How to Comply with Florida DEP AST Rules and Avoid Petroleum Discharges to the Environment

Transcription

1 How to Comply with Florida DEP AST Rules and Avoid Petroleum Discharges to the Environment Aboveground Storage Tank Systems Mott-Smith Consulting Group, LLC

2 Marshall T. Mott-Smith, President Mott-Smith Consulting Group, LLC Wednesday Street Tallahassee, Fl cell

3 Division of Waste Management - Mary Jean Yon, Director Dotty Diltz, Assistant Director Bureau of Petroleum Storage Systems Mike Ashey, Chief Storage Tank Regulation Section Bill Burns, Administrator

4 FDEP District Offices Pensacola Jacksonville Tampa Orlando West Palm Fort Myers

5 Facility Statistics Source - STCM, Apr 2009 Registered > 54,000 Active Regulated 21,122

6 Tanks Registered > 186,000 Closed/removed > 120,000 Regulated USTs 25,570 Regulated ASTs 22,579 *As of Apr, 2009

7 April, 2009 Status Double-wall USTs 67.3% ASTs with Secondary Containment 91% 15,879 ASTs USTs 17,222 8,348 ASTs 20,538 3, Source - STCM, Apr 09 Single-wall USTs 32.7% Single-wall ASTs - 9%

8 Storage Tank Ownership by Facility Type 2009 ASTs & USTs Fuel User/Non Retail 33% 7029 Bulk Product 1% Source: STCM Apr Agricultural 5% Industrial 1% Retail Station 38% Government 18%

9 >35,023 Incident and Discharge Reports Received As of April 2009

10 Protecting Florida s Water Quality

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12 Who or What gives DEP or any Agency the Authority to Regulate your Facility?

13 Your Elected Representatives in the Florida Legislature! Legislators pass laws giving authority for state agencies to adopt rules

14 Proposed AST Rule Changes Current Rule Revision Effort Ongoing Since 1999

15 Some believe there is no hope

16 But There is Hope

17 Applicability Chapter , F.A.C.

18 Are you Regulated?

19 Applicability Chapter , F.A.C. All aboveground storage tanks over 550 gallons containing pollutants (pesticides, chlorine, ammonia, petroleum, or any derivatives of these substances). Tanks must contain products that are liquids at standard temperature and pressure.

20 Types of Facilities Regulated

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22 MAJOR EXCLUSIONS: - LP gas tanks. - Hydraulic lift tanks. - Stormwater or septic tanks - Pipelines. - Loading racks - Flow through process tanks - Residential tanks - Heating oil tanks for on-site use (<30,000 gallons)

23 Pressure Vessels Agricultural tanks less than 550 gallons Vapor Recovery Tanks Mobile Tanks

24 Is this a Mobile Tank?

25 Is this an aboveground tank?

26 Tank, or domicile?

27 Residential Tanks

28 Reference Standards

29 Industry Reference Standards The Technical Foundation of DEP s Regulations ACI API ASME ASTM NACE NFPA PEI SSPC STI UL - American Concrete Institute. - American Petroleum Institute. - American Society of Mechanical Engineers - American Society for Testing and Materials. - National Association of Corrosion Engineers. - National Fire Protection Association. - Petroleum Equipment Institute. - Society for Protective Coatings. - Steel Tank Institute. - Underwriters Laboratories.

30 Industry Reference Standards Available for review at DEP and County Offices Available for purchase by the Association Are considered rules when adopted by DEP Are constantly being updated and modified Are usually developed in Committee by industry experts, and may include regulators

31 DEP s Florida Leak Autopsy Study The Statistical Foundation of DEP s Regulations

32 Leak Autopsy Studies

33 Florida Leak Autopsy Forms 1 Jan Mar 08 Valid AST Discharges 12% 194 Invalid AST Forms 3% Forms Valid UST Discharges 46% Invalid UST Discharges 38%

34 Field-erected AST Facility Discharges without Leak Study or Leak Autopsy Forms - 88% Source - STCM, Apr Field-erected AST System Discharges 117 Field-erected AST Facility Discharges with Leak Study or Leak Autopsy Forms - 13%

