THE KEY RELATIONSHIPS BETWEEN FIRE CODES, NEW YORK AST REGULATIONS AND SPCC PLANS Presented by: Joyce A. Rizzo President JD2 Environmental, Inc. 800 East Washington Street West Chester, PA 19380 www.jd2env.com
SPCC LANGUAGE The SPCC rules were significantly updated in January 2010 from the very general requirements of the 1973 original rules. But the rules are still conceptual with respect to most aspects and basically do not include design or engineering specifications. Technical determinations are basically the responsibility of the certifying engineer.
112.3(d) Professional Engineer (P.E.) Certification P.E must attest that: The P.E. is familiar with requirements. The P.E. or his/her agent has visited the facility. The Plan is prepared in accordance with good engineering practice, consistent with applicable industry standards and 40 CFR 112. Procedures for inspections and testing have been established. The Plan is adequate for the facility.
WHERE ARE INDUSTRY STANDARDS USED? Industry standards and good engineering practice are used in many aspects of plans three key areas are: Evaluation of proper container/tank and piping design. Evaluation of secondary containment effectiveness. Methods to evaluate container/tank integrity.
WHERE ARE INDUSTRY STANDARDS USED? Evaluation of proper container/tank and piping design - key: Applicable materials of construction and product compatibility Corrosion protection Overfill and spill prevention Venting Piping supports
KEY FIRE CODES NATIONAL FIRE PROTECTION ASSOCIATION (NFPA) STANDARDS NFPA 30, Flammable and Combustible Liquids Code NFPA 30A, Code for Motor Fuel Dispensing Facilities and Repair Garages International Fire Code (IFC)
KEY STANDARDS REFERENCED BY FIRE CODES STEEL TANK INSTITUTE (STI) STANDARDS STI SP001, Standard for Inspection of Aboveground Storage Tanks F921 Double-wall Steel Tanks F911 Steel tanks in Dikes
KEY STANDARDS REFERENCED BY FIRE CODES PETROLEUM EQUIPMENT INSTITUTE (PEI) PEI/RP 200, Recommended Practices for Installation of Aboveground Storage Systems for Motor Vehicle Fueling. AMERICAN PETROLEUM INSTITUTE (API) STANDARDS Recommended Practice 653, Tank Inspection, Repair, Alteration and Reconstruction
Applicable UL Standards UL 142 Steel Aboveground Tanks for Flammable and Combustible Liquids Typical for Oil Tanks Steel Aboveground Tank like Lube Cubes Other double-wall steel tanks Single-wall steel tanks in steel secondary containment UL 2085 - Standard for Protected Aboveground Tanks for Flammable and Combustible Liquids Typical for Gasoline and Diesel Ballistics and Impact protection Both the inner and outer steel tanks are built to UL standards UL 80 - Standard for Steel Tanks for Oil-Burner Fuels and Other Combustible Liquids
FIRE CODES AND INDUSTRY STANDARDS The key difference between the use of fire codes and other industry standards is that fire codes are typically adopted as state laws or regulations; standards are referenced. In addition, 112.7(j) specifies that plans include conformance with more stringent state rules.
NEW YORK 6 NYCRR 613-4 AST SYSTEMS New York state has one of the most comprehensive AST regulations in the country. The AST rules have been effective since late 1985 and recently updated as of October 11, 2015. When developing an SPCC Plan in NY, you must also incorporate the applicable state requirements.
NEW YORK 6 NYCRR 613-4 AST SYSTEMS The NY regulations have specific tank design codes and standards for ASTs >60 gallons installed since December 27, 1986. Referenced date-specific UL, API and ULC codes based on date of installation. Corrosion protection, as applicable Materials of construction based on the product stored.
NEW YORK 6 NYCRR 613-4 AST SYSTEMS NY secondary requirements are compatible with SPCC requirements. There are specific technical requirements for piping systems including underground piping for ASTs. Overfill prevention equipment gauge or equivalent Testing/inspection before operation.
NEW YORK 6 NYCRR 613-4 AST SYSTEMS Shear valves on supply inlets of dispensers for pressurized pumping Gravity fed systems with solenoid valves. Check valves on fill piping. Operating valves per NFPA 30
NEW YORK 6 NYCRR 613-4 AST SYSTEMS Spill & Overfill Prevention more specific than any of the 40 CFR 112 requirements Transfer procedures per NFPA 385 or API RP 1007 with delivery standards, i.e., available space, monitoring applicable to 112.7(a)(3)(ii). Report, investigate and cleanup spills and overfills Labeling must include registration ID, design & working capacity and product color code per API.
