this presentation does not claim or imply that it addresses all environmental and safety-related...

This presentation does not claim or imply that it addresses all environmental and safety-related issues - if any - associated with its use. Manufacturing concrete products may involve the use of hazardous materials, operations and equipment. It is the user’s responsibility to determine appropriate safety, health and environmental practices and applicable regulatory requirements associated with the use of this presentation and the manufacture of concrete products.

Use of this presentation does not guarantee compliance with regulatory agency requirements. For further information on specific rules pertaining to tanks, totes, and drums - as well as containment requirements at your facility - check with your local, regional or state agencies.

Storage Tanks and Precast Facilities

West Virginia

Last year, a chemical storage tank leaked into the Elk River. This spill of approximately 10,000 gallons left hundreds of thousands of people without access to tap water.

Could this happen at your facility? What is a Storage Tank? What is a Stormwater Pollution Prevention Plan? Training of employees, spill prevention and conducting inspections. Does my facility need a Spill Control and Countermeasures Plan?


Could this happen at my facility?

Although a precast facility may not have a single 10,000 gallon storage tank, many facilities have a multitude of chemicals in bulk storage containers. Examples of these chemicals include admixtures, curing agents, diesel fuel, kerosene, gasoline, form releases and oils. A discharge of a harmful quantity from one of these storage tanks could significantly impact the environment, particularly if the discharge reaches a river or waterway. A harmful quantity could be any quantity that violates state water quality standards, causes a film or sheen on the water’s surface, or leaves sludge or emulsion beneath the surface.


What is a Storage Tank?

Storage tanks come in a variety of shapes and sizes. The EPA does not use the term "storage tank.“ Instead, the term "bulk storage container" is used. A bulk storage container is 55 gallons or larger, so everything from a drum to the 10,000 gallon or larger diesel Aboveground Storage Tank (AST) at your facility is a Bulk Storage Container.


Example Storage Tanks (Containers) Single-wall Aboveground Storage Tank (AST)

Has one wall to contain the contents of the tank, typically older fuel and oil tanks were single-wall construction. Some form of containment is required when storing oil.

Typically admixture tanks are single-wall polyethylene tanks. Industrial Bulk Containers (IBC) totes and drums are typically single-wall.

Double-wall AST The primary tank is wrapped by an exterior tank that may be in contact with the primary tank (a tank

within a tank). The outer tank has the capacity to capture the inner tank contents should a leak develop. This interstitial space between the tanks can be checked for signs of leakage during regular inspections.

Industrial Bulk Containers (IBC) Totes Typically these totes are single-wall and range in size from 275 to 330 gallons. Many chemicals such as

admixtures and form oils are shipped in totes. Containment would also be required if storing oil.

Drums 55 gallon Drums are an industry favorite for a variety of chemicals at a precast facility. They come in a

multitude of materials and sizes ranging from 10 gallons all the way to 95 gallons. Some form of containment is required when storing oil.

Note: For further information on specific rules pertaining to tanks, totes, and drums, as well as containment requirements at your facility, check with your local, regional or state regulatory agencies. Additional precautions may be needed.

Storage Tanks and Precast FacilitiesExample Storage Tanks (Containers)

Single-Wall Steel AST in Plastic Containment Steel Oil ASTs not in Containment 10,000 Gallon Diesel Double-Wall Steel AST

55 Gallon “Oil” or Larger Drums Plastic Admix Tanks in Containment Industrial Bulk Containers (IBC Totes)


What is a Stormwater Pollution Prevention Plan?

As a precaster, your facility falls under your local or state’s National Pollutant Discharge Elimination System (NPDES) program or the EPA’s Multi-Sector General Permit for Industrial Activities. Both of these programs require a Stormwater Pollution Prevention Plan (SWPPP). The plan is a written document that identifies the industrial activities conducted at the site – including any structural control practices – which the facility will implement to prevent pollutants from making their way into stormwater runoff. The SWPPP also must include descriptions of relevant information, such as the physical features of the facility, best management practices, training of employees, procedures for spill prevention and conducting inspections.


Employee Training

So why do my employees and I need to be trained? Training is required for all employees who work in areas where industrial materials or activities are exposed to stormwater, or who are

responsible for implementing activities necessary to meet the conditions of the permit. (SWPPP) To recognize potential pollution sources and identify pollution prevention techniques.