35 Leak Autopsy Report Forms Required for all new discharges after January 1, Post-January 1, 2003 discharges (These have completed, field-verified Leak-Autopsy Report Forms) 70 Pre-January 1, 2003 discharges from, the Florida Cause of Leak Study (Discharge information generated from inspection file reviews)

36 Field-erected AST Discharges

37 Discharges from Field-erected Aboveground Storage Tank Systems <88 '89 '91 '93 '95 '97 '99 '01 '03 '05 ' Source: STCM, Apr Note: DEP AST Rules began in 1991 Discharges 117 Discharges Included in The Study

38 80 facilities with Discharges reported unknown dates of tank installations Installation Date Ranges of Field-erected ASTs at Facilities with Discharges 14 More Problems with Older Facilities? Year Constructed Apr

39 Percent of Discharges by Product Type Diesel 30% 34 #4 Fuel Oil 3% 4 New Oil 1% 25 # 5 & #6 Fuel Oil 21% Apr 07 Kerosine 1% Jet Fuel 26% 31 Gasohol 1% 13 Unknown 3% Waste Oil 2% Gasoline 11% #2 Fuel Oil 1% Field-Erected AST Systems 4 Petroleum Contact Water 2%

40 Percent of Estimated Gallons Discharged by Product Type PCW <1% Jet Fuel 67% Diesel 8% Gasoline 2% >473,395 Total Gallons Apr # 2, #4, & Kerosine <1% Field-Erected AST Systems #5 & #6 Oil 22%

41 Sources of Discharges - Field-Erected AST Systems Hydrant Piping & Pits 3% Fill pipes & Transfer Hoses 2% 4 Bulk Product Piping 48% 32 Field-Erected Tanks 27% 56 4 Pumps 3% Discharges Apr 07 Small Diameter Piping 1% Vehicles 3% Valves 10% Day Tanks & Fuel Filters 2% Tanks are only 17% if overfills and other external factors are excluded

42 Causes of Discharges from All Sources Apr 07 Material Failure 10% Weather 2% Loose Component 13% Other 2% Mechanical Damage 5% 2 26 Spill 4% Corrosion 22% Physical Damage 5% Overfill 9% Component Failure 7% Field-Erected AST Systems Unknown 17% Human Error 4%

43 Causes of Discharges from Piping, Valves, & Pumps Apr 07 Flanges & Gaskets & Fittings 11% Day Tank Overfill 1% Unspecified Loose Components 7% Air Eliminator Valve 1% Physical & Mechanical Damage 8% Gauges 2% Unspecified Corrosion 21% Spill 4% Weather 1% Unknown 14% Hoses 2% O-Rings 2% Material & Weld Failure 6% Stuck or 5 Open Valves 5% Vehiclerelated 6% Field-Erected AST Systems Pressure Relief Valve 6%

44 Causes of Discharges from Tanks Apr 07 Weather Damage Roof Drain 3% Overfills 28% 9 Unknown 25% Bullet Holes 3% 8 3 Unspecified Corrosion 9% Delta Liner 3% 3 Tank Bottom Leaks 9% Pressure Relief Vent Spill 3% 3% 3 Loose Component 9% Corroded Rivets 3% Human Error 3% Field-Erected AST Systems

45 Causes of Discharges from Field-erected Tanks, Excluding External Factors (e.g. Overfills & Weather) Unknown 40% 8 3 Tank Bottom Leaks 15% 1 Delta Liner 5% Apr 07 Pressure Relief Vent 5% 1 3 Unspecified Corrosion 15% 1 3 Corroded Rivets 5% Field-Erected AST Systems Loose Component 15%

46 Leak Autopsy Reports Received Field-erected Tank is the Source 4 ASTs 3 2 Tanks 1 0 < *Note - DEP adopted API 653 in 1991 Tanks

47 Leak Autopsy Reports Received Bulk Product Piping is the Source Note - Deadline for API 570 Inspections (1 Jan 00) < Piping

48 Registered Florida Facilities with Discharges at Sites with Field-erected ASTs - 65% Source - STCM, Apr 07 Facilities Registered Facilities without Discharges 35%

49 Discharge Photos

50 Tank Overfill

51 Tank Overfill

52 Shop-fabricated Tank Discharges

53 Discharges from Shop-fabricated Aboveground Storage Tank Systems Discharges Included in The Study Discharges <94 '95 '96 '97 '98 '99 '00 '01 '02 '03 '04 '05 '06 '07 Source: STCM, Apr 07

