petroleum storage tanks and stormwater site visit report · 2019-08-15 · case, cat litter) is...
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Petroleum Storage Tanks and Stormwater Site Visit Report Thursday, October 16, 2014
Prepared by: Elora Arana, Environmental Studies student
Prepared for: Dr. Heather Wilkinson, Professor – BESC 489/411
Texas A&M Fleet Services
388 Agronomy Rd., College Station, Texas 77840
White’s Creek
600 John Kimbrough Boulevard, College Station, TX 77843
Background and Introduction
The BESC Environmental Health, Safety and Compliance class traveled to the Texas A&M
Fleet Services facility and White’s Creek Stormwater discharge channel on Thursday, October
16, 2014. Under the supervision of Dr. Heather Wilkinson and Toni Eubanks, EHS Safety
Specialist, we examined Texas A&M University’s petroleum underground storage tanks and
stormwater discharge channel across from the AGLS Building on West Campus.
According to the Fleet Services website (source 1), the facility provides unleaded, diesel
and biodiesel fuels for the TAMU transportation fleet and government vehicles owned by the
university. It also provides mechanical services to university owned vehicles and rental vehicles
for employees. To utilize this facility, employees drive their state‐owned vehicles up to the
pump stations and charge the fuel to a unique key that they are given for that vehicle. The fuel
costs are then billed to the respective department or organization. There is no exchange of
funds for the fuel at the facility by users.
The discharge channel that was visited at White’s Creek acts as a primary source of
stormwater containment and drainage from surrounding areas, surfaces and drains. The
channel is also built to minimize sediment erosion from the creek banks when where is an
increase in the velocity of the water in the system. Load varies dramatically with student
population fluctuations during the year.
Figure 1 – Ultra Low sulfur Diesel pump at Fleet Services facility
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Figure 2 – Pump filling stations at Fleet Services. Customer is pulled up to pump that
corresponds with the fuel type for their vehicle and monitors the transfer of fuel from the
station to the vehicle.
Figure 3 – Main pump fuel terminal where customers enter their key before fueling. Keys are
used to charge the fuel to a connected account.
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Processes with potential for pollution
At the fleet services facility, there is a fairly high incidence of fuel spilling to the ground
from the filling stations to the vehicle, especially from transportation buses since they do not
have an automatic fuel shut off sensor (figure 4). When this occurs, customers and staff at the
facility can remediate small scale spills to the ground using a nearby spill recovery cabinet that
contains materials to contain and absorb spilled fuel (figure 5). A solidifying absorbent (in their
case, cat litter) is regularly applied around the pumps to help absorb any spilled fuel, and a
small, white containment berm, referred to as a “snake” is used to contain fuel spills (figure 6).
Figure 4 – Diagram of an Automatic Shutoff Valve from a vehicle’s gas tank
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Figure 5 – Spill prevention supplies cabinet near pump stations with a broom to spread and pick
up cat litter used for spills.
Figure 6 – Supplies inside spill prevention cabinet, including the white “snake” berm
containment, cat litter and brooms.
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There is the potential for overflowing of fuel if employees are not paying attention to
fuel levels inside of the underground storage tanks (UST’s) when refilling them. Leakage can
also occur if the tank becomes corrodes or the integrity of the protection mechanisms become
compromised in anyway.
At the stormwater discharge site, sediment erosion from the banks of the creek can
occur when stormwater levels rise and sweep away the loose soils and sediments that are not
as tightly compacted closer to the top of the bank. This causes pollution of the creek and affects
the water species that live in the creek.
Chemicals used at the facility
The sacrificial anodes of the cathodic protection (figure 7) used for the corrosion
protection for the PST’s utilizes magnesium and zinc to protect the tanks because they are
more corrosive than the steel tank and help prevent corrosion of the tank.
Microblaze is used by both facilities to clean up large spills by rapidly degrading organic
compounds and hydrocarbon contaminants, eliminating vapors and lower explosion limits
(LEL’s) (source 2 – Microblaze website).
Figure 7 – Diagram of a cathodic protection anode corrosion system illustrating the impressed
current anode system
Pollution Control and waste minimization (air, toxics, water, waste, etc.)
