United States
Environmental Protection
Agency
Environmental Monitoring
and Support Laboratory
PO Box 15027
Las Vegas NV 89114
EPA-600/4-79-027
April 1979
Research and Development
xvEPA
Reconnaissance of
Hazardous Substances
Spills and Spill-threat
Conditions
-------
RESEARCH REPORTING SERIES
Research reports of the Office of Research and Development, U.S Environmental
Protection Agency, have been grouped into nine series. These nine broad categories
were established to facilitate further development and application of environmental
technology. Elimination of traditional grouping was consciously planned to foster
technology transfer and a maximum interface in related fields. The nine series are:
1. Environmental Health Effects Research
2. Environmental Protection Technology
3. Ecological Research
4. Environmental Monitoring
5. Socioeconomic Environmental Studies
6. Scientific and Technical Assessment Reports (STAR)
7. Interagency Energy-Environment Research and Development
8. "Special" Reports
9. Miscellaneous Reports
This report has been assigned to the ENVIRONMENTAL MONITORING series.This series
describes research conducted to develop new or improved methods and instrumentation
for the identification and quantification of environmental pollutants at the lowest
conceivably significant concentrations. It also includes studies to determine the ambient
concentrations of pollutants in the environment and/or the variance of pollutants as a
function of time or meteorological factors.
This document is available to the public through the National Technical Information
Service, Springfield, Virginia 22161
-------
EPA-600/4-79-027
April 1979
AERIAL RECONNAISSANCE OF HAZARDOUS SUBSTANCES
SPILLS AND SPILL-THREAT CONDITIONS
by
H. V. Johnson
Lockheed Electronics Company, Inc.
Remote Sensing Laboratory
Las Vegas, Nevada 89114
Contract No. EPA 68-03-2636
Project Officer
C. E. Lake
Remote Sensing Division
Environmental Monitoring and Support Laboratory
Las Vegas, Nevada 89114
ENVIRONMENTAL MONITORING AND SUPPORT LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
LAS VEGAS, NEVADA 89114
-------
DISCLAIMER
This report has been reviewed by the Environmental Monitoring and Support
Laboratory-Las Vegas, Nevada, U.S. Environmental Protection Agency, and
approved for publication. Approval does not signify that the contents
necessarily reflect the views and policies of the U.S. Environmental
Protection Agency, nor does mention of trade names or commercial products
constitute endorsement or recommendation for use.
-------
FOREWORD
Protection of the environment requires effective regulatory actions that
are based on sound technical and scientific information. This information
must include the quantitative description and linking of pollutant sources,
transport mechanisms, interactions, and resulting effects on man and his
environment. Because of the complexities involved, assessment of specific
pollutants in the environment requires a total systems approach that
transcends the media of air, water, and land. The Environmental Monitoring
and Support Laboratory-Las Vegas contributes to the formation and enhancement
of a sound, integrated monitoring data base through multidisciplinary;
multimedia programs designed to:
• develop and optimize systems and strategies for monitoring pollutants
and their impact on the environment
• demonstrate new monitoring systems and technologies by applying them to
fulfill special monitoring needs of the Agency's operating programs
This report discusses aerial reconnaissance procedures for monitoring
chemical production and storage facilities. Spill and spill-threat conditions
that exist in many chemical production and storage facilities are
photographically documented. The photographic examples of chemical spills and
spill-threat conditions and reconnaissance procedures presented in this report
can assist EPA regional offices charged with monitoring chemical facilities
for compliance with anticipated spill prevention regulations to be issued
under authority of the Federal Water Pollution Control Act (FWPCA) as amended
in 1977.
u
George B. Morgan'
Director
Environmental Monitoring and Support Laboratory
Las Vegas
m
-------
SUMMARY
The U.S. Environmental Protection Agency's Environmental Monitoring and
Support Laboratory in Las Vegas, Nevada, conducted aerial reconnaissance over
a number of industrial facilities engaged in the production, storage, and
handling of hazardous substances that are located near navigable waters of the
United States. The purpose of this project was to demonstrate that aerial
reconnaissance procedures currently utilized in monitoring oil production,
refining, and storage facilities can be applied to monitoring chemical
production and storage facilities to show whether spills or spill-threat
conditions exist within chemical production and storage facilities, and to
provide annotated photographic examples of spill conditions. Typical in-plant
facilities covered in this reconnaissance include: (1) product storage
facilities, including storage and holding tanks, drum storage and staging
areas, and dry-product stockpiles; (2) product transfer facilities, such as
marine and river terminals, and tank car and truck loading racks; and (3)
plant drainage and wastewater treatment facilities. The photographic examples
can serve as training aids for both experienced remote sensing specialists and
inexperienced personnel engaged in monitoring chemical facilities for
compliance with anticipated spill prevention regulations to be issued under
authority of the Federal Water Pollution Control Act (FWPCA) as amended in
1977.
In phase 1 of the project, a survey of current literature and depositories
of chemical spill history information was conducted to identify and describe
those facility elements of spill prevention and containment most often related
to chemical spills and spill-threat conditions that can be readily monitored
from overhead.
In phase 2, aerial photography was collected and analyzed in detail, and
representative examples of a wide range of spill and spill-threat conditions
were selected and annotated with the analysis results for inclusion in this
report. The photographic examples were selected to emphasize the critical
areas within a plant most likely to be involved in spill incidents. The
reconnaissance procedures used, i.e., flight parameters, camera and film
types, interpretation techniques, and documentation formats, were developed
and refined by the Remote Sensing Division of the Environmental Monitoring and
Support Laboratory in Las Vegas for monitoring oil-related facilities.
The photography acquired for this project clearly demonstrates that spill
and potential spill conditions are common occurrences in most chemical
production, storage, and handling facilities. In particular, most facilities
overflown had storage and holding tanks totally lacking secondary containment
structures, and tank car and truck loading/unloading facilities, and marine
and river terminal facilities often lacked visible means of containment should
IV
-------
accidental spills occur. Finally, surface drainage in a majority of
facilities was inadequate to prevent major spills from escaping the plant
properties and entering the natural drainage systems, including navigable
waters.
Once hazardous substances spill prevention and control regulations have
been put into effect, aerial reconnaissance can be effectively and
economically utilized to augment the compliance monitoring efforts of the EPA
regions or other regulatory agencies. An airplane can overfly a large number
of facilities in a brief period of time. With a reconnaissance report in
hand, spill prevention personnel can use the interpretation results to plan
facility inspection itineraries. Time can be devoted primarily to those
facilities with visible problems. The time required to inspect each plant can
be reduced by concentrating on those areas within a plant that the photographs
indicate may have spill problems. The annotated photographs can also serve as
a facility map for use during inspections and as a reference base should a
major spill occur in the future.
