SPCC Plans for Marine Operations

Recommended practices for pollution prevention and avoiding discharges of oil are also included in this section. These practices may also assist facilities in achieving compliance with the SPCC requirements and reduce the possibility of product loss and a discharge.

» Introduction
» SPCC General Requirements Marine Facilities (40 CFR 112.7 )
» Secondary Containment (40 CFR 112.7 (e)(2))
» Facility Drainage and Diversionary Containment Structures (40 CFR 112.7 (e)(1))
» Tanks, Bulk and Portable, and Drums (40 CFR 112.7 (e)(2))
» Marine Transfer Operations: Hosing, Pipelines, and Joints (40 CFR 112.7 (e)(3))
» Tank Car and Truck Loading and Unloading Procedures (40 CFR 112.7 (c)(4))

SPCC Plans for Marine Facilities Introduction

Overview of Laws and Regulations

This section is intended to assist marine facilities that transfer oil products to or from marine vessels. This section discusses the regulations that specifically apply to marine facilities and offers general guidance and recommended practices for pollution prevention when handling oil products in bulk. To meet the requirements of the Oil Pollution Prevention Regulation in Title 40 Code of Federal Regulations (CFR) Part 112, a marine facility must meet the requirements of the Spill Control and Countermeasure (SPCC) Plan requirements and the Facility Response Plan (FRP) if applicable.

Marine facilities involved in large volume transfer operations, are generally subject to multiagency jurisdictions for oil spill prevention and response. Marine facilities are usually regulated by more than one agency under the Oil Pollution Act of 1990 (OPA). The EPA is responsible for the non-transportation-related facilities located landward of the coastline*. The Department of Interior (DOI) Minerals Management Service (MMS) is responsible for offshore non-transportation-related facilities located seaward of the coastline, including certain pipelines. The Department of Transportation (DOT) United States Coast Guard (USCG) or other designated agency is responsible for deepwater ports and fixed offshore facilities. The EPA is responsible for facilities in inland lakes and rivers, including certain piping, and coastal areas landward of the low water mark. The USCG handles transportation-related offshore facilities located landward of the coastline, while the DOT, Office of Pipeline Safety (OPS) handles all onshore pipelines. The OPS is a component of the Research and Special Programs Administration (RSPA).

Marine facilities may be subject to the following: Resource Conservation and Recovery Act (RCRA), Title 1 – Underground Storage Tank (UST) regulations (40 CFR Part 280 and 281); DOT railcar and tanker truck loading and unloading requirements in 49 CFR Parts 171, 173, 174, 177, and 179; DOT OPS regulations for the transportation of hazardous liquids by pipeline in 49 CFR Part 195; the DOT and USCG requirements for facilities transferring oil or hazardous material in bulk in 33 CFR Part 154; and the Occupational Safety and Health Administration (OSHA) requirements for flammable and combustible liquids storage in 29 CFR 1910.106. Links to the USCG and the DOT.

Most marine facilities that transfer to and from vessels will include both a transportation-related transfer area regulated by the USCG and a non-transportation related oil storage area regulated by the EPA. The SPCC should address both of these regulations.

Fines and Penalties

Section 311 of the Clean Water Act makes it illegal to discharge oil or hazardous substances into the waters of the United States within 12 miles of the coast or where it may affect natural resources such as marine sanctuaries.

The law requires the person in charge of a vessel (or a facility) who witnesses or sees a spill that discolors the surface of the water – creates a “sheen” – to report the spill to the U.S. Coast Guard or the National Response Center at 1-800-424-8802 immediately. Failure to report may result in the assessment of a civil penalty and/or criminal sanctions.

The Federal Water Pollution Control Act prohibits the discharge of oil or oily waste into or upon the navigable waters of the United States, or the waters of the contiguous zone, or which may affect natural resources belonging to, appertaining to, or under the exclusive management authority of the United States, if such discharge causes a film or discoloration of the surface of the water or causes a sludge or emulsion beneath the surface of the water. Violators are subject to substantial civil penalties and/or criminal sanctions, including fines and imprisonment.

