SPCC Compliance Update – Integrity Testing of Aboveground Storage Tanks Reply

In accordance with the US Environmental Protection Agency (US EPA) Oil Spill Prevention regulations found at 40 CFR 112.8(c) owners and operators subject to the Spill Prevention, Control, and Countermeasure (SPCC) rule are required to test or inspect each aboveground container for integrity on a regular schedule. Examples of these integrity tests include, but are not limited to: visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other systems of non-destructive testing.

The type of inspection to be performed is generally determined by the registered Professional Engineer certifying the SPCC Plan. Many SPCC plans reference the Steel Tank Institute Standard for Inspection of Aboveground Storage Tanks (SP001) as the accepted industry standard that the tanks will be inspected against. SP001 stipulates the recommended inspection frequency for various tank configurations.

While SP001 allows qualified facility personnel to perform the inspections and this is appropriate for monthly visual checks of the tank integrity, CAPACCIO recommends that tanks be inspected by a certified STI inspector at least once per year. A certified STI inspector will often uncover issues of non-compliance that are missed by facility personnel.

If you need assistance with AST integrity testing or SPCC compliance, or have general questions, please contact Jeff Briggs, certified STI inspector, at jbriggs@capaccio.com or 508-970-0033 ext.  120.

Handling Extremely Hazardous Chemicals – A Discussion of the General Duty Clause Reply

In the Clean Air Act Amendments of 1990, Congress enacted Section 112(r)(1), also known as the General Duty Clause (GDC), which makes the owners and operators of facilities that use listed or other extremely hazardous substances responsible for ensuring that their chemicals are managed safely. The General Duty Clause applies to any facility producing, processing, handling, or storing extremely hazardous substances (i.e., any chemicals listed in 40 CFR Part 68, or any other chemicals which may be considered extremely hazardous).

Although the GDC appears in the Chemical Accident Prevention Program (aka Risk Management Plan (RMP)) regulations, it does not compel subject facilities to prepare and implement an RMP. Instead, facilities subject to the GDC (i.e.  any facility with extremely hazardous substances) are required to:

  • Identify and understand the hazards associated with the extremely hazardous substances used (hazard assessment)
  • Design and maintain a safe facility (prevention program)
  • Minimize the consequences of accidental releases that do occur (emergency response program)

Without specific regulatory requirements to follow, many facilities find it difficult to know if they have satisfied their obligations under the GDC. To demonstrate due diligence we recommend  the following:

  • Conduct a hazard analysis / review using experience, analytical methods such as HAZOP, or creative methods such as what-if brainstorming
  • Identify the consequences of the release identified in the hazard analysis / review
  • Adopt best industry practices, codes or consensus standards
  • Understand the unique site situations that may require specific accident prevention techniques
  • Apply lessons learned from accidents and incidents in similar operations
  • Develop an emergency response plan
  • Develop standard operating procedures, training programs, management of change procedures, an incident investigation program, self-audits involving a third party, and a preventative maintenance program
  • Identify at-risk receptors in the event of a maximum possible release and alternative release scenarios identified in the hazard analysis/review
  • Coordinate interaction needed between facility management, employees, and local response agencies

If you have questions on the GDC or the RMP program, consider attending our free webinar on Wednesday, March 23, 2016. Please register  on our website at http://www.capaccio.com.

For more information on this topic, you may also contact Christine Silverman at 508.970.0033 ext. 127  or csilverman@capaccio.com.

Does Impaired Waters Monitoring Apply To You? Reply

Discharging to impaired waters can require a higher level of responsibility from the discharging site, and these responsibilities must be fulfilled to remain in compliance. Follow the flowchart below to see if impaired waters monitoring applies to you.

Before using this flowchart, confirm that your facility satisfies the following criteria:

  1. Prepared a Stormwater Pollution Prevention Plan (SWPPP) per the 2015 MSGP.
  2. Submitted a Notice of Intent (NOI) and received word of acceptance from the EPA.

 

stormwater flowchart

1Determine if your facility discharges to impaired waters using EPA’s ‘How’s My Waterway’ Tool http://watersgeo.epa.gov/mywaterway/

2 Existence of EPA Approved or Established TMDLs can be determined using the ‘How’s My Waterway’ tool.

3 In some cases, monitoring is required when TMDLs exist; however, EPA will notify dischargers of any monitoring requirements.

4 Determine if an EPA Approved analytical method exists by consulting EPA guidance at http://www3.epa.gov/region1/npdes/stormwater/assets/pdfs/MSGP2008Part624ParametersMA.pdf

CAPACCIO has also posted a You Tube video, which walks you through this process. The recording is posted at:   https://youtu.be/uoD4tnJFMNs

For more information or assistance with your impaired waters monitoring, please contact Cristina Mendoza at 508) 970-0033 x128 or cmendoza@capaccio.com.

 

REMINDER–Deadline for EPCRA 312 Tier II Report is March 1 Reply

Facilities that store chemicals above the threshold planning quantities are required by the Emergency Planning and Community Right-To-Know Act (EPCRA) to report those chemicals on a Tier II report to the State Emergency Response Commission (SERC). The report is due annually on March 1 and the deadline is fast approaching. CAPACCIO can assist your company in completing the entire report or we can simply conduct a peer review of work completed by your staff.

Guidance regarding the data required by the Commonwealth of Massachusetts for Tier II reporting is located at this link:

http://www.mass.gov/eopss/agencies/mema/emergency-info/haz-mat/serc/

The EPA software is available at this link:

http://www2.epa.gov/epcra/tier2-submit-software

Visit http://www.capaccio.com and see our blog posted on December 21 for more
in-depth information on Tier II reporting.

For assistance or peer review of your Tier II report, please contact Bill Potochniak, PE, Practice Area Leader for Healthcare and Education, at 508-970-0033 ext. 134 or wpotochniak@capaccio.com.