(SWPPP & SPCC) Identify Spill Pathways. (SWPPP & SPCC) To use Best Management Practices, Spill Response and Cleanup Procedures. (SWPPP & SPCC) To inform employees of SWPPP and SPCC requirements. (SWPPP & SPCC) Training is to be provided at least annually. (SWPPP & SPCC) Training is required to inform personnel involved in oil storage or maintenance of tanks about proper actions to take in the event of a

spill. (SPCC) Training updates will be conducted whenever a significant change has been made to any oil storage or use (e.g., new tank installation

or process). (SPCC) Training will also be conducted whenever a new employee is assigned to oil handling, maintenance duties or spill response. (SPCC)

Without documentation, the training didn’t happen.


Spill Prevention Establish procedures for training, spill prevention and cleanup. Locate potential pollutants and storage tanks so that leaks/spills cannot reach a storm drain or waterway. Create a Pollution Prevention Team to implement and maintain Best Management Practices (BMPs). Designate a person at your facility who is accountable for spill prevention and who reports to facility management. Spill response can be proactive (engineering-based control such as containment) or reactive (contain spill with absorbent materials).

Proactive measures are generally preferred. Spill cleanup supplies such as absorbent pads, oil-dry, brooms and shovels, and empty drums should be staged in areas accessible

to employees in case of a spill. In the case of large spills, sand could be used to prevent liquids from entering stormwater systems or other environmentally sensitive

areas. Review your SWPPP as it will outline BMPs that will help reduce the pollutants in stormwater discharges from the facility to ensure

compliance.

All spills should be cleaned up immediately!


Conducting Inspections (Not Just Storage Tanks)

Conducting regular visual inspections of designated equipment, activities, material handling areas, storage tanks, chemical and waste storage areas, material hoppers and silos, dust collection systems, wash down and cleaning areas, and best management practices shall be conducted and documented as designated in your SWPPP.

The inspections shall occur when the facility is generally in operation and the equipment, system and/or area can safely be inspected. Tracking or follow-up procedures shall be used to ensure that appropriate corrective actions are taken, where identified. The completed, signed and dated inspection form along with documentation of corrective actions should be filed and retained within the SWPPP.

Without documentation, the inspection didn’t count.


Storage Container (Tank) Inspection Basics: Perform the inspection only when the tank or tank area can safely be inspected. Conduct the inspection during use (off-loading of new material or while in use). Inspect the exterior of the tank. (Is the exterior in good condition? Is the tank showing signs of wetting,

discoloration, blistering, bowing, corrosion, cracks or leaks?) Inspect the tank foundation. (Is the foundation cracked, rusted or showing signs of failure?) Inspect the containment area (or interstice of double-wall tanks, if applicable) and verify it is dry, with no

accumulation of trash or other debris. Inspect the vents, gauges, pumps, hoses, dispensers and alarms for leaks and proper operation where applicable. Is the tank construction compatible with the material stored? Verify the bungs, fill ports and valves are capped, closed and locked when not in use. Are labels and placards appropriate and legible for the contents of the container? Are spill kits or supplies located near or at the tanks? If applicable, are emergency shutoffs labeled and operating?

Document, maintain records of inspections and complete corrective actions.

Example 1000 Gallon Double-Wall Off-Road Diesel Tank

Spill Kit Present(Good BMP)

Fuel Tank Protection (Barrier Wall)

Trash ReceptaclePresent (Good BMP)

Concrete Slab/Foundationin good shape, under the AST as well.

Is the tank grounded?


Double-Wall Fuel Tank Inspection Example: Stand back from your fuel tank and look at it as a whole. Look at the placards, labels, condition of the paint, corrosion, legs,

saddles, level gauge, overfill alarms, spill buckets, interstitial monitor (gauge), vents, emergency vents and electrical service.


Double-Wall Fuel Tank Inspection Example: Open the fill bucket and check for leaks. Is there any residual fuel? If

equipped, is the drain plunger operational?Drain (plunger)

Cam-Lock Cap

Fill Bucket Dry?

Fill Bucket locked when not in use?

Does your fuel supplier use the fill port?


Double-Wall Fuel Tank Inspection Example: Does your gauge operate? Do you know the full and empty measurements? When is the last time you tested the overfill alarm?

Level Gauge

Overfill Alarm


Double-Wall Fuel Tank Inspection Example: Example Overfill Alarm Alarm sounds when

TEST switch is depressed and when the float is activated.

Low Battery indicator blinks when TEST switch is depressed if new battery is needed.

Overfill Alarm indicator blinks when TEST switch is depressed and when float is activated.

SILENCE/TEST switch.


4 in. Steel Bung/Plug

Primary Tank Emergency Vent(Do not use a hammer to loosen on flammable or combustible liquids.)