Note: Using a dispersant, such as dishwashing soap, to make a sheen “disappear” is illegal without permission from the Captain of the Port and can subject the user to a civil penalty of as much as $27,500. This technique does not clean up the oil – it only sends the oil below the water’s surface where it can still harm aquatic organisms.

FRP Requirements

You will be required to have a Facility Response Plan (FRP) in addition to the SPCC if your facility transfers oil over water to or from vessels and has a total oil storage capacity, including both aboveground (AST) and underground (UST) greater than or equal to 42,000 gallons; or

The facility’s total oil storage capacity, including both ASTs and USTs, is greater than or equal to one million gallons, and one of the following is true:

  • The facility lacks secondary containment that is able to contain the capacity of the largest AST within each storage area plus freeboard to allow for precipitation;
  • The facility is located at a distance such that a discharge could cause injury to an environmentally sensitive area;
  • The facility is located at a distance such that a discharge would shut down a public drinking water intake; or
  • The facility has had a reportable spill greater than or equal to 10,000 gallons within the last five years.

All facilities must document the determination of substantial harm by completing the “Certification of the Applicability of the Substantial Harm Criteria Checklist,” Attachment C-II in Appendix C of 40 CFR 112. This certification should be signed by management or the owner and kept with the facility’s SPCC plan.

SPCC Plan General Requirements and Oil Spill Prevention for Marine Facilities

SPCC Plan Requirements

SPCC Plans are required for facilities that store, distribute or transfer oil in quantities as described below and from which an oil spill could reach navigable waters. The term “Oil”, includes; petroleum products such as gasoline, diesel, kerosene, heating oil, motor oil both used and new, and hydraulic oil.

An SPCC Plan is required for a facility where:

  1. The total underground buried storage capacity of the facility is 42,000 gallons or more of oil, or
  2. the total above ground storage capacity is 1,320 gallons or more of oil, or
  3. if a single above ground container has a capacity of 660 gallons or more of oil, and
  4. due to the facilities location, the facility could reasonably be expected to discharge oil into a navigable water way.

Facility Response Plan (FRP)

Most bulk oil storage facilities are subject to the SPCC regulation. Many marine facilities are also subject to the Facility Response Plan (FRP) regulation under 40 CFR 112.20 and 112.21 because of the over water transfer aspect of their operation.. Owners or operators of SPCC-subject facilities should determine whether the facility is required to have an FRP by determining if the facility poses a threat of substantial harm to the environment.

As outlined in 40 CFR 112.20(f)(1), a facility has the potential to cause substantial harm if:

The facility transfers oil over water to or from vessels and has a total oil storage capacity, including both above ground and below ground tanks, greater than or equal to 42,000 gallons; or

The facility’s total oil storage capacity, including both ASTs and USTs, is greater than or equal to one million gallons, and one of the following is true:

  • The facility lacks secondary containment that is able to contain the capacity of the largest AST within each storage area plus freeboard to allow for precipitation;
  • The facility is located at a distance such that a discharge could cause injury to an environmentally sensitive area;
  • The facility is located at a distance such that a discharge would shut down a public drinking water intake; or
  • The facility has had a reportable spill greater than or equal to 10,000 gallons within the last five years.

All facilities must document the determination of substantial harm by completing the “Certification of the Applicability of the Substantial Harm Criteria Checklist.” The check list is provided as Attachment C-II in Appendix C of 40 CFR 112. This certification should be kept with the facility’s SPCC plan. SPCC Check List

Secondary Containment Structures for SPCC Regulated Marine Facilities

SPCC requires that all storage containers have secondary containment for the entire contents of the largest single container within the containment area, and if outside they must have sufficient freeboard to allow for precipitation. Alternative systems are allowed. An Alternate system might consist of a drainage trench that completely encloses the storage tanks and arranged so that a spill would enter the drainage trench and terminate in a catchment basin. Containment structures must be sufficiently impervious to the types of oil products stored at a facility. Diked areas should be free of pooled oil; spills should be removed promptly.

