SECONDARY CONTAINMENT IN THE APSA WORLD

There could be unsure some brand-new inspectors in the room or maybe someone from industry or a consultant who you just decided. Oh, this one looks good, I think I'll go to this class, so I want to make sure you guys know what the acronyms mean so APSA stands for the above-ground petroleum storage act and you probably all knew that. But just in case you didn't even if there's one person who didn't know what abscess stood for this slides for you and it is found in Chapter six point: six: seven of the Health and Safety Code. It was effective January 1st, 2008 and I'm sure most of you are aware that the state program was was not you know, being supported and unfunded, so it was transferred to the Koopas and we've been implementing the opposite program ever since we've gone through training. So now in in developing the unified program training matrix, we are trying to develop consistent training for all the Kupa programs and we developed a matrix of what would be considered beginning training. What would be intermediate and what would be advanced training for a coop inspector and trying to come up with classes that you know? Maybe someone in a in a rural Kupa can watch this class online and they could get the same training that you guys are getting. As a new inspector, they can take this training online, so they're sort of trying to develop a curriculum, and this is one of those classes that came out of that training matrix and then the next acronym that I want to talk about is SPCC. When I first got involved with this, I couldn't I kept switching: what's: what's the seize control and countermeasure or a countermeasure in control, so so there you go. It'S bill prevention, control and countermeasure, and it's found in title 40 of CFR Code of Federal Regulations, part 112. It'S been around for many many years and then it's gone through various amendments which we'll talk about a little bit and there are other classes at the Koopa conference. That Pete Reich is teaching where you're going to get. You can ask questions specifically about SPCC and, of course, protecting in fact navigable waters. So, let's get started, I want you to try the clickers all right. So the way it works is it's like opening your garage door, just push it and let go you don't have to keep pushing it. Okay and it's going to capture whatever you. Let go of laughs. So the last answer you pick. So if you change your mind, whatever is the last answer that you pick okay, so here's the four questions number one on your clicker is: if you're a regulator, number two, if you're a consultant three and so on and other, I think someone said other earlier - was Like maybe a prosecutor or a district attorney, something that could be other, I'm not sure what else other would be. I'M sure you know who you are if your other okay, so let's try this out. You got ten seconds to give me your answer. Alright, Wow. 5050. Eight people in the class awesome: okay, good job, okay. Here we go so here's our results. We have 62 % in the room, our regulators, 12 % our consultants, 24 % industry, so that's a good mix and then who's the other. What is other? Okay? What'S other? I'M curious, oh great, okay, cool all right, great yeah, great! Well, welcome all right! So, let's keep going okay! Now I want to know who knows stuff about APSA here. So if you think you could come up here and teach this class you're you're gon na push one not today, don't worry, I'm all set I'll, be okay, but maybe next time, if you you know some about APSA but but you'd like to learn more or if You have no idea what apps and you you were, the one who was writing down what apps is stood for then, then, okay, so here we go great. Okay, let's see okay, that's kind of what I was thinking that we would we would be great okay. Thank you, so eleven percent could probably teach this class some most of you want to learn more and a very few of you are maybe new new inspectors or you do other programs, and you haven't done too much with APSA. I need to break in right here. So who's the eleven percent - okay, you're gon na - be asking all those hard questions. Aren'T you? Okay? Okay! Well, I actually asked Pete to I volunteered to do this. I haven't actually personally done a lot of absent inspections. I'Ve helped to implement the program, but I asked people can you come in case? They asked me like any really hard questions. Thank you for being here and I did post the presentation online by the deadline. So you all should have been able to get the slides, and then I also posted the SBCC guidance for regional inspectors, which I used to develop part of this course. So if you have not already downloaded those you can, they are available to all right and then so with the clickers. When you see this little guy here, that's I'm going to ask you a question and kind of test your knowledge we're going to review throughout the course and and and last of all in your evaluations. I would really appreciate, because this is the first time doing this class any feedback you have. I think it's you know they're gon na get it not me. So if you want to say, oh you know you did you were too simple, you maybe get into you know, talk more or give me suggestions. Give the Koopa forum suggestions on how to improve this class. Your feedback is greatly appreciated. Alright, okay, so now I'm starting with the course here we go. So in January 1988 Ashland oil company was indicted for violating federal environmental laws and the collapse of a storage tank that spilled more than five hundred thousand gallons of oil into a river in Ohio near Pittsburgh. The Justice Department announced, although indictment returned by a federal grand jury in Pittsburgh, was on misdemeanor charges rather than on felony charges. The department said conviction could allow the governor government to recover tens of millions of dollars from Ashland in what has been described