All spills are contained, remediated and monitored by specifications found in the Texas
A&M university‐wide Spill Prevention, Control, and Countermeasure Plan (SPCC). The plan is in
place to help prevent pollution and discharge of regulated wastes, such as fuel and chemical
products, into navigable waters of the US. This plan is maintained and monitored by Texas A&M
Environmental Health and Safety (EHS), as well as any other organizations and employees that
can potentially affect this plan, including Fleet Services.
The area that Fleet Services is built on is intentionally designed and was built to slope
downward from the outside towards the pumps in order to collect any liquids or fuel that might
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accumulate in a spill incident and to keep spills localized. There are also no drains in the area to
prevent spills material from running off into the stormwater system. (Refer to Figure 2)
Corrosion protection also allows for the checking of fuel leaks within the system
because if corrosion protection is compromised, this would indicate that fuel has leaked into
the area of the protection that is supposed to be fuel‐free and allows for the facility to shutoff
the tank and make repairs.
Daily inventory worksheets are another form of leak detection. By monitoring the levels
of fuel in and out of the tank on a daily basis and looking for large discrepancies, the facility is
able to detect if there is a leak in the system when numbers are not adding up over a series of
days.
Quick release valves in fuel pumps (also known as check valves) release and stop the
flow of fuel out of the pump when they detect a certain amount of force on the hose, usually
indicative of when customers forge to remove the hose from the vehicles gas tank.
At White’s Creek, concrete chunks and rocks are added to the banks of the creek to help
with erosion and sediment control by helping to compact looser soils farther up on the bank
that are more susceptible to being swept away during large rain events when the water levels
are higher and there is a greater velocity of water running through the creek.
TAMU EHS hosts Stream Clean‐Up’s for the streams and creeks around the Texas A&M
campus that allow volunteers to go into safe areas of these streams and creeks and pick up
trash that has accumulated on the banks of these water systems.
Relevant state and federal regulations associated with the site
Plans and guidelines o SPCC Plan
Renewed every 5 years A facility must prepare an SPCC to help prevent the discharge of
regulated wastes (oil) into the navigable waters or adjoining shorelines Main purpose is for prevention as opposed to reactionary measures
o RG‐411 – Investigation and Reporting Releases from Petroleum Storage Tanks Regulatory guide that includes good tips to know for this regulation
Permit types 40 CFR 112 – Oil Pollution Prevention
Contains the SPCC plan and applicable regulations mentioned above
33 CFR 329.4 – Defines Navigable Waters 30 TAC 334 – Underground and Above Ground Storage Tanks
Offers information about installation construction notifications and deadlines and guidelines to registering a tank within 30 days of adding petroleum products to the tank.
TXR040000 New permit issued in Dec. 2013
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Defines TAMU as a Phase II, Level 2 Non‐Traditional MS4 Must submit an Notice of Intent (NOI) and Stormwater
Management Plan (SWMP) within 180 days of new permit Municipal Separate Stormwater System (MS4) very similar to a
city, but with unique attributes Residential population varies by season Exists within 2 separate MS4’s (Bryan, College Station)
Minimum Control Measures (MCM’s) 1‐5 MCM1: Public Education, Outreach and Involvement.
TAMU participates in this several ways, including hosting events such as Stream Clean, New Student and Staff Orientation and participating in campus Sustainability and Earth Days. TAMU EHS is also a part of the Brazos Basin Stormwater Education Committee (BBSEC) and any efforts done by any of the participating entities will count towards credits for the other participating entities.
MCM2: Illicit Discharge Detection and Elimination. In place to help identify preventable discharges and stop them from occurring. There is a specific Spill Team at EHS that detects, investigates and helps to eliminate illicit discharges. Use maps developed in house by GIS personnel in Utilities to trace back potential sources of illicit discharges.
MCM3: Construction Site Stormwater Runoff Control. Includes procedures for creation and enforcement of a plan for small and large construction activities to prevent illicit discharges to the stormwater systems. TAMU EHS implements an inspection program that involves a site visit every 2 weeks and within 24 hours of a storm event, or every 7 days, regardless of storm events.
