storage tank systems for petroleum products and …storage tank systems for petroleum products and...

Storage Tank Systems for Petroleum Products and Allied Petroleum Products

Regulations ESAM Lunch and Learn

Dartmouth, NS

October 12, 2016

Part 2 of 2

October 12, 2016

1. Purpose of the Regulations

2. Authority

3. Application

4. Responsibility

5. Critical Timelines

6. Definitions

7. Overview of the Regulations

8. Summary

9. Resources

Outline of Presentation

– October 12, 2016

October 12, 2016

Leak detection

• Should be part of regular operation and maintenance of storage tank system

7.5 Leak Detection

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What are the leak detection requirements?

• Leak detection by June 12, 2010 • Ongoing leak detection or

monitoring on prescribed frequency

7.5 Leak Detection

5 – October 12, 2016

Single-walled underground storage tanks: • Precision leak test by June 12, 2010

Then: • annual precision leak test, or • use automatic tank gauging, or • use continuous in-tank leak detection

7.5 Leak Detection

October 12, 2016

Horizontal aboveground storage tanks without secondary containment:

• Visually inspect walls for leaks by June 12, 2010 Then: • annual precision leak detection test, or • monthly visual inspection of walls and inventory

reconciliation at least weekly, or • continuous in-tank leak detection, or • continuous external leak monitoring

7.5 Leak Detection

October 12, 2016

Vertical aboveground storage tanks without secondary containment:

• Specified inspection by June 12, 2010 • Then:

– specified inspection at ten year intervals, or – use continuous in-tank leak detection, or – use continuous external leak monitoring as

prescribed

7.5 Leak Detection

October 12, 2016

7.6 Product Transfer Areas

s.1 • “transfer area” means the area around the connection point between

a delivery truck, railcar, aircraft or vessel and a storage tank system in which the tanks have an aggregate capacity of more than 2 500 L.

• “spill” means any loss of a petroleum product or an allied petroleum product in liquid form from a storage tank system, including a loss during a transfer of such a product to or from a storage tank system, but not including a loss that does not reach outside the storage tank system’s secondary containment.

October 12, 2016

7.6 Product Transfer Areas

s.15(1) • The owner or operator of a storage tank system must ensure that

petroleum product and allied petroleum product transfer areas are designed to contain spills that occur during the transfer process.

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7.6 Performance Based approach Performance-based requirements: • state the objective • let stakeholders determine how to achieve the objective • allow flexibility for unique situations PTA design should include a combination of:

– Permanent or temporary physical containment – Standard operating procedures to reduce risk – Training

The owner/operator should be able to explain how the PTA is designed to contain spills.

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7.6 Recommended Steps to Design a PTA

1. Assess the storage tank system and its surrounding environment

2. Identify potential accidents that could happen during product transfer

3. Design ways to prevent and contain spills

4. Implement and test the design

5. Document the results

6. Revise the design if changes are needed

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7.6 PTA design process

Assess STS and

environment

Identify potential for

spills

Design spill management

Implement and test design

Document the results

Revise as necessary

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Aspects of the STS and its environment to assess: • Site • Site history • Equipment • Delivery vehicle • Operating Procedures

Step 1: Assess the STS and its Environment

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Step 2: Identify potential accidents that could happen during product transfer Some spill scenarios and their resultant spill volumes: • Fuel delivery vehicle striking tank causing catastrophic failure

– High volume, up to the volume of the tank itself and possibly the volume of the truck as well

• Spill from hose becoming uncoupled during delivery

– Volume based on flow rate, and time before shut-off

• Spill from hose being incorrectly uncoupled at truck. – Volume of the hose. A hose 10 feet long with a 4 inch diameter will contain

approximately 25 L of product.