by federal officials. Is one of the largest inland oil spills in the nation's history? It was actually flowed 200 miles. It created an oil slick that flowed supplies of drinking water to many communities was contaminated and interrupted. Thousands of fish birds and wildlife were killed. Ashland'S, chairman john hall, conceded that mistakes were made by company employees who responsible for the tank that ruptured. He acknowledged that company procedures for building and operating storage tanks had not been followed at the site of the spill. Four million gallon storage tank - you split apart and collapsed. The tank had split while being filled to capacity for the first time after it had been dismantled and moved from Ohio location and then reassembled at the new facility. That was in January of 1988 April 1988. There was another spill shale oil refinery in Martinez late. In the evening April 23rd 1988, a tank filled with hundreds of thousands of gallons of crude oil began to leak a hose designed to drain water from the roof of the tank. Failed oil began siphoning out into the containment area surrounding the tank. Unfortunately, a storm water valve had been left open and the oil continued to drain into a nearby creek under the freeway and into a marsh because it was dark. Nobody noticed it and it took a long time before they figured out that it was actually coming from their facility and before the source of the spill could be located and stopped about. 400,000 gallons of heavy crude oil had leaked into the environment. So if you've been doing this for a while, you know this is the source of our environmental laws. These catastrophic events are where our laws start from and that's what happened: stronger regulation and enforcement needed to avoid future incidents. So this is your origins of pollution prevention. I'M sure Pete could give other examples. There'S been a lot of amendments since 1988. There'S a lot of flexibility built into the SPCC rule in general, the feds, the Federal Rule wants containment, so this class is about containment and that's what we're going to talk about? It'S a pretty much a thread that runs throughout the federal rule, and so it the concepts around it. If you don't understand them, it's gon na be difficult to implement the rule. So what are we going to talk about today? This is what I want you to get out: your notepad. Everybody got a pen and a piece of paper, cuz you're gon na keep me on track. Just in case. I forget one of these objectives, so the first thing we're gon na do is we're gon na tell you're gon na, remember and memorize when you leave here today. I want you to be able to say if I say when what section of of CFR 112 do you find general containment? Some of you may already knew it, but when you come out of here today, I want you to know which section that is and which section do you find sized containment requirements, so we're going to talk about those sections and then also in apps as well number. Two objective is understanding the difference between general containment and sized containment and when it applies number three is reviewing those nasty exceptions and alternatives. As soon as you got it all figured out, then you find out. Oh there's an exemption to that and then last of all for the 62 % of you who are regulators, understanding your role as an inspector in evaluating secondary containment and then not only for inspectors, but for our industry in the audience. What to expect when an inspector comes out does an app's inspection and they are reviewing your SPCC plan. What they're looking for so this last objective is sort of dual, because our audience today is mixed, mmm, alright, so here's the first one and you guys wrote all those down everybody got them down the four objectives, all right, okay, so here's the next thing! I want you to write down one 12.7. Little c, everybody got it okay, so this is the section where out of the federal regulations, we're we're talking about general containment, how many of you memorize regulations or you can just rattle off those sections? Are you one of those people? My chief is one of those people. He he hasn't done inspections for a long time, but he'll go well. What about in Section that another better did you look in that? Am I just like? Oh gosh, I'm not one of those people that holds on to that information. I should be, but so hopefully, when you leave my class today, you'll remember these sections. Yes, please! I just quickly want to make note that, under the SBCC rule there are requirements that apply to all facilities that are captured by the SBCC rule and under one 12.7. Those are the requirements that are on the present to all of the SPCC world. So when we're talking about general containment, that's applicable to all facilities and all activities that are where oil is transferred, stored, managed used, consumed or otherwise captured by the rule. So when we're talking about 7c here just note that that's for every single SBCC related facility is going to be captured by that, and so that would carry over into the absent world. Thank you, people all right. So this is one of four sections that I'm gon na. Have you write down this first one one 12.7 see what that says. If you look, it up is provide appropriate content. I won't read the whole thing, I'm just going to sort of paraphrase it, but provide appropriate containment, and/or, diversionary structures or equipment to prevent a discharge and we're going to talk about what is a discharge just a little bit. But you can learn more about that in another class, and the entire containment system, including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system will not escape before cleanup occurs. And then in determining the method in design, we're looking at the most likely discharge for general containment, the most likely discharge all right and for general containment as well. There'S all sorts of choices and