Pennsylvania DEP Aboveground Storage Tank Facility Visits NISTM PA CONFERENCE Washington, PA May 18, 2017

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1 Pennsylvania DEP Aboveground Storage Tank Facility Visits 2017 NISTM PA CONFERENCE Washington, PA May 18, 2017

2 What one may expect Documentation review Tank system visual assessment Follow-up

3 PADEP AST Facility Site Visits Why do we show up? Review of AST Integrity Inspection Summaries (Follow-up Inspections) Anonymous tips from all kinds of sources (Compliance Evaluation Inspections) PADEP-certified third party installers/inspectors evaluations (Performance Evaluations) Release (Incident-Response to Accidents or Events) Because we can visit any regulated aboveground storage tank facility at any time (Compliance Evaluation Inspections)

4 RECORDS

5 AST Monthly Operations and Maintenance Checks Record Keeping Requirements Monthly leak detection records and maintenance checklists shall be maintained for the previous 12 months.

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7 Records Spill Prevention Response Plans (SPRPs) are required when the aggregate capacity of all regulated ASTs exceed 21,000-gallons SPCC plans are not necessarily SPRP Plans. (20 mile downstream users notification and notification list required annually) Operation and maintenance plans are an integral part of the SPRP, and are also required for large storage tank facilities Doesn t always need to be a stand alone document, but make sure that it s included with the SPRP, if it is not.

8 Other records requested Tank installation, inspection, modification report summaries Tank manufacturer installation instructions Other permits (Labor and Industry, Local permits, etc.) Facility gate logs Project bids, scope of work, contracts, etc. Cathodic protection testing Safety Data Sheets Others?

9 Let s take a look at what is within the emergency containment area.

10 The obvious violations

11 The obvious violations

12 Why don t you need to use your containment drain?

13 Thoughts on containment walls constructed with concrete masonry units?

14 Closing of emergency containment drain valves or plugs after water is removed from emergency containment.

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16 What are the most common violations??? LABELING External Deterioration Protection

17 More common violations??? No spill containment at fill point Wood support No block valve at top of the tank Bronze block valves can t be used

18 Wood you believe this AST had no compliance issues identified by the PADEP-certified inspector?

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20 They had an operating permit for decades

21 Emergency Venting Violations Common Problems 1. Inadequate design too small, wetted area calculations 2. Not functioning shear pin replaced, won t lift 3. Long bolt manholes needs to have the ability to lift 4. Frangible roof won t work for smaller diameter ASTs 5. Double walled tanks Primary and secondary both need e-vents

22 Emergency Venting 5 Common Problems - Inadequate design not sized properly or just bad math

23 Emergency Venting Common Problems - shear pin broke

24 Emergency Venting Common Problems manway lids bolted down won t lift under excess pressure

25 Emergency Venting Common Problems frangible roof may not work on some smaller diameter (<50 feet) ASTs. *Refer to API 650 (Section ) for design considerations

26 Emergency Venting Common Problems Double walled ASTs with no emergency vent for the secondary tank (F&C liquids)

27 Many of the violations discussed up to this point could have been prevented by BETTER TANK MAINTENANCE

28 Other Items to Consider for Maintenance Checks Aboveground storage tank grounding/bonding Fuel monitoring (check for presence of water/microbes) Cathodic Protection Rectifiers Thermal and pressure relief systems Insulated ASTs check for areas of moisture, external corrosion Follow-up on Unsatisfactory and/or Required items

29 Monthly Maintenance Checks Good idea to keep up with the Temporarily Out of Service Tanks

30 The Follow-up Field Narrative (most issues are resolved this way) Notice of Violations (NOVs) Most of the remaining enforcement actions Consent Assessment of Civil Penalty Consent Order and Agreements Field Orders Administrative Orders

31 How much of a penalty can the PADEP assess? Per Chapter 13 Section 1307 of the PA Storage Tank and Spill Prevention Act of 1989 (a) Assessment.--In addition to proceeding under any other remedy available at law or in equity for a violation of a provision of this act, rule, regulation, order of the department, or a condition or term of any permit issued pursuant to this act, the department may assess a civil penalty for the violation. This penalty may be assessed whether or not the violation was willful. The civil penalty so assessed shall not exceed $10,000 per day for each violation. In determining the amount of the penalty, the department shall consider the willfulness of the violation; damage to air, water, land or other natural resources of this Commonwealth or their uses; cost of restoration and abatement; savings resulting to the person in consequence of the violation; deterrence of future violations; and other relevant factors. Each violation of any provision of this act, rule, regulation, order of the department or condition of a permit, and each day of violation shall constitute a separate violation.

32 So how does the PADEP Division of Storage Tanks calculate the amount of the assessed penalty?

33 THE PENALTY ASSESSMENT MATRIX

34 Guidance PADEP Resources: Storage Tank and Spill Prevention Act. Act of Jul. 6, 1989, P. L. 169, No. 32 Title 25, Pa Code, Chapter 245. Administration of the Storage Tank and Spill Prevention Program. January 7, Verification of Emergency Containment Structures for Aboveground Storage Tanks September 8, Permeability of Secondary and Emergency Containment September 8, Guidelines for the Development and Implementation of Environmental Emergency Response Plans August 6, Penalty Assessment Matrix September 8, 2012.

35 THANKS FOR YOUR ATTENTION ANY QUESTIONS?

36 Chad Clancy AST Unit Supervisor Bureau of Environmental Cleanup and Brownfields Rachel Carson State Office Building PO Box 8763 Harrisburg, PA