-------
CONTENTS
Foreword iii
Summary iv
Figures viii
Acknowledgment xi
1. Introduction 1
Background 1
Purpose 2
Objectives 3
Scope 3
2. Conclusions 4
3. Recommendations 6
4. Aerial Reconnaissance in Support of Oil Spill Prevention,
Control, and Countermeasures Compliance Monitoring 7
5. Reconnaissance Procedures for Monitoring Hazardous Substances
Spill Conditions 10
Mission Planning 10
Data Acquisition and Processing 13
Image Analysis 13
Reconnaissance Report 14
6. Hazardous Substances Spill Conditions 15
High Spill-Risk Conditions 16
Potential Spill Areas 17
7. Photographic Survey of Hazardous Substances Spill Conditions ... 19
Aerial Photography 19
Photographic Examples of Spill Conditions 19
References 60
Vll
-------
FIGURES
Number Page
1 Typical oil SPCC reconnaissance photograph with coded photo
analysis 8
2 Index to the oil SPCC reconnaissance interpretation code .... 9
3 Comparison of target signature differentiation capabilities
between color and black and white photography over a portion
of a chemical production facility 12
4 Overview of a large chemical manufacturing facility 21
5 An enlarged or "closeup" view of a small section of the chemical
plant in Figure 4 22
6 Uncontained storage tanks at a cellophane and sodium sulfate
production facility 23
7 Spill conditions in the processing area of a large industrial
chemical production facility 24
8 Spillage from processing/holding tanks 25
9 Spill conditions at a small chemical packaging facility lacking
secondary containment structures for a number of storage tanks
and drums 26
10 Uncontained tanks and drums at a chemical packaging facility . . 26
11 Spill conditions at a chemical packaging facility 27
12 Stained tanks caused by overflow leaks 29
13 Product storage tanks with adequate secondary containment dikes. 29
14 Absence of drum containment and inadequate surface drainage
control 30
15 Heavy product spillage in a drum storage yard 31
16 Well-engineered dry material storage facilities 31
vm
-------
Number
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
Dry material stockpiles at a titanium dioxide production plant .
Inadequately contained raw material stockpile at a small
manufacturing facility
Inadequately contained raw material stockpiles at a large
industrial chemical manufacturing facility
Spill conditions associated with dry product storage
Example of clean, well-engineered tank car racks and rail
sidings at a large chemical manufacturing plant
Spill conditions at a chemical tank car rack
Truck and rail tank car racks at a large industrial chemical
production facility
Heavy spill stains at the tank car terminal of a small chemical
manufacturing facility
Marine terminal facilities at a large chemical manufacturing
complex
Oblique view of the large marine terminal seen in Figure 25 . .
Product transfer operations at a barge terminal
River terminal facilities for offloading and storing dry product
(raw materials) at two large chemical manufacturing plants . .
Waste water treatment facility at a titanium dioxide production
facility
Haste water discharge at a small part of a large industrial
chemical production facility
Surface drainage at an organic chemical production facility . .
Damaged vegetation from surface runoff at a large chemical
plant
Oblique enlargement of the facility shown in Figure 32
Haste treatment and drainage facilities at a large chemical
processing plant
A network of canals and ditches draining a large chemical
production facility
Page
33
33
34
35
36
37
38
39
40
41
42
43
45
46
47
48
50
51
52
-------
Number Page
36 An enlarged, oblique view of a section of the drainage system
shown in Figure 35 53
37 Untreated waste water discharged into river 54
38 Waste discharge from an acrylic resins production facility ... 55
39 Inadequate drainage control at a chemical packaging facility . . 56
40 The waste dump at this facility is the source of the oil sheen
extending over the harbor waters 57
41 Engineered drainage gathering surface runoff and product
spillage for eventual discharge into a nearby river 58
42 Engineered drainage posing a threat to an adjacent creek .... 59
-------
ACKNOWLEDGMENTS
Mr. .]. Leslie Goodier, consultant with A. 0. Little, Inc., now with
Battelle Memorial Institute, participated in phase 1 of the project. He drew
on his wealth of knowledge and on-the-ground experience with oil and hazardous
substances spills to provide essential background material and descriptions of
potential oil and chemical spill sources.
XI
-------
SECTION 1
INTRODUCTION
BACKGROUND
In 1972, the Environmental Protection Agency (EPA) estimated that, from
all sources, 50 billion gallons* of the Nation's water were polluted each
year.1 The proportion of this total that was attributable to hazardous
substances (chemical) spills was essentially unknown. Coast Guard statistics
for 1972 showed approximately 18.8 million gallons of oil and other hazardous
substances reported as spilled.2 By 1976, the volume of all reported
pollutants exceeded 33.8 million gallons, of which 23.1 million gallons were
classified as oil of all types. "Liquid chemicals" accounted for 2.1 million
gallons of the total reported spillage.3
The lack of detailed information on designated hazardous substances spills
is due primarily to the fact that there have been no Federal regulations that
require the reporting of hazardous substances spills.4 As a result, what
little is known of the magnitude of chemical spills has been acquired
primarily from the relatively small number of spill incidents that have been
voluntarily reported, i.e., 296 in 1976.3
Nevertheless, Congress recognized the threat to the Nation's environment
and public health posed by chemical spills when it enacted the Federal Water
Pollution Control Act (FWPCA) Amendment of 1972. Section 311 of that act
specified that the executive branch would establish a National Contingency
Plan for the removal of "oil and hazardous substances" from the Nation's
harbors and navigable waterways. The executive branch was also directed to:
• establish methods and procedures for removal of discharged oil and
hazardous substances,
« establish the criteria for development and implementation of local and
regional oil and hazardous substances removal contingency plans, and
• establish procedures, methods, and equipment and other requirements for
equipment to "prevent" discharges of oil and hazardous substances from
vessels and from onshore facilities, and to "contain" such
discharges.5
The objective of the law was to eliminate the discharge of pollutants into the
navigable waters in the U.S. by 1985.^
*British units are used because the data in the literature were reported in
British rather than metric units.
-------
Until recently, primary emphasis has been directed toward the prevention,
control, and elimination of oil pollution. EPA published oil pollution
prevention regulations (Title 40 CFR Part 112) in December 1973 which became
effective in January 1974.7 These regulations established procedures,
methods, and equipment requirements for owners or operators of facilities
engaged in drilling, producing, gathering, storing, processing, refining,
transferring, distributing, or consuming oil. The primary vehicle achieving
the purpose of the regulations was the requirement for the preparation and
implementation of oil spill prevention control and countermeasures (SPCC)
plans by owners and operators of nontransportation-related facilities with
aggregate surface storage of more than 1,320 gallons and single tanks with a
capacity of greater than 660 gallons.
The Clean Water Act of 1977, enacted in December of that year, extensively
amended the Federal Water Pollution Control Act. Section 311 was amended to
authorize "EPA to act to mitigate damages to public health and welfare
resulting from discharges of nonremovable substances, and to assess the costs
to dischargers."6 In addition, cleanup liability charges were revised, and
the "area of applicability" was extended beyond the contiguous zone to include
"activities" under the Continental Shelf Land Act or the Deepwater Port Act of
1974.
Through 1977, regulatory emphasis has been devoted primarily to the
cleanup, control, and prevention of oil discharges and spills. Regulations
relating to the prevention and control of hazardous substance spills will be
developed and implemented in Fiscal Year 1979 and 1980. It is anticipated
that in Fiscal Year 1979 EPA will issue spill prevention regulations for
hazardous substances similar to existing oil spill prevention regulations.
PURPOSE
As spill prevention and control regulations are implemented under
authority of Section 311 of the FWPCA 1972 and 1977 amendments, the concurrent
implementation of an effective compliance monitoring system will be essential.