I'll just give you a few examples that are right out of the regulations out of this section: dikes, perms, sump sand collection systems, booms, build version, absorbent materials, etc, and, like Pete mentioned, all facilities are subject to general containment requirements. So what you're looking at here would be piping, that is attached to a tank loading areas, transfer areas, oil filled equipment which we're going to talk about that to you know pretty much anything that you can think of at your facility pulling pushing a dolly around with A drum on it that would be subject to general containment, etc, etc. So, like I already said, it's appropriate containment to prevent the most likely discharge and that concept will we're going to talk more about it in a minute. But what we're talking about here is, you know, we're not looking at the full capacity what is most likely to release into the environment, so it takes a lot of active approaches and thinking on the part of the facility to decide what is the most likely discharge. The inspector wouldn't make that determination, that's something that the facility would need to make, and it just depends on their equipment how much they have. How often they do loading and unloading, how often they fill and unload vehicles. You know, maybe it's just a tank and it never moves. You know they don't move stuff around. Maybe they get a delivery like every six months. You know maybe it's an emergency generator, so the appropriate containment to prevent the most likely discharge is really dependent on the facility so that general containment would be dependent on the facility. Now as far as a discharge. What is a discharge, like, I said, there's probably a whole other class on this, but what we're talking about is described in one 12.1 B, which you don't have to write that down, because that's another class. But you can, if you want to one 12.1 B, and that is in quantities that may be harmful in tour upon the navigable waters of the of the United States. So it could be a sheen. It just depends, but definitely something as small as a sheen can have an impact, so that would be considered a discharge. Next section grab out your pen, one 12.7 little H, so we've had one section in one 12.7: now we have another one, one 12.7 H and we're talking about a very specific equipment at a facility called a loading or unloading rack. How many people have seen these during inspections just a few okay they're, not very many places there, that you don't see them very often, but you might see it once in a while and who can tell me what type of containment does a loading rack need? Sized containment, okay, those are the people in the class who know something about Apso very good. So that was probably a test question on our inspector exam and you must design secondary containment for loading and unloading racks to hold at least the maximum capacity of any single compartment of a tank, car or tank truck loaded or unloaded at that facility. Now is there a difference between a loading rack and a loading area? Yes, the answer is yes and, like I said this is for maybe another class, but it one of the things I remember Pete telling us in training and in our training courses that we took is you're looking for those overhead arms, something that is a mechanical fill Anything else speed on that, so RAC is gon na, be characterized by being a country. Next to Iran ha bad job. You can see the loading arm component in the photograph where the man is standing on the top of the truck. That'S going to be the main feature that would characterize a system like that. As of loading, unloading, rack generally there's going to be a platform or gangway associated with it, but you could have those types of components without a loading arm and that would conceivably keep it from being identified. As a rack, we did EPA amended the rule, the SPCC rule, to update and include a definition of a loading and unloading rack. Probably in 2008 I believe, may have been 2006, but that was to identify specifics for rack requirements that do require sized secondary containment based on a trucks largest compartment, as well as to help differentiate, transfer areas where you would be conducting the transfer through flexible hose connections And that's to reduce the containment requirements from sized and move them back into general containment Wow. I didn't know that all right. So what was the section you for general containment? One twelve point, seven little C, very good, alright! So then this is for loading racks, one. Twelve point: seven little H, our next section number three, this next section is for bulk storage containers and tanks. Please write this section down, so what we're talking about here are our bolt tanks, and this is where a facility is required to construct their containment for bulk storage and drums. That includes drums bulk storage containers and tanks, so that your provide a secondary means of containment. For the entire capacity of the largest single container and sufficient freeboard to contain precipitation - and that's right in that section, dikes containment, curbs and pits are commonly import employed for this purpose and then we'll talk about alternatives later as far as mobile containers, something you would move Around the facility, they are also subject to this section when they're sitting somewhere when they're moving around when they're under the control of the operator and that's actually on the dolly the person is pushing it around. What are they subject to anybody? General containment, very good? Yes, please, okay, a couple, I think a couple of points won't need to be clarified on the general container requirements. If a facility operator is manipulating, moving or otherwise using a drum and it's in within their vision and control, would they need to have a general containment? Somebody with absorbent or a dike or a berm of sorts to follow them