Secondary Containment And 'Impracticability' - San Bernardino County .
Section 5Secondary Containmentand ‘Impracticability’(as applicable to APSA tankfacilities)
Summary Secondary ContainmentRequirementsAPSA/SPCC Plan Compliance PrimerSlide 111r Several SPCC rule requirements andspecifications for controlling releases fromtanks, containers and equipment All to prevent a harmful discharge to navigablewaters Requirements located in several placed in the ruler Two basic types applicability dependson tank/container type General Containment Specific ‘sized’ Containment
Secondary Containment ProvisionsAPSA/SPCC Plan Compliance PrimerSlide 112Non-Tier I facilities (as related to APSA)Secondary Containment Required40 CFR Section(s)General containment for areas with potential forrrrrdischarge, e.g.:PipingOil-filled operational and manufacturing equipmentBulk and non-bulk loading and transfer areas (nonrack related transfer areas)Non-transportation related tank trucks112.7(c)Specific (sized) containment for:r Loading/unloading racks112.7(h)(1)r Bulk storage containers (tanks, containers) – fixed112.8(c)(2)Specific (sized) containment (and dischargeprevention positioning) for:r Bulk storage containers (tanks, containers) – mobile orportable112.8(c)(11)
Secondary Containment ProvisionsAPSA/SPCC Plan Compliance PrimerSlide 113Tier I Qualified Facilities (as related to APSA)Secondary Containment Required40 CFR Section(s)General containment for areas with potential forrrrrdischarge, e.g.:PipingOil-filled operational and manufacturing equipmentBulk and non-bulk loading and transfer areas (nonrack related transfer areas)Non-transportation related tank trucks112.7(c)Specific (sized) containment for:r Loading/unloading racks (likely not present at Tier I QFs)r Bulk storage containers (tanks, containers) – fixed112.6(a)(3)(ii)Specific (sized) containment (and dischargeprevention positioning) for:r Bulk storage containers (tanks, containers) – mobileor portable112.6(a)(3)(ii)
APSA/SPCC Plan Compliance PrimerExample Methods of Secondary ContainmentListed in 40 CFR 112.7(c)Examples include:Slide 114r Dikes, berms, or retainingwallsr Curbingr Culverting, gutters, orother drainage systemsr Weirs or boomsr Barriersr Spill diversion ponds andretention pondsr Sorbent materialsr Drip pansr Sumps and collectionsystems
APSA/SPCC Plan Compliance PrimerSlide 115Which Can a Facility Use?r Can a facility use any of the listed example methods forgeneral OR specific sized containment?r Maybe but likely not: Specific sized criteria imposes technical and engineering limitations onsome of these measures Active measures, separators (unless HUGE), sorbents, weirs or boomscan’t meet the passivisity, volume, or containment holdingrequirements of sized specific containment
Specific (Sized) Secondary ContainmentRequirementAPSA/SPCC Plan Compliance Primerr Specific ‘Sized’ Containment Address the potential of oil discharges from specific partsof or equipment at a facility where oil is stored or handled Requirements include set sizing design criteria, and minimumfreeboard intended to address catastrophic failure of bulktanks & containers and certain equipment The design decision does not rest with the PE it hasbeen dictated in the rule itself The SPCC rule specifies a required minimum sizefor secondary containment for the following areas Bulk storage containers 40 CFR 112.8(c)(2) Loading/unloading racks 40 CFR 112.7(h) Mobile or portable bulk storage containers 40 CFR112.8(c)(11)Slide 116
APSA/SPCC Plan Compliance PrimerSlide 117Specific Secondary Containment Criteriar Must contain the largest single oil compartment orcontainer plus “sufficient freeboard” to containprecipitation Largest single compartment may consist of permanently manifoldedcontainers (i.e. more than a single tank)r Must be passive and permanent – no deployment orother action necessary e.g. curbs, dikes, double-wall shell Valves must remain closed and be manually operable only Precipitation determination? N/A for integral double wall or indoor/weather protected tanks orcontainers Tank/container displacement volume?r Sufficiently impervious to the spilled material
APSA/SPCC Plan Compliance PrimerSlide 118
APSA/SPCC Plan Compliance PrimerSlide 119
APSA/SPCC Plan Compliance PrimerSlide 120
APSA/SPCC Plan Compliance PrimerSlide 121
APSA/SPCC Plan Compliance PrimerSufficient Freeboard Design Standardr EPA did not set a standard requirementfor freeboard capacity e.g., precipitation from a 25-year, 24-hour storm event or 110% of storagetank capacityr The proper method of design is amatter of good engineering practicer Whatever method is used to calculateamount of freeboard “sufficient” forthe facility and container configurationshould be documented in the PlanSlide 122
Example Calculationsfrom SPCC PlansAPSA/SPCC Plan Compliance PrimerSlide 123
APSA/SPCC Plan Compliance PrimerSlide 124SUFFICIENT FREEBOARD ?