The potential use of remote sensing technology to implement a spill detection
system was recognized by EPA's Oil and Special Material Control Division
(OSMCD) in 1976 when it requested the Remote Sensing Division, Environmental
Monitoring and Support Laboratory (EMSL-LV) to conduct aerial reconnaissance
operations over oil production, refining, and storage facilities in several
sections of the country to augment the oil SPCC compliance monitoring efforts
of the individual EPA regions. With the success of this initial effort (the
results of the oil SPCC reconnaissance efforts are detailed in Section 4 of
this report), the OSMCD requested the Remote Sensing Division (RSD) to develop
a similar approach for monitoring chemical facilities. Considering the large
geographical areas encompassed by each region, the number of installations
potentially involved, and the frequencies required for adequate surveillance,
overhead monitoring techniques can be used to advantage. While remote sensing
systems will not replace onsite investigations, they can be important tools to
indicate priority areas that merit onsite evaluation.
The purpose of this project is the development of procedures and criteria
(photographic examples or keys) required to employ remote sensing to locate,
-------
identify, and analyze hazardous substance spills and potential spill
conditions that may represent a threat to the environment.
OBJECTIVES
The basic objective of the project was to define, develop, and demonstrate
remote sensing techniques to rapidly and economically monitor hazardous
substances spill and spill-threat conditions that can be utilized by
appropriate EPA staff, regional program offices, states and other government
agencies participating in environmental planning and enforcement. The primary
goals are to be able to:
• detect potential spill problems areas,
• characterize plant conditions with respect to maintenance and
operation,
• develop criteria for monitoring and monitoring systems,
• develop criteria for optimization of followup on-site inspections of
problem areas, and
• develop documentation for regulatory action.
SCOPE
The reconnaissance procedures and spill criteria (photographic examples)
are restricted to in-plant, nontransportation-related facilities. In
addition, primary emphasis is placed on features and conditions most
frequently related to hazardous substances spills and, of necessity, those
features and conditions that can be photographed from an airplane.
The project was conducted in two phases. In phase 1, a survey was
conducted to determine which plant conditions or features amenable to
detection by aerial remote sensing are most often responsible for or
associated with spills. All facets of a chemical complex were investigated,
including location and physical setting of processing, handling, storage, and
disposal facilities. In addition, a review was conducted of pertinent
references and depositories of chemical spill history information within EPA
and other applicable environmental regulatory agencies. The results of
phase 1 included a list and description of facility elements to be
photographed and analyzed, the suggested sites for gathering aerial
photography, and a tentative format and outline for documenting the
photographic results.
Phase 2 of this project entailed collecting the required aerial
photography, analyzing the film, and documenting the results. Section 4
briefly describes the oil SPCC reconnaissance program, which served as the
model and test vehicle for the reconnaissance procedures detailed in
Section 5. Hazardous substances spill features and conditions encountered in
chemical plants and amenable to remote sensing are described in detail in
Section 6. Section 7 presents the photo analysis results, which include
annotated photographs of spill features and spill conditions, and descriptions
of conditions seen in each photograph.
-------
SECTION 2
CONCLUSIONS
This project clearly demonstrated that a wide range of facility features
and operating conditions related to hazardous substances spills and
spill-threat conditions can be recorded on color aerial film for subsequent
analysis.
In the aerial photographic survey conducted for this project, nearly 100
chemical production, storage, and handling facilities were overflown. From
the film analysis results, it can be concluded that, for a large majority of
the facilities photographed, even the most rudimentary spill prevention and
control measures are either absent or, at best, inadequate. There is a
general absence of secondary containment structures (dikes or similar
barriers) particularly for holding/day tanks within processing areas and drum
storage areas. In addition, drainage control at most facilities is
inadequate, with surface drainage bypassing waste treatment facilities. There
is a general absence of spill control measures at points of product transfer,
and containment of raw material/dry product stockpiles is commonly inadequate
to prevent leaching and transport of these materials into nearby natural
drainage systems.
The basic aerial reconnaissance procedures being conducted for ongoing oil
SPCC reconnaissance support projects can be readily utilized in aerial
monitoring of chemical facilities. Spill features and conditions visible to
an aerial camera are generally the same for both oil and chemical facilities,
notwithstanding the relative complexity of the cleanup and amelioration posed
by chemical spills.
Once hazardous substances spill prevention and control regulations have
been put into effect, aerial reconnaissance can be effectively and
economically utilized to augment the compliance monitoring efforts of the EPA
regions or other regulatory agencies. An airplane can overfly a large number
of facilities in a brief period of time. Once a reconnaissance report has
been completed, spill prevention personnel can use the interpretation results
to plan facility inspection itineraries. Time can be devoted primarily to
those facilities with visible problems. The time required to inspect each
plant can be reduced by concentrating on those areas within a plant that the
photographs indicate may have spill problems. The annotated photographs can
also serve as a handy facility map for use during inspections and as a
reference base should a major spill occur in the future.
-------
Finally, it is apparent that aerial reconnaissance can also serve as a
useful tool for industry. A company can inspect its own facilities for spill
problem areas. The resulting photographs can be used as a photo-base map for
planning, setting priorities, and monitoring progress of corrective measures.
-------
SECTION 3
RECOMMENDATIONS
The procedures for conducting an aerial reconnaissance of chemical
facilities were essentially the same for oil production, processing, and
storage facilities. Likewise, these procedures can be applied to other
industries that handle hazardous substances—principally, the user of consumer
industries. Those industries that store and handle chemical substances in
facilities that may be readily monitored from the air include: iron and
steel, aluminum, fertilizer, pulp and paper, paint and pigments,
Pharmaceuticals, detergent, and textiles.
The utility of this report as a "key" for interpreting aerial photographs
of hazardous substances spill and spill-threat conditions can be further
enhanced for both photo interpreters and personnel responsible for regulation
compliance monitoring if it is supplemented with annotated photographic
examples (keys) and descriptions of spill-related conditions peculiar to the
user industries listed above.
As regulatory authorities prepare pending hazardous substances spill
prevention, control, and countermeasures regulations, consideration must be
given to the widespread inadequacy of spill prevention and recovery features
and conditions within nontransportation-related chemical processing, handling,
and storage facilities, as demonstrated by the photographic examples in this
report. At least minimum standards should be established for construction of
secondary containment dikes, walls, or other structures for storage tanks,
processing holding tanks, raw material stockpiles, and drum storage areas.
Similar standards should be set for waste treatment facilities and plant
drainage. Ideally, all surface drainage ditches should be integrated with the
plant waste treatment system, assuring that product spillage will not directly
escape the premises nor be transported via rainfall runoff beyond the premises
before it can be removed or properly treated. Finally, the general absence of
spill control and recovery measures at points of product transfer, including
tank car and truck racks, as well as marine and river terminal facilities
where spills are a common occurrence, emphasizes the need for minimum
standards for prevention, control, and recovery of hazardous substances
spills.
-------
SECTION 4
AERIAL RECONNAISSANCE IN SUPPORT OF OIL SPILL PREVENTION,
CONTROL, AND COUNTERMEASURES COMPLIANCE MONITORING
With the enactment of the FWPCA Amendments of 1972, the EPA sponsored
research and demonstration projects to assess the feasibility of using
remote sensing techniques for monitoring oil refineries and industrial
activities.8,9,10 These efforts concentrated primarily on oil facilities,
but they clearly demonstrated the potential of applying the techniques to
chemical facilities and spill conditions.