The volume of freeboard should be based on regional rainfall patterns. Facilities in states with large amounts of rainfall (e.g., Washington, Alaska, and Hawaii, and the Commonwealth of Puerto Rico) will require secondary containment to accommodate greater amounts of water.

Precipitation data is available from the National Oceanic and Atmospheric Administration’s (NOAA) National Climatic Data Center (NCDC).

The following table describes the most common secondary containment systems.

Types of Secondary Containment

* Concrete Structures
* Containment Curbing
* Concrete Masonry Unit (CMU) walls
* Earthen Berms
* Trench and Sump Systems

Concrete Structures

Concrete containment structures are typically steel reinforced and cast in place. Concrete structures are usually the cheapest route when constructing a permanent facility, especially where vehicle traffic is an issue. However, keep in mind that concrete cracks. Problems with cracks can be avoided by using ACI (American Concrete Institute) Environmental Standards, ACI 350.

Many containment structures that we have inspected are essentially useless, and many do not meet regulations leaving the owner in a risky position. Even some containment structures made out of concrete that look good on the out side are worthless for containing the liquids they were intended to hold because of cracks. In containmentconcrete pour.jpg (12639 bytes) structures, the amount of cracking that is normally permitted in a standard structure or ordinary pavement may constitute a significant failure if it occurs in a containment structure. As a result, alternative concrete design and construction standards which have been developed specifically for environmental concrete structures should be applied, ACI 350. These alternative standards are not included in typical engineering design curricula and, therefore, are widely unknown by most site design engineers. Building it right the first time will save you money over the long term.

A common misconception is that large, monolithic concrete pours which minimize the number of construction joints will result in improved containment integrity. In fact, studies of these large, monolithic pours have demonstrated a reduced containment integrity due to shrinkage cracking during the concrete cure and differential settlement after the concrete has cured.

  • Conventional concrete is not totally impervious to liquids including petroleum; any spill left inside a concrete containment area may eventually penetrate the concrete and could contaminate groundwater sources. Concrete sealants and coatings may used.
  • The expansion and contraction of piping which runs through concrete containment walls can create areas of weakness and potential leaks.
  • Grout or sealants in expansion joints requires maintenance to prevent weak points, which may allow petroleum penetration. Grout and sealants should be selected to be resistant to the stored material.

Containment Curbs

Containment curbs work well in outside areas and in areas where trucks or other vehicle traffic is present.
Containment curbs are similar to speed bumps and are constructed of concrete. They can also be easily installed on existing paving.

  • Since the area is usually larger, they fill up with rainwater more rapidly than higher containment or walled areas.
  • Collected storm water must be managed.

Concrete Masonry Unit (CMU) walls

CMU or block walls are also commonly used for containment structures. CMU walls should be constructed on level concrete paving to avoid cracks in mortar between the blocks that destroys the integrity of the wall.

In addition CMUs are very porous and they do not form liquid-tight seals between mortared joints. A sealant or coating is recommended on all CMU containment walls.

The open top of the blocks should also be sealed. Water and ice penetrate the blocks and can eventually break them apart.

Earthen Berms

Earthen berms containing clay or bentonite mixtures are commonly used at very large oil storage facilities and in oil field operations. Earthen berms are subject to erosion and require frequent rebuilding. Sandy soil does not effectively contain oil spills; groundwater contamination may result. Impervious liners of clay or synthetic membranes may be required to contain oil spills.

Vegetation inside bermed areas is a fire hazard and restricts the operator’s ability to detect spills or defective equipment and should not be allowed.

Trench & Sump Systems

Trench and sump systems are below-grade containment structures typically covered with metal grates and installed in concrete paved areas and constructed of concrete with a liner or sealant..

Earthen trenches are not recommended and have the potential for groundwater contamination unless constructed with appropriate materials and lined.

Trenches must be properly constructed are supported or they will deteriorate quickly, especially in traffic areas.

