Prepared for:

Dr. Heather Wilkinson

Texas A & M University

BESC 411-500

Fall 2014

Prepared by:

Michelle Barton

Prepared by: Michelle Barton

Petroleum Storage Tanks & Storm Water Management Plan

TEXAS A & M UNIVERSITY SITE VISIT

Table of Contents

Page No.

1.0 Introduction………………….……………………….…………………………......1

2.0 Features of the Transportation Center……………………………………………1

2.1 Location.

2.2 Primary operations and processes

2.3 Financial Assurance

3.0 Relevant state and federal regulations associated with the site…………..……..1-2

3.1 Permit type(s)

3.2 Installation & Training Requirements

3.3 Pollution Prevention Measures

3.4 Reporting Requirements

4.0 Phase II Municipal Separate Storm Sewer System……………………...………2-3

4.1 Municipal Control Measures

5.0 References Cited………………………………………………………………….3

6.0 Appendix of photographs.……………………………………………..……….. 4-6

PAGE 1

1.0 Introduction

On October 16, 2014 a team of 13 environmental health and safety (EHS) professionals in

training, and Dr. Heather Wilkinson, Professor at Texas A & M University (TAMU) visited the

petroleum storage and pumping facility located within the Transportation Center at TAMU. The

Environmental Safety Specialist for the EHS department at TAMU, Ms. Toni Eubanks, provided a

descriptive tour of the facility and addressed all the questions the team raised. Ms. Eubanks also

led an informational discussion of the Texas A & M University Phase II Municipal Separate Storm

Sewer System. This report details the site visit with an emphasis on features associated with EHS

compliance

2.0 Features of the Site

2.1 The Transportation Center is located at 388 Agronomy Road, College Station, TX 77845.

2.2 The facility serves as the only refueling, maintenance, and repair center in College Station

for the 556 vehicles owned and operated by TAMU. The facility pumps an average of

1000 gallons per day of unleaded gasoline, 650 gallons per day of diesel, and 750 gallons

per day of B20 Biodiesel.1 The facility utilizes three 12,000 gallon capacity underground

storage tanks (UST’s) to maintain fuel inventory. The Transportation Center also

maintains inventories of oil, in varying size containers, on campus although those were

not toured during this site visit and are therefore not included in this report.

2.3 TAMU meets the Financial Assurance requirements set forward by the United States

Environmental Protection Agency2 by maintaining a Liability Account. The Liability

Account maintains two separate limits; one to cover the cost of “one daily occurrence”

and one to cover “the cost of all UST releases that might happen in one year.1

3.0 Relevant State and Federal Regulations

3.1 The facility maintains a Spill Prevention, Control, and Countermeasure Plan (SPCC),

required by the EPA and enforced by the Texas Commission on Environmental

Quality (TCEQ). This plan is designed to prevent any discharge of oil into navigable waters

or adjoining shorelines.2

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3.2 All UST’s must be registered with TCEQ within 30 days of installation. All operators of the

UST’s must complete initial safe operation training and retraining every three years. There

are three classes of Operator Permits; Class A Operators have the primary responsibility for

the UST facility, Class B Operators are responsible for the day to day operation at the

facility, and Class C Operators control the dispensing operations. All UST’s are required to

be installed by licensed installers only and supervisors must be on site during the

installation process.

3.3 All UST’s must have corrosion protection, release detection, spill and overfill prevention,

and Stage I & II Vapor Recovery systems. Corrosion protection is provided by the use of

Sacrificial anodes placed inside of the UST’s, and the use of non-corrodible materials in the

manufacture of the UST’s. The anodes must be tested 3-6 months after install and every 3

years after that. TAMU utilizes an automatic tank gauging and inventory control system

(Figure 1) as the primary, and a manual measure and record system as the secondary means

of leak detection. Various spill and overfill prevention measures used at the facility are

found at the fueling center (Figure 2). These include spill containment equipment; cat litter

for small spills, and berms for larger spills. There are emergency shut off valves (Figure 3),

quick release hose fittings, audible and visual alarms, as well as warning/caution signage.

(Figure 4). Stage I & II Vapor Recovery Systems capture vapors that escape during fuel

transfers. Stage I captures vapors released during fuel delivery into UST’s and Stage II

captures vapors released during refueling of vehicles.

3.4 Any leak that occurs in excess of 25 gallons or results in a sheen on surface water must be

reported to TCEQ within 24 hours of occurrence. A corrective action plan must also

accompany the report of a spill.

4.0 Phase II Municipal Separate Storm Sewer System

4.1 TAMU operates a Municipal Separate Storm Sewer System (MS4 ) that is comparable to a

small municipality. To maintain compliance TAMU participates in Municipal Control

Measures (MCM’s) designed to increase awareness of and decrease contributions to storm

water pollution. MCM 1 focuses on Public Education and Outreach and is facilitated through

community, employee, and student education of storm water pollution prevention techniques.

MCM 2 is based on Illicit Discharge Detection and Elimination. The EHS department at

TAMU conducts 2 official inspections per year of storm sewer outfalls and has a hotline

number the public can use to make notification of potential Illicit Discharges. MCM 3

PAGE 3

requires all Construction Contractors to “select, install, implement, and maintain stormwater

control measures that prevent illicit discharges.”1 MCM 4 pertains to post-construction storm

water management and encompasses new developments as well as redeveloped areas. MCM

5 pertains to Good Housekeeping practices that ultimately will prevent or reduce the amount

of pollution runoff from the TAMU campus.

5.0 References

1) http://transport.tamu.edu/Fleet/facts.aspx

2) https://ecampusprod.tamu.edu/webapps/blackboard/execute/content/file?cmd=

view&content_id=_945326_1&course_id=_29988_1

PAGE 4

Fig. 1 Gilbarco Automatic Tank Gauging and Inventory Control System. Provides constant fuel level

measurements and sounds an alarm when a leak in the UST is detected. This system is used in

conjunction with a manual read and log system for fuel inventory.

Fig. 2 Spill prevention equipment located directly on the fueling center. Supplies to

contain a spill (cat litter or a containment berm) are kept in a cabinet sitting directly

next to the fuel dispensing pumps.

PAGE 5

Fig. 3 Emergency Shut Off Valve. Located at fueling center; this can be used in the event of a

spill to immediately discontinue the flow of fuel from the pumps.

Fig. 4 Warning and caution signage directly on fueling center.

PAGE 6

Fig. 5 Stage I Vapor Recovery System. Vapors released during fuel delivery into UST’s are

captured and returned to the fuel delivery truck.

Fig. 6 Stage II Vapor Recovery System captures gasoline vapors when a vehicle is being fueled at

the pump. The vapors are returned through the pump hose to the petroleum storage tank

instead of being released into the air.