Implementation of the SPCC regulations in 1974 presented the 10 EPA
regional offices with the task of monitoring thousands of facilities for
regulation compliance. Limited manpower resources to cover the task of the
regions greatly restricted effective compliance monitoring. Nationwide there
are an estimated 30,000 bulk oil storage terminals, tank farms, and bulk
plants, 285 oil refineries, and several thousand more facilities storing and
consuming oil. In general, it has only been possible to spot-check sites
within a region, concentrating on those facilities with high spill potential
in close proximity to major waterways and responding to specific spill
complaints and reports.
At the request of the EPA's Oil and Special Materials Control Division
(OSMCD) in Washington, D.C., the Environmental Monitoring and Support
Laboratory (EMSL-LV) in Las Vegas, Nevada, implemented an aerial photographic
reconnaissance program to assist the SPCC compliance monitoring efforts of
each of the EPA regions.^ In the first year and a half of operations,
EMSL-LV conducted aerial surveys in 9 of the 10 EPA regions. These surveys
covered 56 large refineries, 235 bulk oil storage terminals, 100 chemical-
related facilities, 29 power utilities, 23 railroad yards, and nearly 150
other industrial sites having some type of petroleum product storage.^ As
a result of these missions, numerous oil spills and potential spill conditions
were documented. As an example, aerial photography obtained in the
San Francisco Bay area, EPA Region IX, indicated some 90 instances of
potential SPCC violations. Followup ground inspections found 31 violations,
and appropriate citations were issued.
The typical SPCC reconnaissance report includes a summary of the project
operations, a detailed index of all facilities photographed, maps showing the
location of each site, large-scale color prints with a transparent overlay
with the coded analysis (Figure 1), and a textual summary of the photo
analysis of each- site. An index to the interpretation code is printed
alongside each photograph to facilitate an understanding of the code used on
the overlays (Figure 2).
7
-------
SITE 68
RIVER
Figure 1. Typical oil SPCC reconnaissance photograph with coded photo analysis.
8
-------
INTERPRETATION
SPILL CONDITIONS CODE
No secondary containment 1
Breach in secondary containment 2
Inadequate secondary containment 3
Product spillage outside containment 4
Point of entry of old spill into drainage 5
Oil slick and/or sheen on water 6
Leaking or deteriorating tanks 7
POINTS OF INTEREST
Tank car/truck loading racks 8
Drum storage area 9
Waste water treatment facilities 10
Waste water outfall 11
Vegetation damage 12
Figure 2. Index to the oil SPCC reconnaissance interpretation code.
The data obtained from the imagery provide an excellent source of
information on the general operating conditions within a plant and on the
drainage pattern leading to the nearest waterway, as well as a general
inventory of the tanks and equipment within the plant. In addition, the
photographs serve as excellent facility maps for a ground inspection team.
Utilizing a reconnaissance report, the regional inspector can plan an
inspection itinerary that concentrates on those facilities or locations within
a facility that appear to be in noncompliance with the regulations and that
bypasses those facilities with no apparent spill conditions. This program of
applying remote sensing technology to assist SPCC compliance monitoring
efforts has been welcomed by many of the EPA regions and has led to requests
for additional aerial reconnaissance flights.
-------
SECTION 5
RECONNAISSANCE PROCEDURES FOR MONITORING
HAZARDOUS SUBSTANCES SPILL CONDITIONS
The chemical spill problem is extremely complex in comparison to the
problems posed by the prevention, control, and amelioration of oil spills. In
addressing chemical spill prevention, consideration must be given to the
physical state of the substances (liquid, solid, or gas) and their chemical
properties, in particular, flammability, corrosiveness, human toxicity, and
reactivity.13 Hazardous materials must be further categorized as soluble
substances, floaters or oily substances, or insoluble or sinking substances
before specific spill cleanup measures can be taken.4
Notwithstanding these complex conditions, EMSL-LV's experience in
performing aerial reconnaissance in support of oil SPCC monitoring has shown
conclusively that in most instances product storage and transfer structures,
as well as spill containment structures, in a chemical facility are similar to
those found in an oil storage and processing facility. When viewed through
the lens of an aerial camera, storage and holding tanks, secondary containment
structures, pipelines, and product transfer structures are essentially the
same for both oil and chemical facilities.
The typical aerial reconnaissance operation over a chemical facility will
normally follow the same procedures and techniques used for oil SPCC
reconnaissance. Each project is conducted in four stages, including mission
planning, data acquisition and processing, image analysis, and report
preparation.
MISSION PLANNING
Aerial Cameras
During mission planning, the project leader consults with the EPA regional
office requesting the reconnaissance support. The list and identification of
facilities or areas to be overflown is compiled. In addition, the sites are
put in order of priority based on the region's inspection requirements.
Aircraft flight parameters and other data acquisition parameters are specified
and combined with flight maps into a flight plan folder.
In past oil SPCC missions, photography has been acquired with RC-8, RC-10,
Zeiss, or equivalent cameras. These are standard aerial mapping cameras,
which normally have a 15.24-cm (6-inch) focal length, color-corrected lens,
10
-------
and 22.86-cm (9-inch) film format. A majority of aerial survey firms
throughout the country utilize these cameras; thus, -his camera type is
generally available for contract surveying. Mapping cameras are particularly
desirable because geometric distortion is minimal; thus, each photographic
print can serve as a photo-base map, which is extremely valuable where current
maps are not available or are of inadequate scale. In addition, these camera
lenses are suitable for color aerial film, and the resolving power of the
optics is sufficient to provide clear, sharp images for analysis.
Aerial Films
Color aerial film is necessary for SPCC reconnaissance missions. The
Earth Satellite Corporation study conducted for EPA in 1972 revealed that
standard color film was useful for monitoring spill prevention features.8
Color aerial film is used instead of black and white film since many pertinent
target signatures cannot be differentiated on black and white film. In
particular, water, oil, and many other substances appear to be the same tone
on black and white film. Figure 3 demonstrates the obvious advantage of color
film over black and white film for differentiating water from product spillage
and dead or damaged vegetation from live vegetation.
The initial SPCC projects in 1976 used Kodak 2445 color negative film with
a "clear" filter. This is a high-speed mapping and reconnaissance film that
is generally available throughout the aerial surveying community. However,
considerable resolution is lost in the process of producing the duplicate film
transparency that is required before the film can be interpreted. In
addition, the duplication cost is relatively expensive as a result of the high
cost of the duplication film (Kodak 4109).
Soon after the initial SPCC projects, a switch was made to color-reversal
film, Kodak 2448 and SO-397, both of which are flown with "clear" filters for
haze reduction. Both films are slower than the 2445 negative film but match
its resolution. These two color-reversal films are duplicated with minimum
loss of resolution and at a significantly lower cost when compared to
duplicating from 2445 negative film. Both films produce acceptable imagery
for analyzing chemical spill conditions. SO-397 is somewhat faster, requiring
less illumination and providing better detail in shadow areas. However, 2448
film is generally stocked and more readily available throughout the country,
and acquisition of photography through contractors is accomplished more
rapidly with this film type.