54 Tank Installation Date Ranges for Shop-fabricated AST Facilities with Discharges facilities with Discharges reported unknown dates of tank installations More problems with Newer Facilities? Is Age of Tank a Factor? 38 Year Constructed Apr 07

55 Percent of Discharges by Product Type Diesel & Emergency Diesel 68% Apr Kerosine 1% Jet Fuel 6% Gasoline 10% Mineral Acid 1% Shop-fabricated AST Systems 8 Heating Oil 2% New & Lube Oil 4% Other 3% Waste Oil 4%

56 Percent of Estimated Gallons Discharged by Product Type New & Lube Oil 1% Heating Oil 1% Diesel 20% Other 3% 15,267 40,255 Waste Oil 53% >75,472 Total Gallons Apr 07 Kerosine 2% Jet Fuel & Av Gas 7% Gasoline 4% Mineral Acid 9% Shop-fabricated AST Systems

57 Sources of Discharges - Shop-fabricated ASTs Bulk Product Piping 1% Fill Pipes 1% Dispensing Systems & Dispensers 12% 25 Delivery Vehicles 6% 13 Valves 2% Pumps 2% 49 Generator Hose Fitting <1% Small Diameter Piping 24% 203 Discharges Apr Shopfabricated tanks 36% 10 9 Fuel filters 2% Customer Day Tanks 4% Vehicles 5% Spill Containment 1%

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59 Causes of Discharges from All Sources Material Failure 2% Physical Damage Improper 8% Installation 3% 16 Spill 14% Vehicle Overfill 6% Human Intervention 2% Loose Component Other 14% 2% Corrosion 5% Overfill 25% 4 19 Mechanical Damage 2% Human Error 6% Component Failure 2% Shop-fabricated AST Systems Unknown 9% Apr 07

60 Causes of Discharges from Tanks Overfills 66% Physical Damage 4% Unknown 14% Apr 07 Corrosion 1% Spill 11% Human Error 1% Improper Installation 3% Shop-fabricated AST Systems 2 8 Human Error 1%

61 Causes of Discharges from Piping, Different Types of Piping Single-wall Unspecified 43% 22 2 Single-wall Fiberglass 4% 4 Single-wall Underground Steel 8% Apr 07 3 Double-wall Fiberglass 60% Doublewall Steel 2% 1 7 Double-wall Flexpipe 14% 2 9 Bulk Product Piping 4% Shop-fabricated AST Systems Single-wall Aboveground Steel 18%

62 Leak Autopsy Reports Received Tank is the Source 15 Shop-Fabricated Tanks < Tanks

63 Leak Autopsy Reports Received Piping is the Source < Piping

64 Compliance

65 DEP Regulates Storage Tank Systems

66 USE APPROVED EQUIPMENT!

67 Equipment Approvals

68 Tanks

69 Installation Date Ranges for all Registered Florida Facilities with Field-erected ASTs Year Constructed Facilities with 2144 Tanks >50,000 gallons ( liters) Nov 06

70 Storage Tank Facilities by Tank Content Jet Fuel 18% Nonvehicular Diesel 10% New Oil 2% Mineral Acid 12% Source: STCM Nov 06 Aviation Gasoline 2% Vehicular Diesel 13% Gasoline 18% Other 5% Grade #2 Fuel Oil 3% Grades #5 & #6 Fuel Oil 15% Waste Oil/Used Oil 2%

71 Field-Erected AST Installation Exterior Coatings

72 Tank Shell Welding Quality work is essential! Bottom plates

73 Piping Connections, Sumps, Manways, & Shell Penetrations

74 Reference Standards- API-650 Cathodic Protection

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91 Roof vents Cutting the shell New bottom construction Pre-painting

92 All new tanks must have secondary containment beneath the tank and in the dike-field around the tank*

93 Petroleum Contact Water Tanks Must meet construction standards except for secondary containment

94 Shop-fabricated tank installation

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96 Issues in selecting the type of shop-fabricated tank best-suited for your needs: Storage volume needed Site security Available space Piping needs Dispensing needs Portability Regulation Cost Operation and maintenance issues Risk assessment fire safety, hurricanes, hunters

