Storage Tank Risk Management Solutions Leak Prevention and Tank Integrity Inspections for ASTs Brian Pine ATC Group Services NISTM 8th Annual Pennsylvania Storage Tank Conference 1
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ATC GROUP SERVICES IN OUR REGION What is ATC Eclipse? Centered in Retail and Bulk Petroleum and Chemical Marketplace Compliance Services ~Tank Inspections ~Sump Inspections Petroleum Field Services ~Installations ~Repairs PADEP Certifications: IAM IUM UMX UTT AMMX AMNX AMR 3
TOPICS What a good system looks like Regulations, State and Federal Prevention is the Key The most probable cause of a spill What happens when a spill occurs, anatomy of spill response Spill event case studies Photographs 4
GOOD SYSTEM Anti-Siphon Product Identifier Labels 5
GOOD SYSTEM Normal Vent 3 Product Fill 3 Primary and Secondary E-Vents 6
GOOD SYSTEM Block Valve, Anti-Siphon Valve (PEI RP 200) Spill Cabinet (Emergency Containment) 7
REGULATIONS FOR LEAK DETECTION AND SPILL PREVENTION 8
STATE/FEDERAL AST LEAK DETECTION/ SPILL PREVENTION REGULATIONS - PENNSYLVANIA State of Pennsylvania 25 Pa Code 245 Storage Tank and Spill Prevention Program Subchapters F (large) and G (small) Aboveground Storage Tanks 245.541 Overfill Prevention Requirements Gauge or monitoring device, AND High level alarm with cut off device or manned operator shut down written procedure 245.542 Containment Requirements 245.543 Leak Detection Requirements (large tanks) Existing ASTs without secondary containment under the bottom of the tank that are in contact with soil without CP or internal lining shall be leak tested at the next IS and each IS inspection thereafter until upgraded 245.613 Monitoring Standards (small tanks) Monthly leak detection monitoring required 9
PENNSYLVANIA INSPECTION STATISTICS 2016 AST Inspections in PA* 919 Aboveground Storage Tank Integrity Inspections in PA (performed by 3 rd party DEP certified inspectors) 136 Monthly Maintenance Check Violations (performed by owners/operators) 698 Performance/Design Standards Violations (paint surface coating, label, vents, etc.) 183 Containment Violations *Statistics provided by PADEP, some tanks had more than 1 violation. 10
PADEP MONTHLY INSPECTION FORM 11
PADEP THIRD PARTY INSPECTION FORM 12
PADEP VIOLATIONS: DESIGN STANDARD VIOLATIONS 13
PADEP CONTAINMENT VIOLATIONS 14
STATE/FEDERAL AST LEAK DETECTION REGULATIONS WEST VIRGINIA State of West Virginia West Virginia Code Aboveground Storage Tank Act 22-30 Each regulated Level 1 and 2 aboveground storage tank and its associated secondary containment structure must be evaluated and certified by a qualified person, as described below: professional engineer, American Petroleum Institute (API), or Steel Tank Institute (STI) certified individual API 653 Leak Detection: STI Leak Detection: CONTINUOUS RELEASE DETECTION METHOD (CRDM) a means of detecting a release of liquid through inherent design. Several acceptable and commonly used CRDM systems are as follows: Release prevention barrier (RPB) (described in definition of release prevention barrier). Secondary containment AST, including double-wall AST or double-bottom AST. Elevated AST, with or without release prevention barrier. RELEASE PREVENTION BARRIER (RPB) a liquid containment barrier that is installed under the AST. Its purpose is to divert leaks toward the perimeter of the AST where they can be easily detected, as well as to prevent liquid from contaminating the environment. RPBs are composed of materials compatible with the liquid stored in the AST and meet appropriate engineering standards. Examples are steel (as in steel double bottom tanks), concrete, elastomeric liners or other suitable materials, provided the above criteria are met. 15
WEST VIRGINIA, FIT FOR SERVICE? 16
STATE/FEDERAL AST LEAK DETECTION REGULATIONS EPA SPCC Federal EPA SPCC (Spill Prevention, Control and Countermeasures) 40 CFR 112 applicability simplified: 1. Is your facility non transportation related? 2. Is your facility engaged in drilling, producing, gathering, storing, processing, refining, transferring, distributing, using or consuming oil? 3. Could your facility reasonably be expected to discharge oil in quantities that may be harmful into navigable waters or adjoining shorelines? 4. Is the total aggregate capacity of aboveground oil storage containers more than 1,320 gallons of oil? Your facility is subject to the SPCC rule. 112.7(e),112.8(c)(6), 112.12(c)(6)(i) Test or inspect each aboveground container for integrity on a regular schedule.. Conduct inspections and tests. Industry Standards API 653, STI SP001 > Leak Detection and Containment! 17
SPCC = SPILL PREVENTION CONTROL & COUNTERMEASURE Prevention is the primary goal of your spill plan How to prevent spills from occurring? Proper Design Frequent Inspections Regular Maintenance Training Awareness + Planning = Prevention 18
PREVENTION IS THE KEY 19
MOST PROBABLE CAUSE OF SPILLS Cause Tank Corrosion Overfill Prevention Method Inspection Planning Design Training Piping/Fitting Failure Inspection/Maintenance Most spills are preventable! 20
INTERNAL CORROSION AND PITTING A multi-billion $$ industry was built around USTs with holes in them We have an advantage with ASTs we can inspect them from the outside 21
