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Storage Tank Systems for Petroleum Products and Allied Petroleum Products Regulations
Waste ProgramsEnvironment Canada
Ontario Tribal Council, Large & Unaffiliated First Nations Meeting October 24, 2013Sault Ste Marie, ON
Page 2
Purpose of Regulations
• To reduce leaks and spills from fuel storage tanks– Leaks and spills from fuel storage is single greatest cause of contamination on
bands lands– Most common cause of problems is poor installation– Second most common cause is poor practices when fuel is delivered
Page 3
What is wrong with this installation?
• Proper tank design and installation prevents problems
Page 4
What is wrong with these installations?
• Poor tank installation may put your community at risk
Page 5
Application of the Regulations
• Video pilot project – Looking for your help
• Survey
Page 6
Snapshot of Obligations
• Obligations were phased in over 4 years
• On June 2012, Regulations were fully in force
• Prohibited practices:– Leaking storage tank systems cannot be operated; – Unidentified storage tank systems cannot be operated, i.e. filled; – Installation, withdrawal from service, and removal of a storage
tank system must only be performed by certified persons
• Minimum technical standards for design and installation based on national standards and codes of practice
Page 7
Snapshot of Obligations (continued)
• Register and label STS• Emergency plan • Keep records for five years or longer • Report leaks to Minister• Regularly inspect for leaks• Systems installed by specified entities • Design plans, drawings and specifications that bear stamp and
signature of professional engineer • Replace “high-risk” tanks (2012)• Product transfer area designed to contain spills (2012)
Page 8
What are the most common problems?
• Incomplete emergency plan
• Improper installation
• Lack of leak detection testing and maintenance
• ‘High-risk’ tanks in service
• Poor design and set-up product transfer areas to contain spills during fuel transfer
• Poor record keeping
• Lack of identification
Page 9
High risk tanks
• Only 3 FSTS still in service in Ontario located on First Nation Lands identified in FIRSTS
– Are they really still in service?– Is it an identificaiton mistake?
Page 10
Emergency Plans
• Emergency plan tells response team what to do if something goes wrong such as a leak or spill
– Includes location of spill equipment, contact numbers, training
• Often emergency plans are missing name, phone number or responding procedures and communication plan
• 50% of identification in FIRSTS do not specify the location of plan
Page 11
Leak Detection
• When a leak starts leak detection helps to minimize harm
• For an aboveground tank, leak detection could be as straightforward as regularly walking around the tank and piping looking for leaks
• Many tanks now come with leak detection installed
Page 12
What is a Product Transfer Area?
The area around the connection points between a delivery vehicle and STS
CURB
Page 13
Product Transfer Areas (PTAs)
• Prevent problems by helping to contain spills that occur during tank filling
• A good PTA should be designed to contain sufficient volume to contain most spills
Page 14
Product Transfer Areas
• There are several systems that have not indicated they have a design in place
Page 15
Identification – On-line - To Obtain System ID
On-linewww.ec.gc.ca
“FIRSTS”
Page 16
Identification - Paper Form
(Page 1 of 6)
Remember: Fuel deliverer could be in violation if they fill tank without an
ID #
Page 17
Spill reporting
• 5 incidents reported in Ontario in 2012
• No Enforcement inspection where non-compliance found
UseSpill Reporting Lines Across Canada
In Ontario – Spills Action Centre
1-800-268-6060
Page 18
Keep Secondary Containment Empty
• Poorly maintained secondary containment can be problematic
• Keep secondary containment free of water, and do not use it for storage
Page 19
What happens if an EC Enforcment Officer (EO) inspects your system?
• Will identify themselves and ask questions about your tank system and other requirements of the regulations
• Will look for ID number and may ask to see some documentation (e.g. emergency plan, maintenance records, leak detection records, etc.)
• If a problem is found, EO will typically let you know what it is and may give you a timeframe to address it
– Most 2 common types of tools used to address a violation
▪ Warning Letter
▪ Environmental Protection Compliance Order (EPCO)
Page 20
Available resources
Useful websites• EC’s Storage Tank website for Petroleum and Allied Petroleum
Products – http://www.ec.gc.ca/st-rs/. Contains link to Regulations.
• CCME Environmental Code of Practice for Aboveground and Underground Storage Tank Systems Containing Petroleum and Allied Petroleum Products – http://www.ec.gc.ca/ceparegistry/documents/regs/CCME/toc.cfm
• Compliance and Enforcement Policy for the Canadian Environmental Protection Act, 1999 -http://www.ec.gc.ca/CEPARegistry/documents/policies/candepolicy/toc.cfm
• National Fire Code of Canada http://www.nationalcodes.ca/nfc/index_e.shtml
Page 21
Available Resources (continued)
Lisa McClemens, Environment Canada – Ontario [email protected](613) 949-8278
Aaron Dornan, Environment Canada Headquarters – [email protected](819) 934-2991
Marie-Michelle Modéry, Environment Canada Headquarters – [email protected](819) 953-0459
General inquiries: [email protected]
Page 22
Thank You
Page 23
Appendix A- Leak detection overviewMaintenance or inspection Required for Frequency
Inventory reconciliation
Aboveground single-walled tanks and piping without secondary
containment
For visual inspections following the strategy outlined below, once every seven days (or every day of use for a distribution site for justified reasons) or based on level
of use of the system (NFCC and CEPA)
Underground single-walled tanks and piping
Once every seven days or based on the level of use of the system (or every day of
use for a distribution site for justified reasons) (NFCC)
Leak detection test
Aboveground single-walled tanks and piping without secondary
containment
Once a year (or a monthly visual inspection as indicated below, or implementation of a
piping corrosion analysis program, designed and implemented by a corrosion
expert, with at least one annual inspection) (CEPA)
Underground single-walled tanks and piping
Once a year or before putting back in service a UST that had been temporarily
withdrawn from service for more than one year (CEPA)
Note: NFCC requirements are once every two years.
All systems If a leak is suspected (CEPA and NFCC)
Visual inspection Aboveground single-walled tanks
and piping without secondary containment
Once a month (or an annual leak detection test as indicated above, or the
implementation of a piping corrosion analysis program) (CEPA)
Advantages Disadvantages Sumps Once a year (CEPA and NFCC)
No power needed
Only surface flaws can be
found
Oil-water separators Once a month (CEPA)
Rapid Results Highly
interpretive requires high
degree of inspector
knowledge regarding
processes and materials
The trained eye can see
a small object
(0.0035’’) at a distance of
12 inches away
Cathodic protection Underground systems with
cathodic protection Once a year (CCME)
Internal inspection Aboveground single-walled vertical
tanks (tank farm) Once every 10 years or based on API 653
inspection results (CEPA)
