheepscot River is about a half mile away and groundwater is within five feet of the pit floor.
Mark Stebbins, mining coordinator in the Dept. of Environmental Protection's (DEP) Land and Water Bureau, said the company "constructed a secondary containment system" in 2002. "If there's a spill of petroleum products, the system catches it so it doesn't get released into the groundwater. It's like a landfill synthetic liner system."
According to engineering diagrams, 12 inches of compacted sand underlie a 60 or 80 mil geomembrane liner; above that is 18 inches of compacted sand, topped by six inches of compacted gravel. Three inches of bituminous pavement, grade B, covers all.
Stebbins compared one part of the facility to a bathtub into which the whole batch plant is placed. "They back the asphalt plant over and up a ramp and slide it into a containment structure which is like a bathtub. If there's a leak, it's contained."
The system addresses the major concern, which is the possible leakage of diesel fuel, used to run the burner which heats the plant. The storage tank, Stebbins said, might hold anywhere from 10,000 to 20,000 gallons. Escaping liquid asphalt is less of a threat because it thickens as it cools.
Stebbins said, "Crooker has a very impressive design. I can't think of any other in the state like it. He went above and beyond."
The pit used to be licensed under the state's Site Location of Development law. Then, a provision in state statutes allowed previously permitted gravel pits to meet newly designed performance standards, Stebbins said, and Crooker was transferred to that program in 1999/2000. The performance standards program does not require a formal application every time the company wants to make a change, such as bring in an asphalt plant or rock crusher. The pit owner simply has to notify the DEP and the towns where the activity is to take place, in this instance, Alna and Whitefield. Each town received notification by letter on June 25.
The program is "a time saver," said Stebbins, "whereas under the old site law, when they sent in an application, it could be several months before they got a permit. Since October, 1993, we've licensed 650 gravel pits under the performance standards. There were previously 250 in the state under the old site law." Stebbins also said the compliance rate is 87 percent, "which is high compared to other department programs. There are 139 pits left under the old site law, so the program has worked well as an alternative regulatory program."
DEP environmental specialist Molly Zogby, who works with Stebbins, said the company "laid down an impervious liner for an aboveground (fuel) storage tank. All fuel has to be contained in a secondary containment structure designed to contain 110 percent of the fuel being stored."
In an advisory letter dated June 21 to Crooker & Sons, project engineer Steven E. Patch of Sevee & Maher Engineers said the company should make sure that existing contours at the site leave a five-foot separation from the containment system and groundwater. He recommended that three test wells and a spring be used as "water quality monitoring points for the temporary operation of the batch plant.... Samples will be analyzed by an independent qualified laboratory for diesel range organic compounds (DROs) according to a Maine Health and Environmental Testing Laboratory method." After the plant is started up, "a detection monitoring program will be initiated, which will include collection of samples for DRO analysis on a semi-annual basis." Follow-up sampling would occur in the fall and spring of each year "for a period of one year following shutdown of plant operations."
In addition, data collected during the sampling and monitoring rounds are to be submitted annually by Crooker to the DEP's land and water bureau "for review. However, if analysis indicates that the batch plant may be impacting ground-water or surface water quality, the [DEP] will be notified immediately," Patch wrote.
The site's Spill Prevention, Countermeasure and Control Plan requires operator training, routine inspections, monitoring and reporting.
The batch plant, scheduled for operation between mid-August and mid-October, will provide pavement for a Damariscotta region contract Crooker has with the Dept. of Transportation.
Story date: 07/25/2007
By Lucy L. Martin
A temporary asphalt batch plant in Crooker & Sons' Whitefield gravel pit will rely on a state-of-the-art containment system that was put in place five years ago.
In addition, under a water quality monitoring program developed in 1995, three wells will be sampled prior to startup in mid-August to establish baseline data.
Practices of 20 years ago, when the Topsham based company operated unlicensed asphalt plants in the Whitefield pit with small, inadequate containment berms, prompted opposition and a legal challenge in 1994, initially by the town of Whitefield and then by neighbors and conservationists fearing fuel leaks. They demanded a spill contingency plan, assurances that the buried liner of the spill containment system wouldn't break, and additional test wells to track groundwater movement.
The Sheepscot River is about a half mile away and groundwater is within five feet of the pit floor.
Mark Stebbins, mining coordinator in the Dept. of Environmental Protection's (DEP) Land and Water Bureau, said the company "constructed a secondary containment system" in 2002. "If there's a spill of petroleum products, the system catches it so it doesn't get released into the groundwater. It's like a landfill synthetic liner system."
According to engineering diagrams, 12 inches of compacted sand underlie a 60 or 80 mil geomembrane liner; above that is 18 inches of compacted sand, topped by six inches of compacted gravel. Three inches of bituminous pavement, grade B, covers all.
Stebbins compared one part of the facility to a bathtub into which the whole batch plant is placed. "They back the asphalt plant over and up a ramp and slide it into a containment structure which is like a bathtub. If there's a leak, it's contained."
The system addresses the major concern, which is the possible leakage of diesel fuel, used to run the burner which heats the plant. The storage tank, Stebbins said, might hold anywhere from 10,000 to 20,000 gallons. Escaping liquid asphalt is less of a threat because it thickens as it cools.
Stebbins said, "Crooker has a very impressive design. I can't think of any other in the state like it. He went above and beyond."
The pit used to be licensed under the state's Site Location of Development law. Then, a provision in state statutes allowed previously permitted gravel pits to meet newly designed performance standards, Stebbins said, and Crooker was transferred to that program in 1999/2000. The performance standards program does not require a formal application every time the company wants to make a change, such as bring in an asphalt plant or rock crusher. The pit owner simply has to notify the DEP and the towns where the activity is to take place, in this instance, Alna and Whitefield. Each town received notification by letter on June 25.
The program is "a time saver," said Stebbins, "whereas under the old site law, when they sent in an application, it could be several months before they got a permit. Since October, 1993, we've licensed 650 gravel pits under the performance standards. There were previously 250 in the state under the old site law." Stebbins also said the compliance rate is 87 percent, "which is high compared to other department programs. There are 139 pits left under the old site law, so the program has worked well as an alternative regulatory program."
DEP environmental specialist Molly Zogby, who works with Stebbins, said the company "laid down an impervious liner for an aboveground (fuel) storage tank. All fuel has to be contained in a secondary containment structure designed to contain 110 percent of the fuel being stored."
In an advisory letter dated June 21 to Crooker & Sons, project engineer Steven E. Patch of Sevee & Maher Engineers said the company should make sure that existing contours at the site leave a five-foot separation from the containment system and groundwater. He recommended that three test wells and a spring be used as "water quality monitoring points for the temporary operation of the batch plant.... Samples will be analyzed by an independent qualified laboratory for diesel range organic compounds (DROs) according to a Maine Health and Environmental Testing Laboratory method." After the plant is started up, "a detection monitoring program will be initiated, which will include collection of samples for DRO analysis on a semi-annual basis." Follow-up sampling would occur in the fall and spring of each year "for a period of one year following shutdown of plant operations."
In addition, data collected during the sampling and monitoring rounds are to be submitted annually by Crooker to the DEP's land and water bureau "for review. However, if analysis indicates that the batch plant may be impacting ground-water or surface water quality, the [DEP] will be notified immediately," Patch wrote.
The site's Spill Prevention, Countermeasure and Control Plan requires operator training, routine inspections, monitoring and reporting.
The batch plant, scheduled for operation between mid-August and mid-October, will provide pavement for a Damariscotta region contract Crooker has with the Dept. of Transportation.
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