NEW YORK 6 NYCRR 613-4 AST SYSTEMS Specific operation and maintenance requirements: Compatibility Corrosion protection Repairs Stormwater controls, i.e., 112.8(b)
NEW YORK 6 NYCRR 613-4 AST SYSTEMS Inspections and Leak Detection Specific Monthly inspections Tanks pre-1987, 10-Year Certified* inspections for tanks >10,000-gallons and or close to sensitive receptors Underground piping: Pre-1987, test every 10-years (less stringent than 40 CFR 280) After 1986, line leak detector for pressurized piping * SP001 or API 653
NEW YORK 6 NYCRR 613-4 AST SYSTEMS Reporting, Investigation & Confirmation Report to Spill Hotline within 2 hours after discovery more stringent than SPCC requirements NYSDEC requirements must be integrated into the SPCC spill reporting sections of the Plan.
NEW YORK 6 NYCRR 613-4 AST SYSTEMS Two-hour reporting exceptions: Less than 5 gallons; Contained and under control; Not reached and will not reach land or waters of the state; and It is cleaned up within 2 hours after discovery
ABOVEGROUND TANK TYPES CONSTRUCTION STANDARDS NFPA 30 requires atmospheric tanks to be designed and constructed in accordance with one of several recognized engineering standards, one of which is the UL 142. The International Fire Code in turn requires tanks to be designed, constructed and installed in accordance with NFPA 30.
OUTSIDE LUBE CUBES UL 142 TANKS
ABOVEGROUND TANK TYPES (30:22.2.1 AND 30A: 3.3.15) Fire Resistant Tank: An atmospheric aboveground storage tank with thermal insulation that has been evaluated for resistance to physical damage and for limiting the heat transferred to the primary tank when exposed to a hydrocarbon fuel fire and is listed in accordance with UL 2080.
ABOVEGROUND TANK TYPES (30:22.2.3 AND 30A: 3.3.15) Protected Aboveground Tank: An atmospheric aboveground storage tank with integral secondary containment and thermal insulation that has been evaluated for resistance to physical damage and for limiting the heat transferred to the primary tank when exposed to a hydrocarbon pool fire and is listed in accordance UL 2085.
UL-2085 Fireguard Protected Tank Example
NFPA 30 Key References Installation Requirements Control of Spillage Normal and Emergency Venting Corrosion Control Tank Construction Supports and Foundation Flooding Testing and Maintenance
Properly Secured to the Foundation?
SPCC SECONDARY CONTAINMENT 112.8(c) (2) Construct all bulk storage tank installations with a secondary means of containment for the entire capacity of the largest single container and sufficient freeboard to contain precipitation. Dikes, containment curbs and pits Ensure that areas are sufficiently impervious to contain discharged oil. Alternate: drainage trench enclosure so that any discharge will terminate and be safely confined in a facility catchment basin or holding pond.
NFPA 30 SECONDARY CONTAINMENT Historically, even since the early 1900 s, NFPA 30 has required diking. The concept of diking is walls between tanks: To deter the movement of a fire from one tank to another With an permeable dike floor so that released product would not accumulate and fuel a fire Environmental regulations have always directly conflicted with this concept.
NFPA 30 Key References Secondary Containment (SC) SC tanks for spill control, in addition to diking or remote impounding. [22.11] Prevent release by siphon flow [22.11.4.3]. All pipe connections above normal maximum liquid level [30A: 4.3.6.1]. Enclosed SC must have emergency vents [22.11.4.8] Interstitial space must be tested with air or vacuum to assure integrity [21.5.2]
Secondary Containment?
For an OnGround AST Like this, how far under the AST does the foundation go? Is the Dike Impermeable?
What s Left after the OnGround AST is Removed? Was there Containment under the tank bottom?
Single-Wall AST in Steel Secondary Any Issues?
ASTs in Earthen Containment pose Issues like what?