Flight Parameters
Photography over a chemical facility may be collected at a variety of
altitudes depending on the size of the facility being photographed. The
primary guideline is to acquire the desired photo coverage in a single pass of
the airplane. Experience has shown that the maximum acceptable altitude for
the acquisition of color photography for SPCC reconnaissance projects is 4,200
feet (1,280 m) above ground level, which produces a photo scale of 1:8400.
Smaller scale photography, acquired at higher altitudes, will often be
incapable of resolving the spatial parameters of many engineering deficiencies
under observation. Overflights of very large facilities, covering a lateral
11
-------
Figure 3. Comparison of target signature differentiation capabilities between color and
black and white photography over a portion of a chemical production facility.
12
-------
area in excess of 6,300 feet (1,9?U m), will require more than one pass of the
airplane if the entire facility is to be inspected. Normally, all flight-line
altitudes are planned at 4,200 feet (1,280 m) above ground level so that photo
scales are constant.
Clear weather--!.e., no clouds or cloud shadows over the facility being
photographed--is a necessary data acquisition parameter. In addition, a sun
angle of 30° or higher is required. Sun angles of less than 30° create
excessive shadows, especially wit'iin processing areas where t^pre may be
numerous high structures; as a result, features of prime interest may be
obscured. Low sun angles during the winter months, coupled with snow cover on
the ground, generally restrict the conduct of aerial reconnaissance in the
northern latitudes of the United States to the lat.p spring, summer, and fall
months. Reconnaissance operations over chemical facilities in the southern
United States, i.e., latitude 30° or less, are not adversely affected by sun
angle restrictions and can generally be scheduled throughout the year, weather
permitting.
The final step in mission planning is the assembly of the final flight
maps, with designated flight lines drawn on them, and completion of a "flight
plan" form which specifies the sensor, film, filter, and flight parameters for
each site to be overflown.
DATA ACQUISITION AND PROCESSING
At the completion of mission planning, the flight maps, flight plan, and
film are delivered to the aircrew (pilot and aerial photographer). At that
time the aircrew is briefed on details of the mission requirements, and any
technical questions are resolved. Should it be necessary to contract the data
collection, aerial survey firms in the area to oe overflown are contacted to
solicit bids to fly the photography. The flight maps, plans, and logs are
sent to the firm selected to fly the mission. If the firm does not have the
required film in stock, E"SL-LV also provides the original film.
Once the mission is completed, the original film and logs are returned to
Las Vegas for processing. The original film is developed and carefully
screened by the project leader image analyst to evaluate the quality and
accuracy of the mission coverage. Once accepted by the image analyst, the
film is titled and returned to the photo lab for duplication. A duplicate
color film positive is required for detailed analysis, and selected color
prints are required for the mission report.
I"^r ANALrsIS
Photo interpretation is conducted on the duplicate positive film
transparencies using a light table and a zoom stereoscope. The stereoscope
not only provides the necessary magnification but also allows viewing and
studying each facility in three dimensions. With the capacity of viewing
height differences, the adequacy and integrity of containment structures and
the slope and direction of surface drainage can be properly assessed. Image
13
-------
analysis includes the evaluation of spectral contrasts (color and tone) within
the image as well as spatial patterns such as size, shape, geometry, and
height of specific features of interest.
Image analysis is centered around the 12-item interpretation code
developed ftir the oil SPCC reconnaissance projects (Figure 2). Each facility
is scrutinized for conditions listed in the code. A transparent overlay to
the photograph is annotated with the analysis results using the proper code
number. Unique conditions not covered by the code may be annotated on the
photo overlay using abbreviated phrases, or the condition may be keyed to the
text where it is fully described.
RECONNAISSANCE REPORT
In the final phase of a reconnaissance project, the results of the photo
analysis are incorporated into an 11-inch by 15-inch (28-cm by 38-cm)
spiral-bound report, described in Section 4. Each site is identified by
facility name, if available. All sites are located on large-scale maps, and
these maps are referenced with the photograph of each site located on the map.
A photo analysis summary is written for each site, highlighting any spill or
potential spill problems seen in the photography. The coded overlays and
photographs are reproduced, collated with the text and maps, and then bound
for delivery to the region.
14
-------
SECTION 6
HAZARDOUS SUBSTANCES SPILL CONDITIONS
It is fully recognized that any spill control and prevention measures that
have been undertaken by a company for a facility or group of facilities have
been accomplished without benefit of "Federal guidelines or regulations, nor
the assistance of industrial codes or regulations developed over the years by
a trade association such as the .American Petroleum Institute."^
Thus, many of these measures have been "custom-designed" for a particular
facility or for the substances being handled. One such facility is the
Niagara Plant of the Hooker Chemicals and Plastics Corporation, in Niagara
Falls, New York.^ In the absence of regulatory guidelines, Hooker adopted
"best engineering practices to eliminate possible pollution incidents as a
result of spills." Many of the containment measures undertaken by Hooker at
this plant are identical to those found in a typical oil handling facility and
could be expected in any oil SPCC plan. Thus, "best engineering practices"
guidelines can result in a spill prevention plan that is remarkably similar to
a typical oil SPCC plan implemented under Federal regulatory guidelines.
The primary facilities within a chemical storage and production complex
that are amenable to aerial surveillance include: (1) product storage
facilities, such as storage and holding tanks, and dry product stockpiles; (2)
product transfer facilities, such as marine and river terminals, tank car and
truck racks, in-plant pipelines, and dry product conveyers; and (3) plant
surface drainage and waste treatment facilities. It is recognized that
materials produced, stored, processed, and transported within a chemical
complex are not all "designated hazardous substances." However, the contents
of tanks, pipes, and so forth cannot be determined directly from photography;
thus, all anomalies detectable from the film are considered a potential spill
condition.
Specific features that can be readily detected in color aerial photography
are divided or grouped into two broad categories. The first group of features
or conditions are those that relate directly to a spill or spill threat. The
list of these features includes:
1. The total absence of secondary containment
2. A breach in secondary containment
3. Inadequate secondary containment
15
-------
4. Product spillage or stains outside a containment structure
5. Leaking or deterioriating tanks
6. Point of entry of product spill into the natural drainage system
7. Product slick or sheen on water surface or discolored water
8. Damaged vegetation
In the second group are features that, while not directly related to spill
conditions, are often the site of numerous spills and are considered potential
spill areas. These areas warrant careful scrutiny when the aerial film is
interpreted. Within this group are such features as:
1. Tank car and truck loading racks
2. Large drum storage/staging areas
3. Waste water treatment facilities and waste dumps
4. Waste water outfalls
HIGH SPILL-RISK CONDITIONS
Storage tanks and the condition of their associated containment structures
are the principal targets for a spill reconnaissance. Most secondary
containments are earthen dikes that are readily discernible in the aerial
photography. The structural and containment integrity of most of these dikes
can be assessed with little difficulty. In a more confined situation such as
a processing area, containment may consist of concrete or steel walls. These
are more difficult to assess because of their smaller size and the fact that
they are often obscured by shadows from nearby tanks or other structures.
Breached dikes are not uncommon. Many dikes are deliberately breached to
facilitate entrance of vehicles and equipment for tank repair or construction.