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Examples of preventative measures that could be incorporated into a PTA design:

Prevention: • Standard operating procedures (SOP) based on the CPPI

Professional Driver’s Manual (2009) • collision protection installed as per the National Fire Code of

Canada. • personnel training

Step 3: Design ways to prevent and contain spills

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The PTA should be designed to contain the largest spill volume from previously identified potential incidents. Here are some examples of containment measures that could be incorporated into a PTA design:

Containment: • Dikes around the paved area that can contain spills, as well as

SOP that require blocking the drain during refuelling

• Sloped pavement so that any run-off would go into a sump or oil-water separator

• For a gravel surface install a geomembrane liner under a few inches of the gravel that would contain spills

• deploy a temporary berm during fuelling at both connection points

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Use water to simulate the conditions of a likely spill scenario. The amount of water used should be the likely spill volume previously identified.

Step 4: Implement and test your design

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Good documentation helps demonstrate compliance. Good documentation includes: • Site assessment • Volume calculations for spill scenarios • Plans for containing spill volumes • Pictures and records of testing • Pictures of operational methods where applicable Along with anything else that will demonstrate how your PTA has been designed, implemented, and how it will manage product transfer.

Step 5: Document the results

October 12, 2016

Step 6. Revise the design if changes are needed

• Evaluate the PTA test results

• Identify any problems

• Update the PTA to address the problems

• Test the updated PTA as needed

• Document as required

• Repeat this process as necessary

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Example: Whale Tank - Secured Site

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Example: System Protection

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Example: Connection Point Impact Protection

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Example: Normally-Open Catchment Drain

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• Identify potential hazards, establish systems for preventing leaks/spills and provide mechanisms for minimizing risk, loss and damage

• In the event of leak/spill provide owners, operators and emergency response personnel with guidance for a timely and effective response (e.g. to minimize health, safety and environmental impacts)

7.7 Emergency Plans – in general

October 12, 2016

• The emergency plan must be keep up-to-date

• The emergency plan must be ready to be implemented

• A copy must be located where the storage tank system is located if that place is a place of work

• When identifying a storage tank to ECCC, the owner or operator should inform ECCC of the civic address of each location where the emergency plan is kept

7.7 Emergency Plans – in particular

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• Emergency Plans can differ greatly in their structure depending on a number of factors (e.g. # of tanks, size of organization, site characteristics, etc.), but effective plans have many things in common

• An emergency plan must be prepared for each STS

7.7 Emergency Plans – components

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Considerations for preparation of emergency plans s. 30(1)

• Product stored: –Properties –Characteristics –Max Quantity

• Site and surrounding area: – Characteristics – Risk of harm

7.7 Emergency Plans - Details

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Contents of plan s. 30(2)

Description of factors considered under s. 30(1) Description of measures taken to prevent, prepare for, respond to and recover from any emergency

List of individuals to implement plan, including roles

Identification of training required

List of emergency response equipment and their location

Measures to notify members of the public

7.7 Emergency Plans - Details

October 12, 2016

Tell Environment and Climate Change Canada the locations where emergency plans are kept. Notification can be done by: • e-mail to ec.registrereservoir-

[email protected] • fax to 819-938-4454 • inputting Identification Form

data in FIRSTS

7.7 Emergency Plans

October 12, 2016

7.7 Emergency Plans

Considerations for assembling a Spill Kit: • Location of kit • Secure container (weighted, breakable seal) • Volume of the worst case PTA spill • Land based or water based spill

– Some absorbents pick up all liquids, some will pick up hydrocarbons but will not absorb water

• Containment items: booms, pillows, pads, particulate • The inclusion of PPE (packed at top of kit) • Traffic cones, flagging tape, etc.

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Spill Containment

Product Transfer

Area

Emergency Plan

Spill Kit

7.7 Emergency Plans in context

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If no - supervised by professional engineer

7.8 Approved Installers

Province Require licensed installer contractor?

Require licensed removal contractor?

NS Yes Yes

NB Yes Yes

PEI Yes Yes

NL No No

October 12, 2016

Regular Operation and Maintenance is the key to safe & environmentally responsible operation of your storage tank system

-e.g. empty water from secondary containment The regulations have specific

requirements for oil-water separator maintenance and disposal from oil-water separators.

7.9 Operation and Maintenance

October 12, 2016

Do not use secondary containment for storage!