97 Do the job right!

98 Do the job right with Qualified Personnel!

99 AST Secondary Containment

100 Liners beneath the tank Internal Secondary Containment Tank Lifting El Segundo bottoms Field-erected AST Secondary Containment Options Double-Bottoms

101 Field-erected AST Lifting for secondary containment installation beneath the tank

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104 Synthetic liner in dike field area Field-erected AST Dike-field Secondary Containment

105 Concrete AST Dike-field Secondary Containment - Field-Erected Tanks Double-walled Synthetic Liner Alternative Dike-field containment

106 Alternative Dike Field Secondary Containment Signal Processor AIR OIL Tank Automatic Shut-Off Valve Hydrocarbon Sensor Sump WATER Operator Drain Pipe Tank Slab Foundation

107 Eco-Tank TABs-02 System T.R.A.P.S. System Alternative Dike Field Secondary Containment

108 Shop-fabricated ASTs needed to have secondary containment by January 1, 1990 New tanks need secondary containment at the time of installation

109 AST Secondary Containment - Shop-fabricated Tanks

110 Piping

111 Piping - The major source of Field-erected AST leaks...

112 Small Diameter Piping with Secondary Containment steel Semirigid

113 Be sure to install the proper valves for shop-fab ASTs with STPs serving dispensers

114 Piping above grade Fiberglass Liner Penetrations

115 Steel Bulk Product Piping with Secondary Containment

116 Steel Bulk Product Piping with Secondary Containment - Installation concerns

117 Airport Hydrant Piping

118 Hydrant Pits Isolation valve pits

119 Hydrant Piping

120 Seaport Hydrant Piping

121 AST Spill Protection

122 Gauges AST Overfill Protection

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124 The January 1, 2010 Deadline for Secondary Containment

125 Table AST Chapter , F.A.C. Year Installed Before the P TVX W U effective date of the rule

126 Field-erected ASTs with Secondary Containment 83% Upgrade status Field-erected ASTs March, 2008 Source - STCM, Mar 08 Single-wall Field-erected ASTs - 17%

127 Internal Corrosion AST Upgrade Problems Liner installation Human Error External Corrosion

128 By January 1, 2010 Bulk Product & Hydrant Piping, unless deferred by API 570 Secondary Containment Internallylined tanks

129 DEP has never extended a deadline Over 80% have upgraded, DEP would be sued if they extended the deadline Supply and demand The longer you wait, the more demand for and the less available the supply of qualified installers of AST secondary containment Supply and Demand The longer you wait, the more demand for and the more expensive the tank and piping system The Rumors are Wrong

130 Don t Wait to Upgrade!

131 Release Detection Standards

132 You have a choice of methods for single or double-wall systems Release detection must be performed monthly Anything that can be visual inspected must be visually inspected Secondary containment systems must have interstitial monitoring You must have an RDRL a Release Detection Response Level established for major components You must keep records of your findings Release Detection General Requirements

133 Performance Standards for Release Detection Methods General. Methods of release detection shall: Be capable of detecting a leak of 0.2 gallons per hour or 150 gallons within 30 days with a probability of detection of 0.95, and a probability of false alarm of 0.05, with the exception of tightness testing, visual inspections, groundwater or vapor monitoring; and manual tank gauging. Be approved in accordance with Rule (2), F.A.C. Have a release detection response level described in writing.

134 Internal Release Detection for Single-wall Systems NONE

135 External Release Detection for Single-wall Systems Well construction Site Suitability Groundwater monitoring wells Vapor monitoring wells

136 External Monitoring Directionally-drilled fiberoptic or cable systems that can detect new discharges above background levels of contamination

137 Release Detection for Double-wall Systems Internal Interstitial Monitoring Visual Vacuum Pressure Hydrostatic Sensors & Probes

138 Interstitial Monitoring for tanks and piping Interstitial monitoring

139 Vacuum Gauges

140 Recommendation for Release Detection First Class Version Vacuum or Pressure Continuous Monitoring

141 Recommendation for Release Detection The Economy Version Visual Inspections!

142 Success of Leak Detection Florida Cause of Leak Study % Detected 51% Failed 23% Unable or Unknown

143 Success of Leak Detection March 06 29% 39% Detected Failed 32% Unable or Unknown

144 Success of Leak Detection Mar 08 22% 35% Detected Failed 43% Unable or Unknown

145 Notification

146 Notification The County (DEP s Contractor) must be given a verbal or written notice within: 30 days of installation or upgrading 10 days before internal inspections or closure And an additional notice within 48 hours of the above 30 days after installation, complete DEP Registration Form for change of ownership, closure, upgrading, facility info, including financial responsibility