APSA/SPCC Plan Compliance PrimerSlide 125
APSA/SPCC Plan Compliance PrimerDouble Walled Tanks?How do you know?Slide 127
APSA/SPCC Plan Compliance PrimerDouble Walled Tanks?Slide 128How do you know?Visual vsmfr specs vspurchase recordsvs optionalequipment
APSA/SPCC Plan Compliance PrimerSufficiently Imperviousr Secondary containment system“must be capable of containingoil and must be constructed sothat any discharge will notescape containment system beforecleanup occurs”(40 CFR 112.7(c))r Diked areas must be“sufficiently impervious tocontain oil” (40 CFR 112.8(c)(2))r Describe in the PlanSlide 129
SufficientlyImpervious?APSA/SPCC Plan Compliance PrimerSlide 130
APSA/SPCC Plan Compliance PrimerSecondary Containment for Mobile/PortableContainersSlide 131r Mobile and portable bulk containers must comply tothe specific sized secondary containmentrequirements of 40 CFR 112.8(c)(11) Must be positioned or located to prevent adischarge to navigable waters Secondary containment must be sized to containcapacity of largest single compartment orcontainer with sufficient freeboard forprecipitation While in stationary or unattended mode ofoperation Except mobile refuelers and non-transportationrelated tank trucks
APSA/SPCC Plan Compliance PrimerSlide 132
Secondary Containment RequirementsAPSA/SPCC Plan Compliance PrimerSlide 134(General Provisions)r ‘General Provisions’ aka GeneralContainment (40 CFR 112.7(c)) Addresses the potential for oil discharges from allparts of a facility where oil is handled, and fromspecific equipment Containment method, design, and capacity aredetermined by good engineering practice to contain themost likely oil discharge until clean-up occurs Intended to address most likely discharge Site, equipment, location and personnel-specific Determined or reviewed/certified by PE– Or facility owner/operator for qualified facilities
APSA/SPCC Plan Compliance PrimerSlide 135General Secondary Containment Requirementr Required secondary containment for all areaswith the potential for a discharge Performance requirement broader than usual useof term ‘secondary containment’: i.e.: Appropriate containment and/or diversionary structures toprevent a discharge to navigable waters that may be harmfulr This is the minimum expectation forcontainmentr This is where plan preparer experience &technical knowledge come in (e.g. PE usinggood engineering practice)
APSA/SPCC Plan Compliance PrimerSlide 136General Secondary Containment Requirementr General facility requirement with no specified sizing orfreeboard requirements Active or passive (e.g. spill or discharge response,weirs, closing valves, drain mat placement, berms,dikes, containment pallets, pre-positioned socks, etc.) Can be facility-wide or equipment/tank specific
APSA/SPCC Plan Compliance PrimerSlide 137General Secondary Containmentr Can be a combination of all types of measures Performance standard: Prevent navigable water discharges Keep the discharge fromcontainment untilescapingclean up occurs
APSA/SPCC Plan Compliance PrimerPassive vs. Active Measuresr 40 CFR 112.7(c) allows for the use of certain types ofactive containment measures to prevent a dischargeand may be used when permanent containment is notfeasible Feasibility determined by the facilityowner/operator or the reviewing/certifying PEr Passive measures are permanent installationsand do not require deployment or action bythe owner or operatorr Active containment measures arethose that require deployment orother specific action by the owneror operatorSlide 138
APSA/SPCC Plan Compliance PrimerActive Measure Examplesr Placing a properly designed storm draincover over a drain to contain a potentialspill in an area where a transfer occurs,prior to the transfer activityr Placing a storm drain cover over adrain in reaction to a discharge,before the oil reaches the drainr Using spill kits in the event of an oildischarger Using spill response capability (spillresponse teams) in the event of an oildischargeSlide 139
APSA/SPCC Plan Compliance PrimerSlide 141Efficacy of Active Measuresr Efficacy depends on: Effectiveness & capacityof the containmentmeasure Timely deployment andproper placement prior toor following a discharge Availability of personneland equipment toimplement the activemeasure timely andeffectively at the facility Personnel and equipmentperformance (drills?)Active containment measures to be used at a facility (and described in the SPCC Plan)should be reasonable, appropriate, tested and believable
APSA/SPCC Plan Compliance PrimerUnloading Procedures Impact on Spill Prediction / FailureAnalysis and ContainmentSlide 142
APSA/SPCC Plan Compliance Primerr Can include bothpassive and activemeasures But like anything else:must be maintained andimplemented!Slide 144