However, when evidence of construction or repair activities is absent, a
breached dike is considered evidence of a spill threat. Ideally, entrance and
exit ramps should be present to permit vehicular access to the diked area.16
Adequacy of a containment dike is based on the condition of the dike,
i.e., whether it is badly eroded or in poor condition, and a judgment as to
the capacity of the dike to hold at least 100 percent of the volume of the
largest tank within the dike.
In addition, large amounts of standing water within a containment dike
reduce its capacity to contain a product spill, thereby posing a spill threat.
The total absence of a containment structure can be determined easily.
Where no containment structure is visible, the image analyst determines if a
16
-------
spill of any significance from the tank would be confined to the facility
property or enter into the natural drainage system.
Many dry (nonliquid or gaseous) products and raw materials found within a
chemical production facility are often stored in the open with little more
than a temporary wall erected as a containment structure. Spills can occur
from overloading the structure, collapse of the structure, or simply leaching
and washout during heavy rains. Evidence of spills of this nature is often
discernible with aerial photography.
Spill stains outside secondary containments are not always evidence of a
threat to the environment. Spill stains are common throughout chemical
production facilities. Most are small and confined to areas with adequate
protection to the drainage system. However, where stains are numerous and
heavy, close scrutiny of the film is warranted to determine the source of the
spills and whether or not any spillage has entered the natural drainage
system.
Leaking or deteriorating tanks are easily detected on the color film;
however, no spill threat is posed if the tanks are adequately contained and
there is no evidence that leakage is escaping the containment by way of the
drain valve or gate.
All drainage features in the vicinity of processing and storage areas
warrant close surveillance. Evidence of the product leakage or spillage from
the facility may include a sheen, slick, or discoloration on the water
surface. Once the point of entry of the discharge is identified, nearby
facilities are carefully scrutinized in order to detect the potential sources.
Damaged or dead vegetation is often evidence of a product spill or leakage
from nearby facilities. Damaged vegetation can be readily seen in color
photography and is a good indicator of a present or past spill condition.
POTENTIAL SPILL AREAS
Numerous product spills and resultant stains are quite common at points of
transfer, in particular at tank car and truck loading racks and the onshore
portions of river and marine terminals. The loading racks require careful
inspection to verify that large spills would not pose a threat to nearby
drainage. Both rail and truck racks should have an impervious (concrete)
loading unloading area and drainage engineered to direct any product spillage
into nearby sumps, catchment basins, or the waste treatment systems.13
Spills at river and marine terminals pose the most direct threat to the
natural drainage system. The aerial film should be analyzed carefully to
determine the presence of spill prevention features. Containment booms (for
floatable substances) should be in evidence at river and marine terminals,
either deployed during product transfer or located nearby for quick deployment
should a spill occur. Boom deployment often requires a motor launch, and one
should be located nearby in case of an emergency.^
17
-------
Drum storage areas are commonly the site of many spill stains, yet more
often than not these areas have no secondary containment structures.
Therefore, once a drum storage area is located in the photography, the
surrounding areas are carefully searched for evidence of spillage or leakage
reaching the nearby drainage.
Waste water treatment facilities and waste dumps are carefully inspected
to ensure that waste material has not leaked, leached, or otherwise spilled
into the nearby drainage system. Damaged vegetation in the vicinity of these
facilities often indicates the presence of product spillage. All waste water
outfalls are also inspected to see if they emanate from the waste treatment
facility or possibly an untreated source.
13
-------
SECTION 7
PHOTOGRAPHIC SURVEY OF HAZARDOUS SUBSTANCES SPILL CONDITIONS
AERIAL PHOTOGRAPHY
In August of 1976, EMSL-LV collected color aerial photography over a wide
range of chemical processing, storage, consumption, and handling facilities.
In these areas there are approximately 200 major chemical production
facilities, plus an untold number of storage, consumption, and handling
facilities.
The photography collected for this project was Kodak 2445 color negative
film, with a "clear" filter, acquired with a Zeiss RMK mapping camera with a
6-inch (152.4-cm) focal length lens. Vertical exposures were taken at 2,500
feet (762 m) above ground, producing an approximate scale of 1:5000. Oblique
exposures were taken over many facilities at 1,500 feet (457 m) above ground
level. Oblique photography was acquired primarily to document spill
conditions for inclusion in this report. Oblique exposures are more readily
read and understood by the untrained or inexperienced viewer than vertical
aerial photographs. Only vertical photography is normally acquired for
reconnaissance purposes.
In addition to the photography acquired specifically for this project,
photography collected over chemical-related facilities during the course of
routine oil SPCC reconnaissance overflights also provided a source of
photographic examples of spill features and conditions.
The majority of the photographic prints in this section of the report have
been enlarged to clearly depict the spill features of concern. Normally,
photo analysis is performed at the original scale, using stereomicroscopes to
enlarge the scene when necessary to resolve small features.
PHOTOGRAPHIC EXAMPLES OF SPILL CONDITIONS
Typical in-plant facilities covered in this section include: product
storage facilities, product transfer facilities, waste treatment facilities,
and drainage.
Product Storage Facilities
Storage facilities include tank farms and isolated tanks, holding tanks
(day tanks) generally located within processing areas, drum storage/staging
facilities, and dry product or raw materials stock piles. When viewing the
19
-------
photography, the image analyst interpreter must assess the structural
integrity of the primary containment features—tanks, or containment walls and
covers (roofs) in the case of stockpiles—as well as the adequacy and
integrity of secondary containment features and the potential threats to
drainage outside the plant boundary.
Figure 4 is an overview of a large chemical manufacturing facility
producing plastics, resins, and general compounded products. There are a
large number and variety of storage and holding tanks at this plant, most of
which appear adequately contained. Nevertheless, potential spill threats are
posed by the two largest storage tanks at the plant (A), which have no visible
means of secondary containment. A spill of any significance from either tank
would have a clear path to the nearby river. There are product spill stains
on the pier leading to the river barge terminal (B), the tank car rack (C),
and where some substance has either leaked or has been dumped into the
water (D). The four large tank barges noted on the lower-left section of the
photograph appear to be permanently moored.
An enlarged view of the dockside section of the plant in Figure 4 is shown
in Figure 5. This oblique view shows that the barges are being used for
storage of heated product (note the venting steam). The orange and brown
stains on the barge tops indicate that in the past the tanks have overflown
and the contents have clearly reached the river waters. These four tanks lack
any means of secondary containment. The spill stain noted at (D) in Figure 4
is clearly seen at (A) in this view. The spill stain at the tank car rack
noted at (C) in Figure 4 is confirmed in this photo at (B). The piers shown
in this photo are scattered with discarded hoses, drums, pipes, tanks, and
other pieces of wornout equipment—evidence of "poor housekeeping."
Examples of both horizontal and vertical product storage tanks without any
visible means of secondary containment can be seen in Figure 6. Both groups
of tanks pose a spill threat to the nearby stream. A dark-brown spill stain
can be seen at the base of the two horizontal tanks. Note also the product
spill leaving the three vertical tanks and entering the stream. Other spill
stains are also visible in this cellophane and sodium sulfate production
facility. Spillage of a white substance covers much of the center section of
this photograph. This material has reached the natural drainage at the two
points annotated on the photograph.