Containment and Diversionary Structures for SPCC Regulated Marine Facilities

Requirements of 40 CFR 112.7 (c)

This section addresses the requirements of 40 CFR 112.7 (c) that requires containment related to storm water drainage. For secondary containment of spills follow the link to Secondary Containment.

The SPCC regulations require containment of storm water drainage from the operating areas of a facility to prevent oil spills and contaminated runoff from reaching storm drains, streams, ditches, rivers, bays, and other navigable waters.

Secondary containment and diversionary structures should be in place to prevent storm water contamination and to contain storm water that has been oil-contaminated from leaks around fuel dispensers, pipelines, valves, joints, transfer connections, and tanks. Facilities should use dikes, berms, curbing, gutters, trenches, absorbent material, retention ponds, weirs, booms, and other barriers or equivalent preventive systems.

Performance Based SPCC

Performance Based SPCC requirements are performance-based, which permits facility owners and operators to substitute alternative forms of spill containment if the substitute provides substantially equivalent protection against discharges to navigable waters to that provided by the systems listed in 40 CFR 112.7(c).

Substantially equivalent containment systems may be possible for AST systems (e.g., small double-walled ASTs equipped with spill prevention devices) that generally have capacities of less than 12,000 gallons. Alternative containment systems may not be appropriate for tank systems larger than 12,000 gallons or for systems that consist of several tanks connected by manifolds or other piping arrangements that would permit a volume of oil greater than the capacity of one tank to be spilled as a result of a single system failure.

The secondary containment structure must be impervious and must prevent water and fuel from percolating through the soil, contaminating the soil and groundwater and possibly surfacing aboveground into navigable waters or adjoining shorelines.

Diked Areas

Diked Areas Facilities with outside operations most often use poured concrete walls or earthen berms to contain drainage and provide secondary containment for storage tanks and curbing and catchment basins for truck loading/unloading areas. These contained areas are referred to in the regulations as diked areas. Concrete and earthen dike containment structures around storage tanks may accumulate significant amounts of water. Drain lines, which must be watertight, are usually installed through the dike walls and are used to drain accumulated storm water from the diked area. These lines should be fitted with valves or other positive means of closure that are normally sealed closed and locked to prevent any oil discharges from escaping the diked area. The valves must be open-close manual valves; flapper valves are not acceptable.

The accumulated rainwater must be examined and determined to be free of oil contamination before diked areas are drained. If any oil sheen or accumulation of oil is observed, an alternate method of draining the diked area must be employed. The contaminated water may be diverted to an onsite treatment plant or oil-water separator; however, the adequacy of these systems is determined on a case-by-case basis for each one’s adherence to good engineering practices and ability to retain a spill in the event of a system malfunction. These valves must be opened to drain storm water and resealed following drainage by trained and authorized facility personnel only. Adequate records must be kept of each drainage event, (i.e., date, time, personnel names) and made part of the SPCC plan.

Drainage Control Systems

Bulk storage facilities may employ many different types and designs of drainage control systems and oil-water separators. Facilities must implement a system that is consistent with good engineering practices, based on the size and complexity of their operations.

One design may consist of a sump located inside a containment area, which may be a blind sump (no drains) or a sump restrained by a normally closed valve. Facilities may remove the floating oil product by manual skimming or using sorbent materials. These materials must be disposed of properly or recovered for reuse. Any oil removed from skimming or the sorbent material must be disposed of as a waste oil. The remaining water in the sump must be inspected before discharging it outside the containment areas. Once sufficiently inspected and found to be free of oil, the water may be discharged by authorized personnel as long as the discharge is supervised and documented.

Other facilities may use a completely or partially buried oil-water separator system equipped with an inlet valve and a weir and baffle system, which directs the oil to one compartment and the water to another. The oil-water separator must never automatically discharge treated water to a sanitary sewer or anywhere outside a contained area.

Another alternative is to pump out diked areas with a manual pump or vacuum truck. Any oil-contaminated water must be transported to an appropriate waste-handling facility for disposal or treated on site.