CORROSION ANALYSES - UT TESTER API 653 Corrosion Rate Calculations The minimum acceptable shell thickness (Tmin) is determined using the following Equation: t min = 2.6D(H-1)G / SE Per API 653, T(min) shall not be less than 0.1 inch for any tank course Pitted Corrosion Install Date Original Thickness Min Field Thickness Corrosion Loss Mn Thick API 653 Inspection Interval Rate of Corrosion RCA (t a -t min ) Remaining Tank Life Course (t o ) inches (t n ) inches (inches) (tmin) inches (years) (in/year) (inches) (years) shell Apr-03 0.25 0.244 0.006 0.1 13.5 0.00044 0.144 324.00 end cap Apr-03 0.375 0.32 0.055 0.1 13.5 0.00407 0.220 54.00 22
WHEN A SPILL OCCURS: ANATOMY OF A SPILL RESPONSE Phase I Notification and Initial Response Phase II Containment and Source Removal Phase III Plan Review and Amendment EPA inspection and enforcement Phase IV Long Term Remediation 23
PHASE I NOTIFICATION AND INITIAL RESPONSE STOP the release if you can do so safely. ELIMINATE sources of ignition. NOTIFY local, state and Federal agencies Local FD State notification: one drop to multiple gallons All states and EPA: sheen on surface water Failure to notify is a MAJOR violation and will become an enforcement penalty multiplier and/or criminal violation Get HELP! Don t skimp at this point to save $$ 24
PHASE I (CONT.) What Spilled? Material released (MSDS) Quantity released Where did the spill go? (Hint: this is part of your SPCC Plan) Containment? Catch basin? Groundwater? Surface water? 25
PHASE II CONTAINMENT AND SOURCE REMOVAL Contain the release What happens if it rains/snows? Can more oil leak from the tank system? Have pathways to surface waters been identified and protected? Can you prevent further impact to groundwater? Source removal Timing is everything. The faster you remove the source, the lower the overall cost 26
SOURCE REMOVAL YOUR BEST INVESTMENT ( AFTER PREVENTION) Recover as much oil before it migrates vertically/horizontally Timeframe: minutes to hours After liquid recovery, excavate as much soil as you can Timeframe: hours to days Whatever is left will need to be mechanically extracted, treated in situ, and/or monitored Timeframe: months to years 27
PHASE III PLAN REVIEW AND AMENDMENT Evaluate your SPCC plan Is the Plan up to date and fully implemented? Are upgrades required to tanks or containment? After a spill occurs is not a good time to start your compliance program EPA and/or your state regulators will likely conduct an inspection If you don t have a plan, you will now!!! 28
PHASE IV LONG TERM CLEANUP Floating product recovery Soil and groundwater remediation Monitoring and reporting Risk assessment and closure planning What you do in Phase I and II determines the duration and costs of Phase IV 29
CASE STUDIES WHEN PREVENTION FAILS 30
CASE STUDY #1 PIPING RELEASE AT BULK PLANT 615 gallons fuel oil released at a rural VT bulk facility 31
THE GOOD Tanks on concrete pads Written SPCC Plan in place ( but not implemented) 32
THE BAD Excessive flex of a flex coupling caused a stress fracture in fitting Note: Potable water valve used for petroleum service 33
THE UGLY 615 gallons discharged to containment Containment floor insufficiently impervious 34
VAC TRUCK AND PUMPING SYSTEM 35
DESPITE QUICK RESPONSE Sheen detected in nearby stream 36
FORENSIC ANALYSIS Improper design of piping, valve and containment structure SPCC plan not fully implemented Customer responded to spill once detected, but not before sheen was detected on stream This was the 2 nd spill reported to EPA in a 4 year period HINT: It all goes downhill from here 37
EPA ENFORCEMENT ACTION Resultant RCRA Facility Investigation: Included all 5 company facilities Multiple violations resulted in a $157,500 penalty PLUS, structural and administrative upgrades required $350,000 spent within 9 months Million gallon tank with inadequate containment and no FRP dismantled Containment upgrades at 2 facilities SPCC Plans revised at all facilities Contaminated soil uncovered during upgrades 38
CASE STUDY #2 OVERFILL Bulk Storage Tank connected to Pipeline Operator thought that he would have time to go to the bar across the street for a quick beer Bartender points to diesel shooting out tank vent Operator runs back to terminal to close valve Diesel? 39
CASE STUDY #2 OVERFILL CONTINUED Operator on site, not drinking beer? 40
CASE STUDY #2 OVERFILL CONTINUED 23,000 gallons diesel released to containment (steel sides, soil bottom) 14,000 gallons recovered by vac truck 9,000 gallons lost to subsurface Containment steel sides, soil bottom Groundwater at 23 feet 3.9 feet of LNAPL in 14 wells within 2 weeks 41
SPILL PREVENTION > CLEANUP IS ONLY PART OF THE COST Loss of Inventory Loss of Equipment Use / Revenue Generation Administrative Hassle Financial Penalties Loss of Reputation Natural Resource Damages Loss of Business Criminal Penalties Loss of Life 42
FIELD INSPECTION FINDINGS ~ DO YOU HAVE CONTAINMENT? 43
FIELD INSPECTION FINDINGS ~ CONTAINMENT???? 44
FIELD INSPECTION FINDINGS ~ SW OR DW TANK? Two E-Vents 45
FIELD INSPECTION FINDINGS ~ SW! Interstice is full of water, no containment of the primary tank 46
FIELD INSPECTION FINDINGS ~ CHECK THE INTERSTICE! 47
FIELD INSPECTION FINDINGS ~ CHECK THE INTERSTICE! 48
FIELD INSPECTION FINDINGS ~ CHECK THE INTERSTICE! 49
FIELD INSPECTION FINDINGS ~ BLOCK VALVE POSITION CORRECT? No PEI RP 200 The first accessible valve.be constructed of steel..capable of withstanding a reasonable degree of stress created by a fire condition. 50
FIELD INSPECTION FINDINGS ~ DOES THIS TANK HAVE PROPER EMERGENCY VENTING? No Wire tie 51
Questions??? 52