Uncontained processing/holding tanks (A) are the apparent source of
extensive product spillage in the processing area of the industrial chemical
production plant photographed in Figure 7. The orange and white colors of the
product spillage are easily distinguished from the pools of standing water in
the foreground, apparent remnants of heavy runoff from a recent rainstorm.
Some of the standing water has been heavily contaminated by the product
spillage, as evidenced by the discolored pools at (B). Dead vegetation on the
left is an indicator of the toxic effects of the product spillage. The
numerous drums scattered throughout the area are also a potential source of
spillage and contamination. Only one tank (C) is adequately contained with a
concrete wal 1.
20
-------
Figure 4. Overview of a large chemical manufacturing facility.
-------
rso
ro
•
Figure 5. An enlarged or "closeup" view of a small section of the chemical plant in Figure 4.
-------
POINT OF ENTRY *
SPILL INTO DRAINAG
\ '
-------
UNCONTAINED
TANKS
Figure 7. Spill conditions in the processing area of a large industrial chemical production
facility.
Quite often the photographs revealed that processing/holding tanks either
lacked adequate secondary containment or were totally uncontained. Figure 8
shows an example of uncontained holding tanks that have overflowed, spilling a
white substance that has clearly reached the nearby harbor waters. The light
sheen identified on the photograph did not originate from this facility but
was traced to a large storm drain located out of view of this photograph.
Small chemical packaging facilities commonly lacked secondary containment
features for both storage tanks and drums. Figures 9, 10, and 11 display
conditions typically found in small packaging operations in the areas surveyed
for this study. Spill stains can be seen around the storage tanks and drums,
none with secondary containment, at the small facility shown in Figure 9.
Standing pools of water (probably remnants of storm runoff) can be easily
differentiated from the nearby product spills; nevertheless, this water most
likely has been contaminated by the spilled substances. Likewise, the small
facility in Figure 10 has no visible means of containing any spills from the
-------
Figure 8. Spillage from processing/holding tanks.
25
-------
UNCONTAINED
TANJiS.
UNCONTAINED
DRUMS
Figure 9. Spill conditions at a small chemical packaging facility lacking secondary containment
structures for a number of storage tanks and drums.
UNCONTAINED TAJIKS
Ml
DRUM
STORAGE -
Figure 10. Uncontained tanks and drums at a chemical packaging facility.
26
-------
^^•ifcA at/ i
, \
M&-DRUfe
Figure 11. Spill conditions at a chemical packaging facility.
many tanks and drums located there. Any spill in the rear of the building
v/ould flow into the drainage ditch that leads to a nearby river. Spills from
the drums and loading dock on the right side of the building would likely flow
toward the front of the facility and enter the storm sewer system. (Note that
the spill from the loading dock (A) can be clearly traced to the storm drain
(B).)
Most of the storage tanks at the small chemical packaging plant in
Figure 11 have adequate secondary containment. However, none of the hundreds
of drums located at this facility has any visible secondary containment.
Heavy spill stains are visible in the drum storage area. The three largest
storage tanks are without secondary containment, and a large product spill
leads from the base of these tanks, past the entrance gate, and several
hundred feet into the public street.
Leaking and deteriorating storage tanks can readily be detected in aerial
photographs. Product overflow or leaks create a readily identifiable
-------
signature. Figure 12 provides an example of storage tanks stained by
overflowing product, probably through vents located at the top of the tanks.
Overflowing tanks in themselves are not necessarily a spill threat, except
when secondary containment structures are inadequate or absent. However,
stains suggest that the tanks have not been closely monitored during filling
operations or that the structural integrity of the tanks may be suspect.
Stains occurring below the top of a tank indicate the tank may be leaking out
of the seams; this may be the result of corrosion and deterioration from
wi thin.
Figure 13 is an example of adequately contained storage tanks. The dikes
appear to be high enough to contain the contents of most, if not all, of the
tanks within them. In addition, should a dike be breached or a drain valve be
accidently left open, any spillage would flow into the nearby waste settling
pond.
Although absence of drum containment has been cited in several previous
figures, examples of the consequences of inadequate drum containment are shown
in Figures 14 and 15. Figure 14 is a photograph of a large chemical packaging
facility with hundreds of drums stored throughout the facility without any
secondary containment. The drums, most of which are painted yellow with
others painted blue, white, and black, are the source of product spillage in
several instances. The spillage has mixed with standing pools of water at
several locations within the plant. A municipal drainage ditch, which leads
directly to a nearby harbor, bounds the facility on two sides. Stains at two
points near the ditch indicate spillage has entered the ditch. During periods
of heavy runoff from rainstorms, the standing pools of contaminated water
would also overflow into the ditch. As a result of an absence of secondary
containment for the drum storage areas, as well as for a majority of the
tanks, and an absence of surface drainage control, this facility poses a
significant spill threat to nearby navigable waters.
In the absence of secondary containment structures, drum storage areas can
pose a spill threat. An enlarged view of one of several drum storage areas in
a large industrial chemical production facility is shown in Figure 15. At two
points noted, surface runoff, transporting spillage, leads directly to a
drainage canal. In addition, these drums are stored on bare ground that has
been saturated from repeated spills and must be considered a potential threat
to ground water.
Most of the chemical production facilities photographed for this study had
stockpiles of dry product or raw materials. A majority of the dry product
storage areas were inadequately contained to prevent the substance from being
transported, either by direct overflow, surface runoff, or leaching, to nearby
natural drainage systems. Figure 16 is an example of a well-engineered raw
material (dry) storage facility. The hopper car rail siding shows no evidence
of spillage nor does the unloading facility where the cars are inverted. The
material is dumped from the cars onto conveyers beneath the facility and then
carried to the storage silos or to the stockpiles noted. The entire stockpile
area is recessed several feet below the level of the containment dike. Excess
water within the diked area is channeled through drainage ditches to the plant
waste treatment facilities.
28
-------
OVERFLOW
STAINS
Figure 12. Stained tanks caused by overflow leaks.
WASTE
SETTLING POND
Figure 13. Product storage tanks with adequate secondary containment dikes.
29
-------
Figure 14. Absence of drum containment and inadequate surface drainage control.
30
-------
Figure 15. Heavy product spillage in a drum storage yard.
HOPPER CAR
UNLOADING
FACILITY
Figure 16. Well-engineered dry material storage facilities.
31
-------
An enlarged view of a raw material stockpile at a titanium dioxide
production facility is shown in Figure 17. This stockpile also appears to be
adequately contained. There is no evidence of material spillage or leaching
of material beyond the containment wall.
Typical examples of inadequately contained dry product/raw material
stockpiles are shown in Figures 13, 19, and 20. The stockpile of yellow
substance in Figure 18 has containment on two sides but is uncontained on the
other side. At point (A), the material has entered or is entering the river.
This material is transported to a hopper on the roof of the plant via a
pipelike conveyer. (Note the fugitive dust scattered on the roof around the
hopper). During a rainfall, this dust (spillage) will be carried by runoff
either into the street or the river. Additional stains are found along the
riverbank where material has been spilled or dumped. Among these is a spill
stain which, leading from a small concrete drum storage pad (B), has reached
the river.