Undiked Areas

Undiked Areas Operating areas of a bulk storage facility that do not have secondary containment systems specifically designed for those areas are considered undiked areas. Drainage must be controlled for these areas which may include: tank car and truck loading/unloading areas, piping and manifold areas, garage bays, and fuel islands. All undiked areas can be designed to control drainage through a combination of curbing, trenches, catchment basins, and retention ponds, as necessary to retain a spill. These structures must be inspected and examined for integrity and their effectiveness. For example, if a paved area is improperly graded or if a curb is deteriorating, contaminated water may escape from the facility. For this reason, a professional Engineer must certify the SPCC plan to ensure that the drainage system is adequately designed and properly maintained in accordance with good engineering practices.

Truck or engine washdown areas are a separate issue and should not be a part of the SPCC. Waste water from these activities is an industrial waste stream and must be (1.) pretreated and disposed of in a sanitary sewer, or (2) treated and recycled, or (3) disposed of by evaporation or at a permitted waste water disposal facility.

Tanks, Bulk and Portable, and Drums

Types of Tanks

Above ground storage tanks are available in a wide variety of designs. The most common type of tank is the atmospheric tank used for storing petroleum products. Atmospheric tanks are designed to contain pressures of 0 to 0.5 psig. There are five common types of atmospheric storage tanks used for petroleum products:

  • fixed roof tank
  • floating roof tank,
  • fixed vertical roof tank,
  • vapor dome roof tank,
  • and lifter roof tank.

Floating roof tanks minimize vapor loss because the roof rests on the liquid, which greatly reduces the vapor space between the top of the tank and the top of the liquid. Lifter roof or vapor dome tanks reduce the amount of vapor loss by moving up or down with vapor volume changes. Ordinary fixed cone roof tanks and vertical roof tanks tend to have higher vapor loss than the other three types. Aboveground tanks often are painted with aluminum or white paint to reflect heat, which decreases the temperature rise of the liquid contents and slows evaporation. The thickness of the metal used for tank construction is based on the strength required to hold the mass of the liquid. There is also an added allowance for corrosion encountered during the service life of the tank. Storage tanks should be constructed of materials compatible with the contents contained in the tank. Steel tanks resist heat from exposure to fires and maintain structural integrity for a longer period of time than any other material currently used for tank construction.

Low pressure (0-15 psig) storage tanks are commonly used for storing petroleum products with low vapor pressures. Low pressure tanks are designed to contain liquids with vapor pressures slightly higher than atmospheric pressure, but not exceeding 15 psig. Spheroid and horizontal tanks are the two common types used for petroleum products; however, spheroid tanks are normally used for storing very “light” hydrocarbons, such as pentane, butane, and propane, which do not present a spill hazard if released. Horizontal tanks are used for storing products such as light crude oil, gasoline additives, gasoline blending stocks, and naphtha solvents which constitute a spill hazard if released. Most horizontal tanks are constructed of welded steel, but some older riveted steel tanks may still be in service. Horizontal storage tanks should be frequently examined for cracks, corrosion, buckling, or other damage.

Tank Inspections and Testing

Tanks, pipes, joints, gaskets and seams should be inspected routinely for for visible oil leaks. The inspection should be recorded on an inspection form and kept for three years. Typically tanks are inspected once a week. All visible leaks should be reported to the person in charge of spill prevention as noted in the SPCC Plan.

Tank corrosion and bottom deterioration is also a concern. Tanks bottoms can corrode and leak with out any signs of a visible leak. Corrosion protection can be provided by dielectric coatings and cathodic protection. In some cases double bottom tanks have been used. The type f material and foundation must be considered and should be evaluated by an engineer.

Corrosion of a tank’s surface may also result in tank failure. Corrosion that is concentrated in small areas of a tank’s surface or “pitting” creates a high potential for tank failure. If tanks are rusty, holes may form causing the tank to leak. Tank supports and foundations should also be inspected for cracks, crumbling, deterioration, and seepage.