APSA/SPCC Plan Compliance PrimerOil-Filled Operational Equipmentr Subject to the general secondarycontainment requirements of 40CFR 112.7(c)Slide 146
APSA/SPCC Plan Compliance PrimerRequirements for Mobile Refuelers & OtherNon-Transportation Related Tank Trucksr General secondarycontainment requirementsapply Dec. 2006 amendment eliminatedthe specific sized secondarycontainment requirementr Does not apply to vehicles that are usedprimarily to store oil in a stationary locationr As with any portable/mobile container, mustalso position or locate them to prevent aharmful navigable water dischargeSlide 147
APSA/SPCC Plan Compliance PrimerWhat do you observe? Any issues?Slide 148
APSA/SPCC Plan Compliance PrimerPipingSlide 149r All piping, including buried piping, atregulated facilities must comply with the 40CFR 112.7(c) general secondary containmentrequirementsr A determination of adequate secondarycontainment should consider: The reasonably expected sources of discharge Maximum flow rate Duration of a discharge Spill detection capability
APSA/SPCC Plan Compliance PrimerPipingr In many cases, secondarycontainment (especially activemeasures) will be possible In other cases, active measureswould not be appropriate E.g. 8” high pressure jet fuel transferpipeline at facility edge– Facility recently replaced thiswith double-walled pipingr If active methods of containment areselected, facility personnel should be ableto demonstrate that they can effectivelydeploy these measures to contain apotential spill before it reaches navigablewaters or adjoining shorelinesSlide 150
APSA/SPCC Plan Compliance PrimerTransfer AreasSlide 153r Activities that occur within transfer areasinclude: Unloading fuel from a truck to a bulk fuel tank Loading oil into a vehicle from a dispenser Loading fuel from a mobile refueler into anairplane Loading lubricating oil from a truck intoequipment Unloading and moving drums and totes on aforkliftr Transfer areas are subject to the general containmentrequirements of 40 CFR 112.7(c)
APSA/SPCC Plan Compliance PrimerContainment at Transfer Areasr Determination of adequate secondarycontainment should consider: Reasonably expected sources and causes ofa discharge Reasonably expected maximum rate ofdischarge Ability to detect and react to the discharge Reasonably expected duration of thedischarge Time it would take a discharge to impactnavigable waters or adjoining shorelinesSlide 154
APSA/SPCC Plan Compliance PrimerSlide 155
APSA/SPCC Plan Compliance PrimerLoading/Unloading RacksSlide 156r Definition of loading/unloading rack was clarifiedand made more specific in the 12-2008amendments, and the requirements clarified Fixed structure (such as a platform, gangway) Necessary for loading or unloading a tank truckor tank car and located at an SPCC regulatedfacility A loading/unloading rack includes a loading orunloading arm, and may include any combinationof the following: piping assemblages, valves, pumps, shut-off devices, overfillsensors, or personnel safety devices
APSA/SPCC Plan Compliance PrimerSlide 157Facility Drainage: From Diked Areasr Drainage from diked storage areas must be restrained byvalves to prevent discharges into facility drainage or effluenttreatment systems Unless the systems are designed to control such discharger Diked areas may be emptied by pumps or ejectors only bymanual activation Must inspect the condition of the accumulation before starting, toensure no oil will be dischargedr If the facility drainage drains directly into a watercourse (i.e.storm water discharge) and not into on-site wastewatertreatment, the facility must inspect uncontaminated retainedstormwater prior to draining 40 CFR 112.8(c)(3)(i) - (iv) are also required
APSA/SPCC Plan Compliance PrimerSlide 158Facility Drainage: From Diked Areasr Draining diked areas into stormwater (or othersurface watercourse) requires compliance with 40CFR 112.8(c)(3)(ii) - (iv): Not allow drainage of uncontaminated rainwater from thediked area into a storm drain or open watercourse, lake, orpond, bypassing the facility treatment system unless thefacility Normally keeps the bypass or drainage valve sealed closed Inspect the retained rainwater to ensure that its presence will notcause a discharge as described in §112.1(b) Open the bypass valve and reseal it following drainage underresponsible supervision; and Keep adequate records of such events, for example, any recordsrequired under relevant stormwater discharge permits or NPDESdischarge permits
APSA/SPCC Plan Compliance PrimerSlide 159
APSA/SPCC Plan Compliance PrimerSlide 160
APSA/SPCC Plan Compliance PrimerSlide 161
APSA/SPCC Plan Compliance PrimerSlide 162A drainage log is provided in TemplateAttachment 3.3 (Table G-18)
