Storage Tank Systems for Petroleum Products and Allied Petroleum Products Regulations

Transcription

1 Storage Tank Systems for Petroleum Products and Allied Petroleum Products Regulations ESAM Lunch and Learn Dartmouth, NS October 12, 2016 Part 2 of 2

2 Outline of Presentation 1. Purpose of the Regulations 2. Authority 3. Application 4. Responsibility 5. Critical Timelines 6. Definitions 7. Overview of the Regulations 8. Summary 9. Resources Page 252 October 12, 12, 2016

3 7.5 Leak Detection Leak detection Should be part of regular operation and maintenance of storage tank system Page 53 October 12, 2016

4 7.5 Leak Detection What are the leak detection requirements? Leak detection by June 12, 2010 Ongoing leak detection or monitoring on prescribed frequency Page 54 October 12, 2016

5 7.5 Leak Detection Single-walled underground storage tanks: Precision leak test by June 12, 2010 Then: annual precision leak test, or use automatic tank gauging, or use continuous in-tank leak detection Page 55 October 12, 2016

6 7.5 Leak Detection Horizontal aboveground storage tanks without secondary containment: Visually inspect walls for leaks by June 12, 2010 Then: annual precision leak detection test, or monthly visual inspection of walls and inventory reconciliation at least weekly, or continuous in-tank leak detection, or continuous external leak monitoring Page 56 October 12, 2016

7 7.5 Leak Detection Vertical aboveground storage tanks without secondary containment: Specified inspection by June 12, 2010 Then: specified inspection at ten year intervals, or use continuous in-tank leak detection, or use continuous external leak monitoring as prescribed Page 57 October 12, 2016

8 7.6 Product Transfer Areas s.1 transfer area means the area around the connection point between a delivery truck, railcar, aircraft or vessel and a storage tank system in which the tanks have an aggregate capacity of more than L. spill means any loss of a petroleum product or an allied petroleum product in liquid form from a storage tank system, including a loss during a transfer of such a product to or from a storage tank system, but not including a loss that does not reach outside the storage tank system s secondary containment. Page 58 October 12, 2016

9 7.6 Product Transfer Areas s.15(1) The owner or operator of a storage tank system must ensure that petroleum product and allied petroleum product transfer areas are designed to contain spills that occur during the transfer process. Page 59 October 12, 2016

10 7.6 Performance Based approach Performance-based requirements: state the objective let stakeholders determine how to achieve the objective allow flexibility for unique situations PTA design should include a combination of: Permanent or temporary physical containment Standard operating procedures to reduce risk Training The owner/operator should be able to explain how the PTA is designed to contain spills. Page 60 October 12, 2016

11 7.6 Recommended Steps to Design a PTA 1. Assess the storage tank system and its surrounding environment 2. Identify potential accidents that could happen during product transfer 3. Design ways to prevent and contain spills 4. Implement and test the design 5. Document the results 6. Revise the design if changes are needed Page 61 October 12, 2016

12 7.6 PTA design process Assess STS and environment Revise as necessary Identify potential for spills Document the results Design spill management Implement and test design Page 62 October 12, 2016

13 Step 1: Assess the STS and its Environment Aspects of the STS and its environment to assess: Site Site history Equipment Delivery vehicle Operating Procedures Page 63 October 12, 2016

14 Step 2: Identify potential accidents that could happen during product transfer Some spill scenarios and their resultant spill volumes: Fuel delivery vehicle striking tank causing catastrophic failure High volume, up to the volume of the tank itself and possibly the volume of the truck as well Spill from hose becoming uncoupled during delivery Volume based on flow rate, and time before shut-off Spill from hose being incorrectly uncoupled at truck. Volume of the hose. A hose 10 feet long with a 4 inch diameter will contain approximately 25 L of product. Page 64 October 12, 2016

15 Step 3: Design ways to prevent and contain spills Examples of preventative measures that could be incorporated into a PTA design: Prevention: Standard operating procedures (SOP) based on the CPPI Professional Driver s Manual (2009) collision protection installed as per the National Fire Code of Canada. personnel training Page 65 October 12, 2016