ASTs should be subjected to periodic integrity testing. Some of the accepted methods for testing are the following:

  • X-ray or radiographic analysis measures wall thickness and detects cracks and crevices in metal.
  • Ultrasonic analysis measures shell metal thickness.
  • Hydrostatic testing shows leaks caused by pressure.
  • Visual inspection detects some cracks, leaks, or holes.
  • Magnetic flux eddy current test used in conjunction with ultrasonic analysis detects pitting.

Level Gauges and Alarms

Level gauges and alarms are most commonly used to ensure that tanks are not overfilled. There are two basic objectives for using alarms and gauges:

  • Avoid overfilling and spilling liquid.
  • Prevent damage to the tank from overfilling.

Larger tanks may be designed with gauges, high-level alarms, and high-high level alarms to satisfy this requirement. Smaller tanks may be gauged by “stick”. Generally it is not adequate to only “stick” a tank during filling operations. A second overfill protection measure should be used as a backup. Some trucks have automatic shutoff systems, that will shut off the pump once the meter reaches a pre-selected volume of product such as 90% of the tanks capacity.
In the simplest case, the gauge is a small-diameter glass or plastic tube vertically attached to two openings in the tank shell. Liquid level in the tank is shown by the level in the tube.

Another common sight level gauge is a float gauge. A float rides on top of the liquid in the tank and moves a marker attached to a cable or chain on the outside of the tank. The marker moves up or down with the product level in the tank.

High liquid level alarms are usually tied into a float gauge or level gauging system. The alarms produce an audible or visual signal when the liquid level in the tank reaches a predetermined height.

This consists of a fill-level alarm connected to a pump control that automatically shuts down the pump when a preset liquid level is reached. This system eliminates the possibility of human failure and is effective at stopping overfilling of tanks.

This system consists of communication between the tank gauger and pumping station and relies on human perception of liquid levels in the tanks and pumping rates to avoid overfilling tanks. Human error could cause a spill if the tank gauger or pumping station misreads an audible or code signal to start or stop pumping.

Underground and Partially Buried Tanks

Underground tanks have both advantages and disadvantages for storing petroleum products. The advantages are reduced vapor loss, increased safety, efficient land use and greater security. The disadvantages are undetected leaks and higher corrosion factors for metal tanks. Fiberglass-reinforced plastic tanks are commonly used for storing petroleum products underground. They have a distinct advantage over metal tanks in being corrosion-free.

Steel tanks should be protected from corrosion by coatings and cathodic protection.. Underground corrosion of metal surfaces is a direct result of an electric current generated by the reaction between the metal surfaces and chemical ions present in the soil and water. The flow of current from one portion of the tank to another causes metal ions to leave the surface of the metal, creating pits. The rate of destruction of the metal is directly related to soil moisture and chemical makeup of the soil.

Underground tanks should also be leak test and adequate records kept of such tests. These records must be made part of the SPCC plan and kept for at least three years.

The Federal UST regulations found in 40 CFR 280 have technical requirements consistent with the underlying regulatory purposes of the SPCC program and are equally protective for purposes of preventing discharges of oil into waters of the United States. These regulations contain provisions for corrosion protection, leak detection, tank overfill and spill prevention equipment, and tank tightness testing. Facilities should refer to the full text of 40 CFR 280 or seek the advice of a consultant when making determinations of compliance.

Portable Tanks, Temporary Tanks and Tank Trucks

Mobile or portable oil storage tanks including tank trucks and temporary tanks should be positioned or located so as to prevent spilled oil from reaching navigable waters. A secondary means of containment, such as dikes, basins, or spill pallets, must be provided for temporary tanks and parked tank trucks whether full or not. The containment area must hold the contents of the largest container stored in the area. Temporary tanks are generally contained in an earthen berm with a plastic liner. Overnight tank truk parking may vary from a bermed area to a fully contained garage.

These temporary storage areas and truck parking area must be located where they will not be subject to periodic flooding or washout.

Containment for drums and other small containers does not have to be expensive. If there are a small number of drums, a facility may purchase plastic spill pallets or portable containment devices designed for drum containment.