around. No there's not a containment requirement, while it's under an operational control, if they start a transfer action from the drum to a tank or some other transfer activity, there would need to be at a minimum. Some sort of active measure available that would be assortment spill, kit or other sort of deployable method for the operator to display out or cover a storm drain or something if there was a spill that hit the ground and started flowing. So something says yes, thank you. That'S good all right and then the next section this is section number. The last section that you're going to write down from the federal regulations would be the section which we are just talking about: mobile or portable storage containers and tanks, one 12.8 little c11, where it talks specifically about these mobile containers and that they are subject to the Sized containment requirements unless, like Pete mentioned, if it's being moved around - and this is with the exception of mobile refuelers and I'm going to talk about those in a minute because there are some exceptions for mobile refuelers, so in the federal guidance for regional inspectors. There'S these great charts and - and so this is in your download materials, and it actually gives the sections here that you can. I got my little pointer here. It gives the sections for bulk storage containers and the sections I just mentioned: loading and unloading, racks, mobile and portable containers and then other areas and we're talking about onshore storage facilities. Now I've had it's funny because I've had a few facilities who've. Given me a call and they're just getting there getting, they got they're just now getting their SPCC plan done and for some reason they don't think they have to check all these boxes because they say well our facilities right, not right. Next to the shore, and I'm like no, no, no, they think for some reason, they're not subject to this requirement because they see the word on shore. Has anybody else had that kind of a confusion from their facility at all, or if you noticed it, they may not be wanting to ask you, because they think they're supposed to know so. Take a close look at those SPCC qualified facility templates and the boxes that they check, sometimes they're. Just all left blank. The I had a pretty big chain of oil change facilities that left a whole bunch of those boxes, blank on their template because they felt they thought this was for like oil rigs, because it says for some reason they saw the word shore and they think that That'S something like on a port or something like that. So just to let you know, and then this also talks about impracticability determination which we're going to talk about that later and gives other sections. If you look in this guidance, it does talk about production facilities as well and gives those sections we're not going to be talking about that today. But just so you're aware there are other sections that would apply for say an oil production facility or a offshore oil-drilling. If you, you would look at differ sections and the regulations for possibly sized containment or general containment, so these ones that we just got the four that you just wrote down. This is for onshore storage facilities, most of the facilities we're going to see as absent inspectors and for our business and industry in the audience most likely. This is what your facility is. If you have a production facility, you would have different sections. That would apply anything good, okay, all right. So now we're moving on to APSA state law and we're going to talk about it's pretty easy, there's, not four sections an app. So there's really just one main section this one right here. So please write this down to five. Two, seven, zero point, four point: five, and in this section it's pretty much in a nutshell, it says they have to have a federal plan and they have to implement it and that's. I could read it to you, but that's: each owner operator of a storage tank shall prepare an SPCC plan and they need to conduct the inspections and implement that plan, and that's what it says in that section of APSA. This section down here is probably a good one to jot down as well. That'S why I have it up on the screen, because that's where you're going to find your apps of penalties. So if you were to do, let's just say, for example, you gave multiple notices to a facility for preparing an SPCC plan as an inspector or as an industry person. You get multiple notices from an inspector that you need to do your plan and for whatever reason, the facility does not does not prepare their SPCC plan and close out that violation. Eventually, our job as the Kupa is to use graduated enforcement, and we may end up writing a Notice of Violation to that facility, and you know escalating that possibly doing an administrative enforcement case or something like that to gain compliance. And in that case, you would want to refer to this section five to seven 0.12, a and in this section it talks about that. If they, if the facility fails to prepare the plan, then they would be subject or be in compliance or implement. There'S a lot to it: it's not just having a plan. You have to implement the plan, then they would be subject to a civil penalty of not more than five thousand dollars for each day on which the violation of continues and then, if they commit a second and subsequent violation, then it could go up to ten thousand Dollars per day, yes with your district attorney's office, to consider moving that to that part, the respective district attorney's office, because we are interested at taking out two cases particularly class what violations, and particularly where we have competed and I'll. Just repeat the question since we're taping is a gentleman with the District Attorney's Office is encouraging Koopas, who are having problems with repeat offenders, not in compliance with APSA, to be sure to talk to your your prosecutors