16 Step 3: Design ways to prevent and contain spills The PTA should be designed to contain the largest spill volume from previously identified potential incidents. Here are some examples of containment measures that could be incorporated into a PTA design: Containment: Dikes around the paved area that can contain spills, as well as SOP that require blocking the drain during refuelling Sloped pavement so that any run-off would go into a sump or oilwater separator For a gravel surface install a geomembrane liner under a few inches of the gravel that would contain spills deploy a temporary berm during fuelling at both connection points Page 66 October 12, 2016

17 Step 3: Design ways to prevent and contain spills Page 67 October 12, 2016

18 Step 4: Implement and test your design Use water to simulate the conditions of a likely spill scenario. The amount of water used should be the likely spill volume previously identified. Page 68 October 12, 2016

19 Step 5: Document the results Good documentation helps demonstrate compliance. Good documentation includes: Site assessment Volume calculations for spill scenarios Plans for containing spill volumes Pictures and records of testing Pictures of operational methods where applicable Along with anything else that will demonstrate how your PTA has been designed, implemented, and how it will manage product transfer. Page 69 October 12, 2016

20 Step 6. Revise the design if changes are needed Evaluate the PTA test results Identify any problems Update the PTA to address the problems Test the updated PTA as needed Document as required Repeat this process as necessary Page 70 October 12, 2016

21 Example: Whale Tank - Secured Site Page 71 October 12, 2016

22 Example: System Protection Page 72 October 12, 2016

23 Example: Connection Point Impact Protection Page 73 October 12, 2016

24 Example: Normally-Open Catchment Drain Page 74 October 12, 2016

25 7.7 Emergency Plans in general Identify potential hazards, establish systems for preventing leaks/spills and provide mechanisms for minimizing risk, loss and damage In the event of leak/spill provide owners, operators and emergency response personnel with guidance for a timely and effective response (e.g. to minimize health, safety and environmental impacts) Page 75 October 12, 2016

26 7.7 Emergency Plans in particular The emergency plan must be keep up-to-date The emergency plan must be ready to be implemented A copy must be located where the storage tank system is located if that place is a place of work When identifying a storage tank to ECCC, the owner or operator should inform ECCC of the civic address of each location where the emergency plan is kept Page 76 October 12, 2016

27 7.7 Emergency Plans components Emergency Plans can differ greatly in their structure depending on a number of factors (e.g. # of tanks, size of organization, site characteristics, etc.), but effective plans have many things in common An emergency plan must be prepared for each STS Page 77 October 12, 2016

28 7.7 Emergency Plans - Details Considerations for preparation of emergency plans s. 30(1) Product stored: Properties Characteristics Max Quantity Site and surrounding area: Characteristics Risk of harm Page 78 October 12, 2016

29 7.7 Emergency Plans - Details Contents of plan s. 30(2) Description of factors considered under s. 30(1) Description of measures taken to prevent, prepare for, respond to and recover from any emergency List of individuals to implement plan, including roles Identification of training required List of emergency response equipment and their location Measures to notify members of the public Page 79 October 12, 2016

30 7.7 Emergency Plans Tell Environment and Climate Change Canada the locations where emergency plans are kept. Notification can be done by: to fax to inputting Identification Form data in FIRSTS Page 80 October 12, 2016

31 7.7 Emergency Plans Considerations for assembling a Spill Kit: Location of kit Secure container (weighted, breakable seal) Volume of the worst case PTA spill Land based or water based spill Some absorbents pick up all liquids, some will pick up hydrocarbons but will not absorb water Containment items: booms, pillows, pads, particulate The inclusion of PPE (packed at top of kit) Traffic cones, flagging tape, etc. Page 81 October 12, 2016

32 7.7 Emergency Plans in context Emergency Plan Product Transfer Area Spill Kit Spill Containment Page 82 October 12, 2016

33 7.8 Approved Installers Province Require licensed installer contractor? NS Yes Yes Require licensed removal contractor? NB Yes Yes PEI Yes Yes NL No No If no - supervised by professional engineer Page 83 October 12, 2016