APSA/SPCC Plan Compliance PrimerUn-Diked Facility DrainageSlide 163r When secondary containment requirementsare addressed through facility drainagecontrols (vs. berms or dikes), otherrequirements apply 40 CFR 112.8(b)(3) and (4) The drainage system must be designed to flowinto ponds, lagoons, or catchment basins designedto retain oil or return it to the facility
APSA/SPCC Plan Compliance PrimerImpracticability Provisionr If a facility owner oroperator finds thatcontainment methodsare “impracticable,” acombination of othermeasures in place ofsecondary containmentmay conditionally besubstituted Bulk tanks/containers Transfer areas, piping Oil-filled equipment Loading/unloading racksSlide 164
APSA/SPCC Plan Compliance PrimerMeaning of “Impracticable”Slide 165r An “impracticability determination” is intended to beused when a facility owner/operator is incapable ofinstalling secondary containment by any reasonablemethodr Considerations include: Space and geographical limitations Local zoning ordinances Fire codes Safety Other good engineering practice reasons thatwould allow for secondary containment
APSA/SPCC Plan Compliance PrimerImpracticability RequirementsSlide 166The impracticability provision requires:r Explanation in SPCC Plan of why secondarycontainment methods are impracticabler Periodic integrity testing of bulk storagecontainers and periodic integrity testing andleak testing of the valves and piping associatedwith the containersr Unless facility has submitted a Facility ResponsePlan (FRP) under §112.20: An oil spill contingency plan (per 40 CFR 109.5); and A written commitment of manpower, equipment, and materialsrequired to control and remove any quantity of oil dischargedthat may be harmful
APSA/SPCC Plan Compliance PrimerImpracticability and Qualified Facilitiesr Self-certified SPCC Plans may notinclude any determinations thatsecondary containment is impracticable At all for Tier I qualified facilities At Tier II qualified facilities – only if thedetermination and alternative provision isreviewed and certified by a PE.Slide 167
Secondary Containment for Mobile/Portable Containers rMobile and portable bulk containers must comply to the specific sized secondary containment requirements of 40 CFR 112.8(c)(11) Must be positioned or located to prevent a discharge to navigable waters Secondary conSecondary containment must be sized to contain tainment must be sized to contain
SPCC GUIDANCE FOR REGIONAL INSPECTORS 4-6 December 16, 2013 Chapter 4: Secondary Containment and Impracticability Determination Figure 4-3: Secondary containment provisions in 40 CFR part 112 related to onshore oil drilling and workover facilities (§§112.7 and 112.10).
DIRECT-PLUMBED Containment Tanks Models 2478SQ-NA-DP 1100Lb/150Gal Containment Tank 3072-NA-DP 1500Lb/200Gal Containment Tank 4280-NA-DP 2650Lb/353Gal Containment Tank. About this manual Read this manual for the following information about inside Direct-Plumbed containment tanks:
Single Storage Tank Containment Wall Height Calculation 61 . 3. Example Multiple Storage Tank Containment Wall Height. Calculations 63 . 4. Multiple Storage Tank Containment Wall Height Calculations 64 . D. Bulk Facility Containment Construction Criteria 66 . 1. Outline of General Specifications for cast concrete secondary. containment systems .
Cost Containment in Healthcare September 2015 2 Cost Containment in Healthcare September, 2015 3 DEFINITION & CLASSIFICATION What is a Cost Containment? v Almost all European countries have introduced and implemented cost containment measures that keep expenses in check.
unpredictable “acts of God” can no longer reasonably be said to be so. The established doctrine of contractual impracticability rests on the notion that a party may be exculpated from liability for failed or delayed contractual performances if supervening events made the performance impracticable unless that party assumed the risk of the event.
loss of secondary containment integrity.) B. The standby gas treatment system is operable. C. All automatic secondary containment isolation valves are operable or are secured in the closed position. 1.15 (DELETED) 1.16 RATED FLUX Rated flux is the neutron flux that corresponds to a steady state power level of 1930 NW(t).
SECONDARY CONTAINMENT TESTING REPORT FORM (Page 1 of 6) Type of Action Installation Test Repair Test Six Month Test 36 Month Test I. FACILITY INFORMATION CERS ID Date of Secondary Containment Test Business Name (Same as Facility Name or DBA-Doing Business As) Business Site Address City ZIP Code .
The API commands in this guide are applicable to the Polycom RealPresence Group 300, Polycom RealPresence Group 500, and Polycom RealPresence Group 700 systems.