and work with them on cases. Revolving repeat offenders. A lot of times, in my experience so far they just haven't gotten around to it. They don't really understand that they need to do the template or you know whatever we have most of our. We have about 700 apps at facilities 750 and about 110 of them are PE certified facilities. You know over 10,000, the rest are qualified facilities, so about 600 qualified facilities, and they just you know, they've the other. We told them to do the SPCC plan and now we've got to go back and make sure they have it now that we're getting around to that next inspection freak timeframe, and now they haven't done it yet I'll get to you set one sec, and so now It'S like well we've, given you notice, we sent you a letter, you still don't have it so now we probably have to escalate it and move forward with that. You had a question here: okay, so the question was: is there a specified time frame from when you give notice that they have to have an SPCC of when they need to have it great question? It has been required, depending on your facility, if you're, with Ben, if you're a business depending on your facility, but now all the deadlines are pretty much over unless you're a farm. You are required to have an SPCC plan in place. Now already is, if you are subject to the requirement of having 13, 20 gallons of oil or more or petroleum or more, if you're talking about APSA. So so when we go in there as an inspector, you are already supposed to have that plan. So the way it works kind of like with all of our violations, we typically and it depends on your internal guidance if you're, if you're with a Koopa or if you are a business person, you know the Koopa that you reside in usually it's 30 days. Sometimes 60, depending on the agency and and then after that timeframe is over. If the agency sometimes they'll ask for extensions, a facility can ask for extension if they need more time, but if once that's exhausted, then then it would be required. So I would say it depends, is the answer, but I would say it would range between 30 to 60 days, depending on what the facility has to implement your agency might decide to work with a facility. If maybe they have to. You know retrofit an area and it's going to take them a few months to get that capital together to to do those retrofits and implement the plan. Good question. Thank you and please ask questions throughout all right. So our goal in APSA and the federal requirements spill prevention, control and countermeasure. So when I think control, I think that some type of containment or or active measures that you're putting in place to prevent releases prevent discharge now. Can somebody in the audience tell us what is an SPCC plan? Buddy oh, come on this gentleman right here. You keep yes, sir, tell us what an SPCC plan is I'll. Give you some candy, I have a few pieces left, contain any releases you have and, most importantly, how what you're going to do with it when you have a release to prevent it from reaching an apical water thanks trainee, they very good, very good. What'S your name Tom Parker, from where Butte County awesome Butte County there, you go all right: okay, very good! So for our video, it's details, the equipment, workforce procedures and training to prevent control and provide adequate countermeasures for the discharge of oil and, if you're, already familiar with app. So you know with apps that we're talking about petroleum, which is a subset of oil and you you would have gotten more about the difference between apps and SPCC and petroleum and oil. That'S ended that's in an earlier class. So that's not for today, if you, if you're a little confused on that, see me after class, we've got some online training that you can check out. So when we're talking about the above-ground storage tank program, it was enacted in 1990 and the goal of that program was to protect vegetation, wildlife, surface water, human health and groundwater in the state of California, from the damaging effects of petroleum. And so what we have to do in implementing that program as a Koopa is to review and implement the SPCC plan make sure the SBCC plans are being implemented at the facility and then make sure the facility has installed any release detection systems that they need to Have in place require and investigate, if you think you have violations where there's been releases at that facility and then if there have been releases, make sure that corrective action occurs for cleanup of those releases and then, of course, to inspect the facilities and and then you Know now we have our office of the State Fire Marshal that is going to be overseeing the program. Many of the Koopas have implemented and made it part of their fee structure to charge a fee to permitted facilities for APSA. Some have decided to not charge they're qualified facilities, but they're still implementing the program for those facilities. Every coop is doing it a little bit differently. There'S going to be a panel tomorrow talking about implementation at the different Koopas. So what we're talking about here, though, in general in a nutshell, is just protecting the waters of the state and protecting navigable waters and navigable waters does include storm drains by the way. I know I've been talking about the state program right now, but this does apply to the federal program. All right so get out your clickers we're going to do a question just to see if you're awake and paying attention here. Okay, so your question is what regulations are known as the oil pollution prevention regulations? All right, you got ten seconds very good, awesome, okay, good most of you are paying attention. Some of you might have missed clicked, but yes, 40 CFR. 112. Is the right answer. All right, let's go to the next question here, so hopefully I didn't trip you up there, but what does the first C

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