Marine Transfer Operations, Hosing, Pipelines, Connections and Joints

Transfer operations are covered in 40 CFR 112.7 (e)(3). This regulation covers piping, valves, gauges, regulators, compressors, pumps and other mechanical devices used to transfer oil from one area to another within a facility. Pipelines used to transport oil for interstate or intrastate commerce are considered transportation-related systems and are regulated under the DOT OPS program. Pipelines which are used for the transport of oil exclusively within the confines of a non-transportation-related facility are regulated under the SPCC program. Some of the more common mechanical transfer systems are the piping systems required to transfer product between tanks and railcar or truck loading and unloading areas.

Underground piping must have a protective wrapping and coating, and cathodically protected if used in corrosive soil conditions. If any section of buried piping is exposed for any reason, it must be examined for deterioration and corrosion and repaired, if necessary. Obviously, buried piping cannot be visually examined and must be subjected to periodic pressure testing, regardless of materials of construction. Plastic or fiberglass-reinforced pipes do not require protective coatings or cathodic protection.

Inspections

Tanks, pipes, joints, gaskets and seams should be inspected routinely for for visible oil leaks. The inspection should be recorded on an inspection form and kept for three years. Typically tanks and transfer operations are inspected once a week. All visible leaks should be reported to the person in charge of spill prevention as noted in the SPCC Plan. Inspections reports should be kept for three years.

Tanks Car and Tank Truck Loading and Unloading at Marine Facilities

Loading and unloading operations are covered in 40 CFR 112.7 (e)(4). This includes fueling activities by customers at gas stations and cardkey facilities, and the receipt of product from tank cars, tank trucks or smaller carriers. Fueling terminals, islands, and other loading areas must meet the same requirements as the unloading areas of a facility.

Department of Transportation (DOT)

Department of Transportation (DOT) regulates loading and unloading procedures regardless of the types of trucks servicing a facility. All drivers must follow loading/ unloading procedures found in 49 CFR 171, 173, 174, 177, and 179. Training programs be conducted and thoroughly address the requirements and procedures. These requirements should be incorporated into a Standard Operating Procedures (SOP) manual for product transfer. Facilities should also ensure that other commercial drivers or contractors using the facilities are competent in these procedures and consider requiring training certificates.

Tank car (railcar) and tank truck loading/ unloading areas have a high probability for spills. Secondary containment systems should be designed by an engineer and specifically for a facility’s topography and the size of the tank car/truck loading or unloading at the site. Loading/unloading areas typically are designed to permit vehicle access and incorporate a secondary containment system. The most common loading/ unloading area containment system is a covered, curbed, and graded area that drains to a sump. Drainage should flow into retention ponds, catchment basins, or treatment systems designed to retain oil or return it to the facility. A method to clean or retain oily stormwater or return it to the facility from loading/unloading areas must also be considered. A system that incorporates good engineering practices minimizes the volume of water, ice and snow that enters the containment area.

Tank trucks when parked overnight on the companies property should be positioned in a containment area. This should be followed even if the tanks are empty at the end of the day.

Containment Systems Requirements

The containment system must be designed to hold the maximum capacity of the largest compartment of a tank car or truck loaded or unloaded at the facility. As an example, if a 9,000-gallon tanker truck has three 3,000-gallon compartments, the loading area containment should hold at least 3,000 gallons. If there are separate areas for different unloading or loading operations, each area should be designed specifically to hold the capacity of the largest carrier anticipated to conduct operations in that area. For facilities that load or unload from “unit trains,” the containment system must be capable of containing the aggregate volume of product for all open railcars/ compartments linked to the manifold in a series for product transfer at the same time. An engineer must look at the entire facility as a unit to determine the adequacy of the spill containment systems in place.

A warning light or physical barrier system (such as a brake-interlock system for bottom-loading trucks) or warning signs should be provided in loading and unloading areas to prevent a vehicle from leaving before completely disconnecting from the fuel transfer lines.

Prior to filling and departure of a tank car or truck, the lowermost drain and all outlets of such vehicles should be closely examined for leakage. If necessary, valves should be tightened, adjusted, or replaced to prevent leaking in transit.