DIKING TO NFPA 30 SPECIFICATIONS
SPCC CORROSION PROTECTION REFERENCES Bulk Storage Containers [112.8 (c)]: (4) Protect any completely buried metallic storage tank installed on or after January 10, 1974 from corrosion by coatings or cathodic protection compatible with local soil conditions. You must regularly leak test such completely buried metallic storage tanks. (5) Not use partially buried or bunkered metallic tanks for the storage of oil, unless you protect the buried section of the tank from corrosion. You must protect partially buried and bunkered tanks from corrosion by coatings or cathodic protection compatible with local soil conditions.
SPCC CORROSION PROTECTION REFERENCES (d) Facility transfer operations, pumping, and facility process. (1) Provide buried piping that is installed or replaced on or after August 16, 2002, with a protective wrapping and coating. Cathodically protect buried piping installations or otherwise satisfy the corrosion protection standards for piping using40 CFR 280 or state 40 CFR 281 If a section of buried line is exposed - carefully inspect it for deterioration. If you find corrosion damage - undertake additional examination and corrective action in accordance with the magnitude of the damage.
NFPA 30A CORROSION PROTECTION 4.3.8 Any portion of tank/piping in contact with soil: Properly engineered Installed Maintained corrosion protection STI Standards RP 892 Underground piping RP-01-69 External corrosion RP 1632 CP USTs Internal protection protective coatings and linings
ONGROUND ASTs MUST HAVE CORROSION PROTECTION
NFPA 30A Key References 4.3.7 Physical Protection 6 ft. high security fence At least 10 feet from tank and A gate properly secured against unauthorized entry unless property has a secured perimeter fence. Provide protection against vehicular collision by suitable barriers, such as 4-inch diameter steel pipe filled with concrete set 3 ft. deep in a concrete footing and spaced no more than 4 feet apart. Other approved means to protect against vehicular damage includes vehicle resistance testing such as that provided by UL 2085 for protected tanks
Foundation with Bollards in Place
Do you see any Issues Here?
PROTECTED EMERGENCY GENERATOR WITH AST
UL 2085 ASTs with Mounted Dispensers with Bollards
Large Aviation Fuel AST
If UL 2085, are bollards needed?
ASTs IN UNDERGROUND VAULTS 30A: 4.3.3
SPCC Requirement for Overfill 112.8(c) (8) Engineer or update with good engineering practice to avoid discharges - provide at least one of the following devices: (i) High liquid level alarms with an audible or visual signal (ii) High liquid level pump cutoff devices set to stop flow at a predetermined level. (iii) Direct audible or code signal communication between the container gauge and the pumping station.
SPCC Requirement for Overfill 112.8(c) (8) (iv) A fast response system for determining the liquid level of each bulk storage container such as digital computers, telepulse, or direct vision gauges. If you use this alternative, a person must be present to monitor gauges and the overall filling of bulk storage containers. (v) You must regularly test liquid level sensing devices to ensure proper operation.
NFPA 30A Key References Overfill/Spill Prevention 4.3.6.3 Alarm @ 90% capacity AND Automatic shut-off @98% or restricted flow @95% capacity AND Means to determine liquid level shall be accessible to delivery operator (4.3.6.2).
Overfill Prevention: NFPA 30A v SPCC Minimum Requirements NFPA 30A is more stringent than the SPCC requirements which specifies a choice of the same type of requirements. Under 112.7(j), more stringent requirements would apply if they are codified by the state. The P.E. typically defaults to the more stringent fire code requirements.
BULK STORAGE CONTAINERS 112.8(c) Overfill Prevention
Typical Overfill prevention valve installed in fill as level in the AST rises, the valve floats up and closes the fill typically set at 95% capacity.
Easy-to-Read Local Gauge
Remote Fill Box Containment with Fill Connection for AST
PROPER PLACEMENT OF TANKS Distance From Buildings Distance From Property Lines Distance from Dispensers Spacing Between Tanks
Typical Distances that Have to be Considered
NFPA 30A Key References Separation Distances Protected Tank, less than 6,000 gallons: 15 ft. from property line 5 ft. from building or public way 3 ft. between each tank 0 ft. from fuel dispensers
NFPA 30A Key References Separation Distances Protected Tank, more than 6,000 gallons: 25 ft. from property line 15 ft. from building or public way 3 ft. between each tank 0 ft. from fuel dispensers
Horizontal Above Aboveground Tanks
QUESTIONS AND ANSWERS