Aboveground Petroleum Storage Act Requirements

1. Aboveground Petroleum Storage Act Requirements

2. Overview • Background and Scope of APSA • Definitions • APSA Facility Types • SPCC plan Requirements • Facility Diagram, Procedures, Training, Recordkeeping, Maintenance • Inspection Timeframe & what to expect

3. APSA Background • Aboveground Petroleum Storage Act is now part of CA H&SC, Chapter 6.67 • Gives local CUPAs authority over APSA • Federal Oil Spill Prevention Program is part of 40 CFR 112 • Federal EPA still has authority • Requirements of each program are similar but not identical

4. Scope of APSA • Feds – “Navigable Waters” • CUPA – greater than 1,320 gallons

5. Regulated Chemicals • “Petroleum” – crude oil fraction, liquid at room temperature and pressure • Includes fuels, lubricants, solvents, biodiesel • But NOT propane, LPG, LNG, or 100% biodiesel or synthetics or corn ethanol, some waxes, tars, or asphalts

6. Aboveground Tank • 55 gallon or more capacity • Substantially or totally above ground

7. NOT Aboveground Tanks • NOT • “Permanently Closed” tanks, Boiler, Haz Waste at TSD facility, crude oil production tank, oil-filled electrical equipment, UST, or a DOT regulated tank…

8. “Permanently Closed” Tanks • All liquid and sludge removed from tank and connecting lines • All pipes and lines disconnected and blind flanged/blanked • All valves closed and locked out (except vent valves) • Tagged as “permanently closed” with closure date

12. Transportation Related?

15. APSA Facilities • 1,320 gallons or more of aggregate aboveground petroleum storage capacity • Based on Rated Design Capacity... • Modified overflow, vent, etc. does not always count • Procedural means of limiting capacity do not count

16. APSA Exempt Facilities • A tank facility at a Farm, Nursery, Logging site, or Construction site is exempt if….. • No tank exceeds 20,000 gallons • AND total storage is less than 100,000 gallons • APSA Exempt facilities must still… • Conduct daily inspections • Allow CUPA to inspect periodically • Provide Secondary Containment if required by CUPA • Comply with applicable Federal rules

21. What is an SPCC plan? • Spill Prevention, Control, and Countermeasure (SPCC) plan • Spill Prevention • Training, procedures, awareness • Control • Containment, immediate response • Countermeasure • Cleanup, notifications

22. Three types of APSA facilities • Tier I Qualified Facility - Can use Template SPCC and self-certify • Tier II Qualified Facility - Can self-certify own SPCC plan • Non-qualified Facility - Must have SPCC plan certified by a Professional Engineer

23. Qualified Facilities • To be a Qualified Facility… • Less than or equal to10,000 gallons of any aboveground oil storage – not just petroleum • No discharge greater than 1,000 gallons in past 3 years • No two discharges greater than 42 gallons within any 12 month period in the past 3 years

24. Tier I Qualified Facilities • Less than or equal to10,000 gallon total aboveground oil storage capacity • No single tank more than 5,000 gallons • You must… • Complete and self-certify the Template SPCC Plan

25. Tier II Qualified Facilities • Less than or equal to10,000 gallon total aboveground oil storage capacity • Individual aboveground tank more than 5,000 gallons • You must… • Prepare a self-certified SPCC plan

26. Non-Qualified Facilities • Greater than 10,000 gallons total aboveground oil storage capacity • You must… • Have an SPCC plan certified by a Professional Engineer

27. SPCC Plan Elements • Elements required in an SPCC plan include… - Facility description and diagram - Description of each storage location, and containment - Likely discharge scenarios - Tank inspection and testing program - Oil handler training - Security - Response and notifications - Plan must be reviewed at least every 5 years. Must be updated within 6 month of any significant change

28. Inspection • Plan prepared properly? • Plan implemented as described? • Workers know about plan? • Plan vs. Real World • CUPA only inspecting APSA subject items • Plan must be implemented by Nov 10, 2010

29. Sized Secondary Containment • Contents of largest container plus precipitation • Applies to… • Loading/unloading Racks • Storage tanks and containers • Includes portable totes and drums while stored (must also be located properly) • Non-transportation related tank trucks (i.e. mobile refuelers) during storage

30. Sized Secondary Containment

31. Sized Secondary Containment

32. Secondary Containment (Drainage) • Water inside secondary containment must be inspected for oil contamination prior to discharge • Records should be kept for at least 3 years

38. General Containment • “Most likely” discharges  spill kits, drain covers, spill buckets, etc. • Applies to… • Piping, oil-filled equipment, (non-rack) transfer areas, non-transportation related tank trucks (i.e. mobile refuelers) during use

39. POOR General Containment

40. General Containment

41. General Containment

44. Overfill Prevention • Describe Procedures and Hardware

47. Overfill Prevention • High liquid level alarms/shutoffs • Liquid level indicators • Alarm should be heard or electronically sent to pumping station

50. Loading Racks • Permanent Structure w/ piping, loading arm, valves, pumps, shut-offs, etc…