147 Registration

148 Registration Owners must register with FDEP 30 days after regulated substances are put into the system. Fees - $25/year/tank < 250,000 gallons - $1 per 10,000 gallons > 250,000 gallons Questions? Call:

149 Hazardous Substance ASTs Registered, but not Regulated Must pay Registration Fees Pressure Vessels

150 Financial Responsibility

151 Financial Responsibility References EPA Requirements. One million dollars coverage required for petroleum marketers (cleanup and third party liability). $500,000 coverage required for non-marketers. Use FR Allowable Mechanisms - Letter of Credit, Surety Bond, Insurance, etc. Only for petroleum storage systems. State & Federal facilities are exempt

152 $1,000,000 dollars/incident, $3,000,000 annual aggregate Large tanks, three million/six million Financial Responsibility

153 Repairs, Operation, and Maintenance of Storage Tank Systems

154 Repairs Short-cuts don t always work, and you get what you pay for

155 Repairs Hire qualified people with good references

156 Impressed Current System Cathodic Protection Installing anodes

157 Operation & Maintenance

158 Dike-field Maintenance

159 Internal lining General O & M Piping connection drip-protection Fuel filters

160 Internal lining Stormwater management Stormwater retention and removal, and dike field liners Overfills and inadequate containment

161 API 653 Inspections

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163 API 570 tests for Bulk Product Piping

164 Unusual Situations

165 Recordkeeping

166 RecordKeeping Most records kept for two years, others for the life of the system

167 Recordkeeping Keep a spiral notebook of visual inspections Keep a tabbed notebook of all other records required by the Department Photo-document if possible Keep DEP Registration Information up-to-date

168 Out-of-Service and Closure Requirements

169 Out-of-Service Single-wall 2 years Double-wall 10 years Tanks must be empty!

170 AST Out-of-Service

171 AST Closure Two Choices Removal, or abandonin-place

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173 A Petroleum Storage System Contractor (PSSC) certified by the Department of Business and Professional Regulation IS NOT REQUIRED

174 Closure Assessments Recommendation: Hire a qualified, experienced professional environmental consulting firm

175 Incident and Discharges

176 Incident and Discharge Reporting Discharges Incidents

177 Incidents Discharges Confirmed Release Unusual operating conditions Stained soils

178 Incident & Discharge Response Tank bottom leak that remains in the dike-field - incident Overfill outside of the dikefield - discharge Assessment well drilling - discharge

179 Incident Response Complete Form #6 within 24 hours or the close of the next business day perform an investigation and notify the County of the results within two weeks

180 Discharge Response Complete Form #1 within 24 hours or the close of the next business day control and abate the discharge

181 Need a time extension for closure? Have a better way of meeting a DEP rule? Alternate Requirements

182 Ammonia Storage Tanks

183 Mineral Acid Storage Tank Requirements

184 Mineral Acid Storage Tanks Phosphoric Acid Tank Sulfuric Acid Tank 800,000 Gallon Discharge

185 Phosphoric Acid Hydrochloric Acid

186 Storage Tank Forms

187 Storage Tank Forms Discharge Report. Storage Tank Facility Registration. Certification of Financial Responsibility. Alternate Procedures. Incident Notification. Limited Closure Summary Report

188 Petroleum Discharge Report Forms Received Discharges 6254 Source: STCM, Apr 09 ASTs and USTs <80 '81 '83 '85 '87 '89 '91 '93 '95 '97 '99 '01 '03 '05 '07 35,023 Discharge Report Forms Received

189 Post-1998 Petroleum Discharge Report Forms Received Discharges Source: STCM, Apr ASTs and USTs '98 '99 '00 '01 '02 '03 '04 '05 '06 '07 '08 ' Post-1998 Discharge Report Forms Received

190 The End

191 Atlas Fueling Systems Eco-Station

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