MCM4: Post‐Construction Stormwater Management in New and Redevelopment. Develops and implements plans to control and prevent illicit stormwater discharges from new or redeveloped sites; EHS mainly uses this to deal with erosion control.
MCM5: Pollution Prevention and Good Housekeeping for Municipal Operations. Used to prevent and reduce pollutant runoff from municipal operation and is an operation and maintenance program that includes employee training. At TAMU, this includes street and road maintenance, such as the “street sweepers” maintained by Utility and Energy Services, park and open space maintenance and fleet maintenance, maintained by TAMU Transportation services.
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MCM6 does not pertain to TAMU and MCM7 is optional and no one in Texas, including TAMU, has opted into this control measure because of the increase in liability issues.
TPDES
Required monitoring
Corrosion protection (cathodic protection) (refer to figure 7) o Check 3‐6 months after installation, then again every 3 years
MCM3 o Must check construction sites within 24 hours of a storm event and every two
weeks, or every week, regardless of a storm event. TAMU EHS must monitor creeks annually
o Walk the length of the creeks and visually inspect for illicit discharges
Report schedule
Annual pump and valve test Annual LDAR testing (sources 3 and 4 – Sage Environmental and EPA)
o Testing of valve and pumps for leaking volatile organic compounds (VOC’s) to the atmosphere
o Outside contractor Annual tightness test
General Comparison to a municipal or industrial version of this entity
Production function and volume
There are three petroleum storage tanks – one low sulfur diesel, one biodiesel and one
unleaded gasoline. Each tanks holds 12,000 total gallons. Roughly 2,300 gallons of diesel is
pumped per day and roughly 600 gallons of unleaded gasoline is pumped per day.
The volume of the discharge channel varies widely with rain events that occur.
How these distinctions affect the threshold for regulation of this entity?
Since Fleet Services and the White Creek channel are both a part of a larger EMS system,
they share many of the same permits that they university is regulated under. At Fleet Services,
small spills and incidents can be handled at the site, and larger incidents may need the
assistance of the TAMU EHS Spill Team for clean‐up and reporting. Their permits also include
facilities and objects not under Fleet Services direct control .
References Cited
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In Text Sources Source 1: "Fleet Facts and Figures." Fleet Facts and Figures. TAMU Transportation Services, n.d.
Web. 23 Oct. 2014. <http://transport.tamu.edu/Fleet/facts.aspx>.
Source 2: "Micro‐Blaze® Microbial Products." MicroBlaze. Verde Environmental Inc., n.d. Web.
23 Oct. 2014. <http://www.micro‐blaze.com/site/>.
Source 3: "Leak Detection and Repair (LDAR)." Leak Detection and Repair (LDAR). Sage
Environmental Consulting. Web. 23 Oct. 2014.
<http://www.sageenvironmental.com/air_quality/ldar>.
Source 4: Leak Detection and Repair: A Best Practices Guide. Washington D.C.: Environmental
Protection Agency, Oct. 2007. PDF.
Additional Sources
"WHITE CREEK (BRAZOS COUNTY)," Handbook of Texas Online
(http://www.tshaonline.org/handbook/online/articles/rbw83), accessed October 23, 2014.
Uploaded on June 15, 2010. Published by the Texas State Historical Association.
Spill Prevention, Control, and Countermeasure (SPCC) Rule. Washington D.C.:
Environmental Protection Agency, May 2011. PDF.
Operating And Maintaining Underground Storage Tank Systems. Washington D.C.:
Environmental Protection Agency, Sept. 2005. PDF.
Storm Sewer Outfall Inspection. College Station, Texas: TAMU EHS, Mar. 2013. PPT.
Toni Eubanks, Environmental Safety Specialist, TAMU Environmental Health and Safety,
College Station, Texas, [email protected], 979‐845‐6207
Stormwater Phase II Final Rule. Washington D.C.: Environmental Protection Agency,
Dec. 2005. PDF.
"General Permit TXR040000 for Phase II (Small) MS4s." General Permit TXR040000 for
Phase II (Small) MS4s. Texas Commission on Environmental Quality, n.d. Web. 23 Oct. 2014.
<http://www.tceq.texas.gov/permitting/stormwater/WQ_ms4_small_TXRO4.html>.