A little confused about secondary containment 1

[chicopee]

A diked tank farm has several interconnected tanks and the stored fuel oil will be dispensed by top loading 3000 gallons fuel oil service trucks. Per Mass. DEP, is it necessary to have a secondary containment outside the diked tank farm to contain overfills of the oil service trucks?
If secondary containment by berming the area is not feasible is it then necessary to have an oil water separator at the storm drain servicing the area mentioned above?
Also within that same property, fuel oil trucks are parked overnight. Is it then necessary to have secondary containment where the trucks are parked?

Note that the whole operation described above is near a river in which the nearest storm drain discharges?

 

[zdas04]

I don't know anything about Mass regulations, but I looked at the Federal SPCC regulation and it says (40 CFR 112 Section 2):

Facility means any mobile or fixed, onshore or offshore building, structure, installation, equipment, pipe, or
pipeline (other than a vessel or a public vessel) used in oil well drilling operations, oil production, oil
refining, oil storage, oil gathering, oil processing, oil transfer, oil distribution, and waste treatment, or in
which oil is used, as described in Appendix A to this part.

Which says pretty clearly that the truck-loading area and the truck staging area come under the same federal regs as your diked tank farm.

If you read on down in the SPCC reg, you'll find that the federal law is probably more strict than the DEP in that I can't find the option of doing oil separation on the storm water runnoff in the SPCC.

David

 

[chicopee]

ZDAS04 thanks for your input. It is going to be interesting to see how many "mom and pop" facilities that do not have the deep pockets as oil companies do,will be able to afford retrofitting their loading racks many of which are strategically isolated in order to serve "Hill" people.

 

[zdas04]

Why do you think that they "hope" to require implementation of the 2002 revisions to the SPCC in mid-2008? Six years is a long public-comment period and the EPA has been sued by everyone with a stake. The last change moved it from October, 2007 to mid-2008 with the comment that "this would give them time to implement other changes".

The old law used a lot of weasel words that people took to mean that specific provisions did not apply to them. The new law tightened that up a lot and the result is full employment for PE's that sign the SPCC Plans. There are a LOT more sites that now need plans than there are PE's to sign them. The latest change added a provision for small operations that have less than 10,000 gallons of storage (but more than 1,320 gallons) that they can build their own plan without a PE--of course the law doesn't say exactly how they will get conversant enough with the very complex law to be able to build a one-off plan.

Good luck,

David

 

[dtlb26]

From my interpretation, you can have low point drains that would feed back to the primary system.

All works great until you evaluate your SPCC plan. Hence why one should always look at tertirary containment.

 

[Advisor83]

Your best option is to pump all water from the sump while not pumping the oil out. Once the oil is to a level that is not desired, have a third party come out to pump the oil out. This way your in control of your sump liquid levels while still being "environmentally" safe.

 

[rocketscientist]

As I recall from my days in environmental consulting, the dike must contain the volume of the largest tank + the rainwater from a 5-year flood. For Ohio law, known for its harshness:

"Containment dikes must have 10% more volumetric capacity than the largest storage tank located within the containment area."

"Dikes and surface area must be constructed of materials compatible with the liquids they are to contain; capable of withstanding a full hydrostatic head of liquid discharge; capable of restricting vertical and horizontal liquid movements at a rate not to exceed thirty-five hundredths of an inch per day; and contain no open drains."

"Any storage tank over 15 feet tall shall be placed no less than 4 feet from the inside base of the secondary containment facility dike."

(

http://ohioline.osu.edu/aex-fact/0594_2.html)

In Pennsylvania, rainwater requirements are more vague:

"The containment area provided by the dikes or other method of secondary containment shall have containment capacity sufficient to hold the volume of the largest single tank, plus a reasonable allowance for precipitation based on local weather conditions and facility operation."
(

http://www.dep.state.pa.us/dep/subject/rbi/bogm.htm)

What is a 5-year flood, the rainwater rates are based on frequency data often available from the USDA and other sites. Given the rate of rainfall and the area of drainage (not the same thing as the area of the tankfarm area), you can calculate the additional volume needed.

Note that by Ohio law, as with many states, the drain valve must be locked to prevent tampering. Also, many states require remote level sensors now with adequate maintenance to reduce spillage. But, this is just common sense in most instances.

Dirk Willard

 

[dcasto]

One way to lower the containment volume is to put a roof over the are to keep the 5 year rain out. Parking trucks in a covered area is good for them and keeps the impondment volume down is heavy rain areas like Houston.

 

[bimr]

Yes, your need a method to prevent the oil from reaching the river.

The entire SPCC regulatory system was started because of a spill into the Ohio River.