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Pennsylvania DEP Aboveground Storage Tank Facility Visits
2017 NISTM PA CONFERENCE
Washington, PA
May 18, 2017
What one may expect…
• Documentation review
• Tank system visual assessment
• Follow-up
PADEP AST Facility Visits
Why do we show up?
• Review of AST Integrity Inspection Summaries (Follow-up
Inspections)
• Anonymous tips from all kinds of sources (Compliance Evaluation
Inspections)
• PADEP-certified third party installers/inspectors evaluations
(Performance Evaluations)
• Release (Incident-Response to Accidents or Events)
• Because we can visit any regulated aboveground storage tank
facility at any time (Compliance Evaluation Inspections)
PADEP AST Facility Site Visits
PADEP AST Facility Visits
RECORDS
Record Keeping Requirements
Monthly leak detection records and maintenance checklists shall be maintained for the previous 12 months.
AST Monthly Operations and Maintenance Checks
PADEP AST Facility Visits
PADEP AST Facility Visits
Records• Spill Prevention Response Plans (SPRPs) are
required when the aggregate capacity of all regulated ASTs exceed 21,000-gallons• SPCC plans are not necessarily SPRP Plans. (20
mile downstream users notification and notification list required annually)
• Operation and maintenance plans are an integral part of the SPRP, and are also required for large storage tank facilities• Doesn’t always need to be a stand alone
document, but make sure that it’s included with the SPRP, if it is not.
Other records requested
• Tank installation, inspection, modification report summaries
• Tank manufacturer installation instructions
• Other permits (Labor and Industry, Local permits, etc.)
• Facility gate logs
• Project bids, scope of work, contracts, etc.
• Cathodic protection testing
• Safety Data Sheets
• Others?
PADEP AST Facility Visits
PADEP AST Facility Visits
Let’s take a look at what is within the “emergency containment” area….
PADEP AST Facility Visits
The obvious violations…
PADEP AST Facility Visits
The obvious violations…
PADEP AST Facility Visits
Why don’t you need to use your containment drain?
PADEP AST Facility Visits
Thoughts on containment walls constructed with concrete masonry units?
Closing of emergency containment drain valves or plugs
after water is removed from emergency containment.
PADEP AST Facility Visits
PADEP AST Facility Visits
PADEP AST Facility Visits
What are the most common violations???
External Deterioration Protection
LABELING
PADEP AST Facility Visits
More common violations???
No spill containment at fill point
Wood supportNo block valve at top of the tank
Bronze block valves can’t be used
PADEP AST Facility Visits
“Wood” you believe this AST had no compliance issues identified by the PADEP-certified inspector?
PADEP AST Facility Visits
PADEP AST Facility Visits
They had an operating permit for decades
Emergency Venting Violations
Common Problems
1. Inadequate design – too small, wetted area calculations
2. Not functioning – shear pin replaced, won’t lift
3. Long bolt manholes – needs to have the ability to lift
4. Frangible roof – won’t work for smaller diameter ASTs
5. Double walled tanks – Primary and secondary both need e-vents
PADEP AST Facility Visits
8”
5Emergency Venting
Common Problems
- Inadequate design – not sized properly or just bad math.
4” 4”
Emergency Venting
Common Problems - shear pin broke
Emergency Venting
Common Problems – manway lids bolted down won’t lift under excess pressure
Emergency Venting
Common Problems – frangible roof may not work on some smaller diameter (<50 feet) ASTs.
*Refer to API 650 (Section 5.10.2.6) for design considerations
Emergency Venting
Common Problems – Double walled ASTs with no emergency vent for the secondary tank (F&C liquids)
PADEP AST Facility VisitsMany of the violations discussed up to this point could have been prevented by…
BETTERTANK MAINTENANCE
Other Items to Consider for Maintenance Checks
• Aboveground storage tank grounding/bonding • Fuel monitoring (check for presence of
water/microbes)• Cathodic Protection Rectifiers • Thermal and pressure relief systems• Insulated ASTs – check for areas of moisture,
external corrosion• Follow-up on Unsatisfactory and/or Required items
PADEP AST Facility Visits
Monthly Maintenance Checks – Good idea to keep up with the Temporarily Out of Service Tanks
PADEP AST Facility Visits
The Follow-up…
• Field Narrative (most issues are resolved this way)
• Notice of Violations (NOVs)
• Most of the remaining enforcement actions– Consent Assessment of Civil Penalty
– Consent Order and Agreements
– Field Orders
– Administrative Orders
PADEP AST Facility Visits
How much of a penalty can the PADEP assess? Per Chapter 13 Section 1307 of the PA Storage Tank and Spill Prevention Act of 1989…
(a) Assessment.--In addition to proceeding under any other remedy available at law or in equity for a violation of a provision of this act, rule, regulation, order of the department, or a condition or term of any permit issued pursuant to this act, the department may assess a civil penalty for the violation. This penalty may be assessed whether or not the violation was willful. The civil penalty so assessed shall not exceed $10,000 per day for each violation. In determining the amount of the penalty, the department shall consider the willfulness of the violation; damage to air, water, land or other natural resources of this Commonwealth or their uses; cost of restoration and abatement; savings resulting to the person in consequence of the violation; deterrence of future violations; and other relevant factors. Each violation of any provision of this act, rule, regulation, order of the department or condition of a permit, and each day of violation shall constitute a separate violation.
PADEP AST Facility Visits
So how does the PADEP Division of Storage Tanks calculate the amount of the assessed penalty?
PADEP AST Facility Visits
THE PENALTY ASSESSMENT MATRIX
PADEP AST Facility Visits
PADEP Resources:Storage Tank and Spill Prevention Act. Act of Jul. 6, 1989, P. L. 169, No. 32
Title 25, Pa Code, Chapter 245. Administration of the Storage Tank and Spill Prevention Program. January 7, 2012.
“Verification of Emergency Containment Structures for Aboveground Storage Tanks”. 263-0900-022. September 8, 2012.
“Permeability of Secondary and Emergency Containment”. 263-3300-002. September 8, 2012.
“Guidelines for the Development and Implementation of Environmental Emergency Response Plans”. 400-2200-001. August 6, 2005.
“Penalty Assessment Matrix”. 263-4180-001. September 8, 2012.
Guidance
THANKS FOR YOUR ATTENTION
ANY QUESTIONS?
Chad Clancy AST Unit Supervisor
Bureau of Environmental Cleanup and BrownfieldsRachel Carson State Office Building
PO Box 8763Harrisburg, PA 17105-8763