7.9 Operation and Maintenance

October 12, 2016

Spill reporting requirements s.41

• Verbal notification as soon as possible

Atlantic Canada 1-800-565-1633 Newfoundland and Labrador 1-800-563-9089

• Written follow-up for spills 100 litres or larger

7.10 Release Reporting

October 12, 2016

Temporary withdrawal s.43

• Either returned to service (<2 yrs) or becomes permanent

• Cathodic protection maintained

• If withdrawn for > 1 year

– Precision leak detection for USTs or shop-fabricated ASTs

– Internal inspection for field-erected ASTs

• Label affixed to fill pipe

• Keep record with date of withdrawal

7.11 Withdrawal from Service

October 12, 2016

Permanent withdrawal s.44

• Remove and dispose of liquids and sludge

• Vapours purged to less than10% of lower flammability limit (verify via combustible gas meter)

• No immediate or long-term harmful effects

• Label affixed to fill pipe

• Keep record with date of withdrawal

• Written notification to Minister within 60 days

• Must be removed, except field erected


October 12, 2016

Removal of system s.45

• Must be completed by approved person or supervised by P.Eng.

• Appropriate records kept


October 12, 2016

ID & New installations

• ID of system s.28(2) – Information and certification Schedule 2

• Design and construction records

– Installer or supervision s.33(2) – Design plans, drawings & specifications s.34(1) – As-built drawings s.34(2)

Keep these for the life of the tank!

7.12 Record Keeping

October 12, 2016

Operation and maintenance

• Leak tests or inspections of any component

• Free oil and separated solids thicknesses for oil-water separators

• Disposal of free oil and separated solids and liquid discharge from oil-water separators

• Disposal of tank bottom water

Keep for 5 years

7.12 Record Keeping

October 12, 2016

Emergency plans and releases

• Up-to-date emergency plan both on-site and available to responsible persons s.31(1)

• Spill report for product 100 liters or larger s.41

Keep copy of spill report

7.12 Record Keeping

October 12, 2016

Temporary withdrawal

• Date of withdrawal s.44(2)

• Proof of operation of cathodic protection system s.43(a)

• Results of leak tests or inspections on tanks out of service for more than a year

7.12 Record Keeping

October 12, 2016

Permanent withdrawal and removal

• Date of withdrawal s.44(2)

• Withdrawal by approved person or supervised by P.Eng. s.44(1)

• Liquid and sludge disposal s.44(3)

• Proof of tank purge s.44(3)

7.12 Record Keeping

October 12, 2016

• Identify the system

• Leaking systems – temporarily withdraw from service and manage as needed

• Product Transfer Area & Emergency Plan

• Arrange for removal of single-walled underground tanks and piping as necessary

• Removals and installations by approved people

• Evaluate tanks systems against “high risk” criteria and manage as needed

• Arrange for leak detection as needed (one-time and ongoing)

• Report all spills

• Keep records of above

8. Summary - For storage tank systems:

October 12, 2016

• EC’s Storage Tank website for Petroleum and Allied Petroleum Products – http://www.ec.gc.ca/rs-st/

includes Contact Information and Fact Sheets (Tank Tips)

• CCME Environmental Code of Practice for Aboveground and Underground Storage Tank Systems Containing Petroleum and Allied Petroleum Products – https://www.ec.gc.ca/lcpe-cepa/default.asp?lang=En&n=61B26EE8-1

• Compliance and Enforcement Policy for the Canadian Environmental Protection Act, 1999 – https://www.ec.gc.ca/lcpe-cepa/default.asp?lang=En&n=66B8D849-1

• National Fire Code of Canada – http://www.nrc-cnrc.gc.ca/eng/publications/codes_centre/2015_national_fire_code.html

9. Resources

October 12, 2016

Chris Feetham Senior Compliance Promotion Officer, Environmental Stewardship Branch Environment and Climate Change Canada / Government of Canada [email protected] / Tel: 902-426-2401 Agent principal en promotion de la conformité, Direction générale de l'intendance environnementale Environnement at Changements climatiques Canada / Gouvernement du Canada [email protected] / Tél. : 902-426-2401

For Information Please Contact

storage tank systems for petroleum products and …storage tank systems for petroleum products and...

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