34 7.9 Operation and Maintenance Regular Operation and Maintenance is the key to safe & environmentally responsible operation of your storage tank system -e.g. empty water from secondary containment The regulations have specific requirements for oil-water separator maintenance and disposal from oilwater separators. Page 84 October 12, 2016

35 7.9 Operation and Maintenance Do not use secondary containment for storage! Page 85 October 12, 2016

36 7.10 Release Reporting Spill reporting requirements s.41 Verbal notification as soon as possible Atlantic Canada Newfoundland and Labrador Written follow-up for spills 100 litres or larger Page 86 October 12, 2016

37 7.11 Withdrawal from Service Temporary withdrawal s.43 Either returned to service (<2 yrs) or becomes permanent Cathodic protection maintained If withdrawn for > 1 year Precision leak detection for USTs or shop-fabricated ASTs Internal inspection for field-erected ASTs Label affixed to fill pipe Keep record with date of withdrawal Page 87 October 12, 2016

38 7.11 Withdrawal from Service Permanent withdrawal s.44 Remove and dispose of liquids and sludge Vapours purged to less than10% of lower flammability limit (verify via combustible gas meter) No immediate or long-term harmful effects Label affixed to fill pipe Keep record with date of withdrawal Written notification to Minister within 60 days Must be removed, except field erected Page 88 October 12, 2016

39 7.11 Withdrawal from Service Removal of system s.45 Must be completed by approved person or supervised by P.Eng. Appropriate records kept Page 89 October 12, 2016

40 7.12 Record Keeping ID & New installations ID of system s.28(2) Information and certification Schedule 2 Design and construction records Installer or supervision s.33(2) Design plans, drawings & specifications s.34(1) As-built drawings s.34(2) Keep these for the life of the tank! Page 90 October 12, 2016

41 7.12 Record Keeping Operation and maintenance Leak tests or inspections of any component Free oil and separated solids thicknesses for oil-water separators Disposal of free oil and separated solids and liquid discharge from oil-water separators Disposal of tank bottom water Keep for 5 years Page 91 October 12, 2016

42 7.12 Record Keeping Emergency plans and releases Up-to-date emergency plan both on-site and available to responsible persons s.31(1) Spill report for product 100 liters or larger s.41 Keep copy of spill report Page 92 October 12, 2016

43 7.12 Record Keeping Temporary withdrawal Date of withdrawal s.44(2) Proof of operation of cathodic protection system s.43(a) Results of leak tests or inspections on tanks out of service for more than a year Page 93 October 12, 2016

44 7.12 Record Keeping Permanent withdrawal and removal Date of withdrawal s.44(2) Withdrawal by approved person or supervised by P.Eng. s.44(1) Liquid and sludge disposal s.44(3) Proof of tank purge s.44(3) Page 94 October 12, 2016

45 8. Summary - For storage tank systems: Identify the system Leaking systems temporarily withdraw from service and manage as needed Product Transfer Area & Emergency Plan Arrange for removal of single-walled underground tanks and piping as necessary Removals and installations by approved people Evaluate tanks systems against high risk criteria and manage as needed Arrange for leak detection as needed (one-time and ongoing) Report all spills Keep records of above Page 95 October 12, 2016

46 9. Resources EC s Storage Tank website for Petroleum and Allied Petroleum Products includes Contact Information and Fact Sheets (Tank Tips) CCME Environmental Code of Practice for Aboveground and Underground Storage Tank Systems Containing Petroleum and Allied Petroleum Products Compliance and Enforcement Policy for the Canadian Environmental Protection Act, National Fire Code of Canada html Page 96 October 12, 2016

47 For Information Please Contact Chris Feetham Senior Compliance Promotion Officer, Environmental Stewardship Branch Environment and Climate Change Canada / Government of Canada chris.feetham@canada.ca / Tel: Agent principal en promotion de la conformité, Direction générale de l'intendance environnementale Environnement at Changements climatiques Canada / Gouvernement du Canada chris.feetham@canada.ca / Tél. : Page 97 October 12, 2016