09 - spcc plan-integrity inspections · condor earth 2 and spill prevention, control, and...
TRANSCRIPT
SPCC Plans ‐ Setting the Standard for Tank Integrity
5/2/2019 ‐ Stanislaus County Storm Water Workshop
Condor Earth 1
Jordan JohnsonSTI Tank Inspector
Condor Earth
Copyright © 2019, Condor Earth, All Rights Reserved
How many of you have heard of an SPCC Plan?
◦ Anyone have one at their facility?
◦ Bonus – Anyone know what SPCC stands for?
SPCC Plans ‐ Setting the Standard for Tank Integrity
5/2/2019 ‐ Stanislaus County Storm Water Workshop
Condor Earth 2
and
Spill Prevention, Control, and Countermeasures (SPCC) Plan
Different , yet similar.
Fundamental part of storm water permits A facility/site specific document addressing pollution in storm water
discharges from industrial facilities and construction sites in order to protect the integrity of receiving waterways.
SPCC Plan Applies to designated oil storage facilities that have the potential to
discharge oil to navigable water of the United States and adjoining shorelines.
A facility-specific document focused on oil pollution from facilities in order to protect the integrity of waterways.
30,000ft. Overview
Copyright © 2019, Condor Earth, All Rights Reserved
SPCC Plans ‐ Setting the Standard for Tank Integrity
5/2/2019 ‐ Stanislaus County Storm Water Workshop
Condor Earth 3
Topic #1 – Spill Control(Secondary Containment)
Topic #2 – Continuous Release DetectionTopic #3 – Tank Integrity Inspections
General Secondary Containment ◦ 40 CFR 112.7(c)◦ Enough containment to prevent discharges◦ Procedures, Spill Response, Structures
Specific or Sized Secondary Containment◦ 40 CFR 112.8(c)(2)◦ Bulk storage containers◦ Specific volume required◦ Typically structures
Copyright © 2019, Condor Earth, All Rights Reserved
SPCC Plans ‐ Setting the Standard for Tank Integrity
5/2/2019 ‐ Stanislaus County Storm Water Workshop
Condor Earth 4
Do these containers need it?If so, how much capacity?
Secondary Containment
Copyright © 2019, Condor Earth, All Rights Reserved
Is this enough?Secondary Containment
Copyright © 2019, Condor Earth, All Rights Reserved
SPCC Plans ‐ Setting the Standard for Tank Integrity
5/2/2019 ‐ Stanislaus County Storm Water Workshop
Condor Earth 5
Is this enough?Secondary Containment
Copyright © 2019, Condor Earth, All Rights Reserved
Close to enough?Secondary Containment
Copyright © 2019, Condor Earth, All Rights Reserved
SPCC Plans ‐ Setting the Standard for Tank Integrity
5/2/2019 ‐ Stanislaus County Storm Water Workshop
Condor Earth 6
More than enough?Secondary Containment
Copyright © 2019, Condor Earth, All Rights Reserved
Elevated Tanks◦ See all sides of the tank◦ Tank bottom not in contact with the ground
Release Prevention Barrier◦ Concrete floor◦ Liquid barrier
Copyright © 2019, Condor Earth, All Rights Reserved
Continuous, passive by design
SPCC Plans ‐ Setting the Standard for Tank Integrity
5/2/2019 ‐ Stanislaus County Storm Water Workshop
Condor Earth 7
Raised Tank on Supports, Double-Wall TankCRDM
Copyright © 2019, Condor Earth, All Rights Reserved
Tank on Concrete FloorCRDM
Copyright © 2019, Condor Earth, All Rights Reserved
SPCC Plans ‐ Setting the Standard for Tank Integrity
5/2/2019 ‐ Stanislaus County Storm Water Workshop
Condor Earth 8
40 CFR 112.8(c)(6): Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs. You must determine, in accordance with , the appropriate qualifications for personnel performing tests and inspections, the frequency and type of testing and inspections.
Copyright © 2019, Condor Earth, All Rights Reserved
industry standards
QUIZ – what is the key phrase above?
Steel Tank Institute (STI)◦ STI SP001 – 6th Edition (January 2018)
American Petroleum Institute (API)◦ API Std 653 – 5th Edition (November 2014)
Fiberglass Tank & Pipe Institute◦ RP 2007-1
Copyright © 2019, Condor Earth, All Rights Reserved
Any Others?
