THERE may be some confusion about rules and regulations for secondary spill containment at bulk plant storage locations, but one thing is pretty clear: “most spills occur at the loading rack.”
That was the message from John Storb of Storb Environmental, who was joined in the discussion by Davis Lis of Apex Environmental and Brian Savage of Savage of Savage Associates at the Atlantic Regional Energy Expo in Atlantic City, New Jersey.
“Secondary containment is what most of us are struggling with,” Lis said, adding that if product is stored overnight in a tank truck, secondary containment is required by Environmental Protection Agency (EPA) regulations.
The Spill Prevention, Control & Countermeasures (SPCC) rule also requires companies with qualifying facilities to prepare SPCC plans that contain basic information, including company name, facility location, identity and amount of regulated (oil) substances stored at the facility, a description of the nearest potential receiving water body, and procedures for taking corrective actions and/or countermeasures in response to an oil spill. Although EPA has extended the compliance date to 2007, companies are tasked with preparing SPCC plans.
“A lot of this is up in the air,” Storb said. “Regulators haven't decided on a definition of a loading rack.”
Maintenance required
Meanwhile, bulk storage facilities should be maintaining and upgrading their tanks and equipment. Not keeping up with updating can be costly in the long run, Savage said. Replace old pumps and use back-pressure valves, he advised.
When upgrading facilities, a variety of people should be involved in the planning, including equipment suppliers, company accountants, and operations managers, said Savage.
The panel recommended the use of concrete at loading racks, but cautioned designers to insure that all seams and crevices are sealed and the concrete is certified for impermeability.
Storb cautioned about asphalt paving at racks where gasoline is loaded. “Gasoline will erode the asphalt,” he said.
One problem noted by the group applies to storage tanks that could float if there is enough liquid in the containment area prompted by a large spill.
If a facility fails an inspection and is fined, the company should challenge the report, if possible, Savage said.