InterstitialEmergency Vent

(Do not use a hammer to loosen on flammable or combustible liquids.)

Double-Wall Fuel Tank Inspection Example: Are your emergency vents operating? (Will they open and close?) Are all bungs/caps properly secured? Can they be easily opened to remove fuel?


Double-Wall Fuel Tank Inspection Example: Do you have a primary vent? Is it open? Is anything blocking it? (Bird/Wasp Nest)

Can water enter the tank?


Double-Wall Fuel Tank Inspection Example: Is the dispenser operating properly? Are there any leaks? Is the electrical properly installed?

Is the dispenser handle operating properly?

Can you lock the dispenser handle?

Is the hose in good shape? Any cracks? Has it been run over?

When was the filter last changed?

Electrical conduit in good shape? (It should be rigid, explosion-proof when a gasoline tank is present?)

Is the interstitial (leak) gauge operating?


Does my facility need a Spill Control and Countermeasures Plan (SPCC)? I have a Stormwater Pollution Prevention Plan (SWPPP). Why do I need an SPCC

Plan? Although the SWPPP covers the potential pollutants at your facility, if you store any type of petroleum-

based products (diesel, gasoline, kerosene, motor oil, hydraulic oil, transmission fluid, greases, form release agents, form release oil, biodegradable releases or oils, petroleum-based paints) at your facility, you may need an SPCC.

If you have a total aboveground oil storage capacity greater than 1,320 gallons or a completely buried storage capacity greater than 42,000 gallons?

Most precasters will not have 42,000 gallons of buried storage, but could have 1,320 gallons of aboveground oil storage containers. These containers or tanks are portable or fixed with the capacity of 55 gallons or more.

55 Gallons, are drums included? Yes any “oil” drums of 55 gallons or greater are included in the SPCC regulation.

What about admixtures? More than likely not. Most admixtures are not petroleum-based. Verify the MSDS, SDS or check with the

manufacturer for the presence of petroleum.


Does my facility need a Spill Control and Countermeasures Plan (SPCC)? I have one 500-gallon diesel AST, two 225-gallon oil ASTs, one 275-gallon tote of

biodegradable form release and a few 55-gallon drums of grease. Do I need an SPCC?

Yes, your aboveground storage is 1,335 gallons. You would be regulated under the EPA SPCC rules.

We never fill the diesel or oil tanks full. Do we still need an SPCC? The capacity to store is independent of the actual amount stored. If you have storage for 1,320 gallons of

“oil” but never fill it, you are still regulated by SPCC.

Can I write my own SPCC Plan? Maybe. Facilities that have no greater than 10,000 gallons of storage, no individual

aboveground oil storage containers greater than 5,000 gallons and no discharges (spills) in the past three years may qualify to use the EPA’s Tier I Qualified Facility SPCC Plan Template. However, some states do not allow self-certification.

Your best bet is to contact your environmental professional or consultant for further guidance.


Where can I get further information?

Stormwater Pollution Prevention Plans EPA’s Proposed 2013 Multi-Sector General Permit

http://cfpub.epa.gov/npdes/stormwater/msgp.cfm

EPA’s Developing Your Stormwater Pollution Prevention Plan: A Guide for Industrial Operatorshttp://www.epa.gov/npdes/pubs/industrial_swppp_guide.pdf

EPA’s Ready Mixed Concrete, Crushed Stone, and Sand and Gravel Industrial Stormwater Compliance Resources http://www.epa.gov/compliance/assistance/sectors/readymix-aggregate.html

NPDES Permit Program – State Contactshttp://cfpub.epa.gov/npdes/contacts.cfm?program_id=45&type=STATE

Spill Prevention Control & Countermeasure (Oil) EPA Region 8 “Do I Need to Have a SPCC Plan?”

http://www2.epa.gov/region8/do-i-need-have-spill-prevention-control-and-countermeasure-plan

EPA Oil Spills (SPCC Guidance)http://www.epa.gov/emergencies/content/spcc/index.htm

EPA Tier I Qualified Facility SPCC Plan Templatehttp://www.epa.gov/oem/content/spcc/tier1temp.htm

EPA SPCC Guidance for Regional Inspectorshttp://www.epa.gov/emergencies/content/spcc/spcc_guidance.htm

http://cfpub.epa.gov/npdes/stormwater/msgp.cfm

this presentation does not claim or imply that it addresses all environmental and safety-related...

Documents

gallon storage tank

term storage tank

chemical storage tank

bulk storage containers

primary tank

exterior tank

outer tank

term bulk storage container