SPCC Plans ‐ Setting the Standard for Tank Integrity
5/2/2019 ‐ Stanislaus County Storm Water Workshop
Condor Earth 9
Size/Capacity/Configuration◦ Shell capacity◦ Configuration
Tank Components◦ Complex systems, ◦ Identify and test operability
Copyright © 2019, Condor Earth, All Rights Reserved
Risk Based Classification◦ Configuration Spill Control CRDM◦ Shell capacity
Higher Risk Installations◦ Higher frequency of inspections◦ Additional types of testing
Copyright © 2019, Condor Earth, All Rights Reserved
SPCC Plans ‐ Setting the Standard for Tank Integrity
5/2/2019 ‐ Stanislaus County Storm Water Workshop
Condor Earth 10
What things come to mind with the phrase…
“Tank Integrity”
◦ Tank Testing◦ Certified Inspector◦Monthly Inspections
Tank Owner/Representative◦ Monthly Visual Observations
Certified Tank Inspector◦ External/Internal/Leak Testing
Copyright © 2019, Condor Earth, All Rights Reserved
SPCC Plans ‐ Setting the Standard for Tank Integrity
5/2/2019 ‐ Stanislaus County Storm Water Workshop
Condor Earth 11
SPCC Plans ‐ Setting the Standard for Tank Integrity
5/2/2019 ‐ Stanislaus County Storm Water Workshop
Condor Earth 12
Underground Storage Tanks (USTs) cannot be used as Aboveground Storage Tanks (ASTs)
SPCC Plans ‐ Setting the Standard for Tank Integrity
5/2/2019 ‐ Stanislaus County Storm Water Workshop
Condor Earth 13
This happens when you don’t properly vent a storage tankhttps://www.youtube.com/watch?v=2WJVHtF8GwI
Drone video captures the Liberty County fire that took place near Highway 77 in Texas, involving 300 barrels of oil and five storage tanks. https://chrn.cl/2sS9AKb
SPCC Plans ‐ Setting the Standard for Tank Integrity
5/2/2019 ‐ Stanislaus County Storm Water Workshop
Condor Earth 14
SPCC Plans ‐ Setting the Standard for Tank Integrity
5/2/2019 ‐ Stanislaus County Storm Water Workshop
Condor Earth 15
Any issues with these tanks?Integrity Inspections
Copyright © 2019, Condor Earth, All Rights Reserved
Do my tanks need them?Integrity Inspections
Copyright © 2019, Condor Earth, All Rights Reserved
SPCC Plans ‐ Setting the Standard for Tank Integrity
5/2/2019 ‐ Stanislaus County Storm Water Workshop
Condor Earth 16
Do my tanks need them?Integrity Inspections
Copyright © 2019, Condor Earth, All Rights Reserved
Do my tanks need them?Integrity Inspections
Copyright © 2019, Condor Earth, All Rights Reserved
SPCC Plans ‐ Setting the Standard for Tank Integrity
5/2/2019 ‐ Stanislaus County Storm Water Workshop
Condor Earth 17
Do my tanks need them?Integrity Inspections
Copyright © 2019, Condor Earth, All Rights Reserved
Do my tanks need them?Integrity Inspections
Copyright © 2019, Condor Earth, All Rights Reserved
SPCC Plans ‐ Setting the Standard for Tank Integrity
5/2/2019 ‐ Stanislaus County Storm Water Workshop
Condor Earth 18
Do my tanks need them?Integrity Inspections
Copyright © 2019, Condor Earth, All Rights Reserved
Do my tanks need them?Integrity Inspections
Copyright © 2019, Condor Earth, All Rights Reserved
SPCC Plans ‐ Setting the Standard for Tank Integrity
5/2/2019 ‐ Stanislaus County Storm Water Workshop
Condor Earth 19
Do my tanks need them?Integrity Inspections
Copyright © 2019, Condor Earth, All Rights Reserved
Do my tanks need them?Integrity Inspections
Copyright © 2019, Condor Earth, All Rights Reserved
SPCC Plans ‐ Setting the Standard for Tank Integrity
5/2/2019 ‐ Stanislaus County Storm Water Workshop
Condor Earth 20
Do my tanks need them?Integrity Inspections
Copyright © 2019, Condor Earth, All Rights Reserved
Do my tanks need them?Integrity Inspections
Copyright © 2019, Condor Earth, All Rights Reserved
SPCC Plans ‐ Setting the Standard for Tank Integrity
5/2/2019 ‐ Stanislaus County Storm Water Workshop
Condor Earth 21
Do my tanks need them?Integrity Inspections
Copyright © 2019, Condor Earth, All Rights Reserved
Do my tanks need them?Integrity Inspections
Copyright © 2019, Condor Earth, All Rights Reserved
SPCC Plans ‐ Setting the Standard for Tank Integrity
5/2/2019 ‐ Stanislaus County Storm Water Workshop
Condor Earth 22
Do my tanks need them?Integrity Inspections
Copyright © 2019, Condor Earth, All Rights Reserved
Do my tanks need them?Integrity Inspections
Copyright © 2019, Condor Earth, All Rights Reserved
SPCC Plans ‐ Setting the Standard for Tank Integrity
5/2/2019 ‐ Stanislaus County Storm Water Workshop
Condor Earth 23
Do my tanks need them?Integrity Inspections
Copyright © 2019, Condor Earth, All Rights Reserved
Copyright © 2019, Condor Earth, All Rights Reserved
Tanks for your attention!