The wetlands bordering the facility in Figure 19 show severe vegetation
damage in areas where spillage from the stockpile of black material (possibly
coal) has escaped the containment dikes. The areas of heavy spillage are
totally void of vegetative growth. There are large pools of water standing
within the stockpile area, and seepage and overflow may be causes of the
spillage reaching the wetlands. The long incomplete containment wall appears
to have been constructed after the nearby spillage occurred. Nevertheless,
the vegetation damage remains.
An even more vivid demonstration of the consequences of inadequately
contained dry product storage can be seen in Figure 20. The containment wall
for this stockpile has been breached in three places causing extensive
vegetation damage in the foreground. Even the live vegetation noted does not
appear vigorous and healthy but is showing signs of stress. It is very likely
that leachate has migrated into the nearby river water.
Product Transfer Facilities
Analysis of the aerial photography revealed considerable product spillage,
generally in small amounts, and spill stains in and around product transfer
points. This was not unexpected since EMSL-LV's past experience in
reconnaissance of oil-related facilities revealed the same situation. Points
of product transfer are likely areas for spills to occur. In general, a
majority of the facilities viewed had few if any secondary containment or
recovery features, such as grated trenches, sumps, and so forth, which could
minimize the effects of a major spill.
The photography also revealed that railroad tank car racks are a much more
common occurrence than truck racks in the facilities studied. Very few large,
centrally located truck racks were detected, whereas in oil production,
refining, and storage facilities large truck racks are the norm. Tank trucks
were seen in most of the facilities, but points of transfer appeared to be
distributed throughout the facilities rather than centrally located.
32
-------
Figure 17. Dry material stockpiles at a titanium dioxide production plant.
Figure 18. Inadequately contained raw material stockpile at a small manufacturing facility.
33
-------
CO
-fj.
DAMAGED
VEGETATION
Figure 19. Inadequately contained raw material stockpiles at a large industrial chemical manufacturing facility.
-------
*"
UNCONTAINED^,
PROCESSING
CONTAINMENT WAL
OVERFLOW
SPILLAGE
DEAD
VEGETATION
Figure 20. Spill conditions associated with dry product storage.
Figure 21 is an example of a very large tank car facility with
well-engineered drainage control. Drainage ditches would carry any major
spill from the racks to the plant waste treatment facilities. Figure 22 shows
heavy product spillage and spill stains at the tank car racks of a large
organic chemical manufacturing plant. Spillage volume is inadequate to flow
beyond the racks; however, rainfall runoff would transport some of the spilled
product into drainage ditches that bypass the plant's waste treatment
facilities and empty into a nearby river.
35
-------
f > ^y
P-isTT-fr
•^rSHI
OJ
CTl
Figure 21. Example of clean, well-engineered tank car racks and rail sidings at a large chemical manufacturing plant.
-------
DRUMS
(NO CONTAINMENT)
Figure 22. Spill conditions at a chemical tank car rack.
Figure 23 shows several tank car racks and truck racks at a large
industrial chemical production complex. Spill stains and product spillage are
visible at several points. A major spill at these racks would likely flow
into the nearby drainage ditches. Unfortunately, as in the previous
photograph, the ditch bypasses a waste settling pond and enters a wetland area
bordering the plant.
In Figure 24, product spillage from the tank cars at this small chemical
packaging facility is quite heavy. Careful analysis of the photograph shows
these stains have reached the river water. Finally, the 10 vertical storage
tanks (red) and the drum storage area lack any visible means of secondary
containment.
Several marine terminals were photographed for this study. These
terminals are indistinguishable from typical oil barge and tanker terminals.
Figures 25 thru 27 are examples of typical conditions at marine terminals
servicing chemical facilities. Figure 25 is a vertical photograph of the
river terminal facilities of a large chemical production complex. Along with
barge and tanker docking facilities is the terminal for a large railroad tank
car barge (ferry). Figure 26 is a low-altitude oblique view of the same
terminal taken one day earlier. The wood plank deck of the barge dock offers
no containment should a hose or pipe burst during product transfer operations.
The heavy black stains noted on the dock surface are an indication of numerous
-------
co
00
Figure 23. Truck and rail tank car racks at a large industrial chemical production facility.
-------
VERTICAL
UNCONTAINEDfl TANKS
Figure 24. Heavy spill stains at the tank car terminal of a small chemical manufacturing facility.
39
-------
RAIL ROAD TANK CAR
BARGE (FERRY)
Figure 25. Marine terminal facilities at a large chemical manufacturing complex.
40
-------
AILROADTANK
CAR BARGE
Figure 26. Oblique view of the large marine terminal seen in Figure 25.
-------
Figure 27. Product transfer operations at a barge terminal.
product spills. Notice the subtle oily sheen beneath the stained dock. In
addition, the barge is only moored to the dock with bow and stem lines.
Additional crossed spring lines would reduce the chances of hose or pipe
rupture resulting from surge action caused by the passage of large vessels.
Figure 27 is an example of a smaller barge terminal facility. Any spill
occurring during product transfer operations would enter the river unhindered.
Booms have not been deployed around these barges as a precaution should a
spill occur, and none were stored close at hand for emergency response to a
spill. This was the case at all marine terminals photographed for this study.
An example of marine terminal facilities for offloading dry products/raw
materials at chemical processing plants is shown in Figure 28. At both of the
plants, heavy spillage of the white substance offloaded at the terminals has
coated much of the area. Rainfall has washed and will continue to wash much
42
-------
DISCHARGE FROM
SURFACE RUNOFF
RIVER
WASTE DISCHARGE
Figure 28. River terminal facilities for off-loading and storing dry product (raw materials) at
two large chemical manufacturing plants.
43
-------
of this spillage into the river. Note in particular the heavy spillage at the
ship terminal and the river bank of the facility at the top of Figure 28.
Waste. Treatment Facilities and Surface Drainage
Detailed interpretation of the aerial photography acquired over the
chemical production and storage facilities in the study area revealed that
waste treatment and surface drainage control varied widely from facility to
facility. The adequacy of waste treatment cannot be fully assessed from
aerial photography; nevertheless, certain deficiencies are readily apparent.
The total absence of waste treatment facilities, the presence of discolored or
turbid waste discharge plumes into adjacent natural drainage, and the presence
of damaged vegetation near points of waste discharge are often indicators of
potential deficiencies in waste treatment. Surface drainage within a facility
boundary should be interlinked with the waste treatment system so that
accidental spills and contaminated surface runoff can be blocked or treated
prior to discharge beyond the facility boundary.
Figure 29 is an example of visible waste treatment facilities at a
titanium dioxide production plant. All waste substances are channeled to the
settling pond to allow suspended materials to settle prior to discharge into
the river. Notwithstanding this treatment, waste substances are being
discharged into the river. (Note the color of the discharged water and the
clearly defined plume created by the discharge.)
An example of inadequate waste treatment can be seen in Figure 30. Four
waste water pipes are discharging effluent into a drainage ditch that empties
into the nearby river. Only the discharge at (A) has been treated; the others
bypass the settling pond. Drainage analysis also shows seepage from a solid
waste landfill that terminates in the river beyond the boundary of the
photograph. Also, spillage within the containment dike of the three large
tanks flows to a sump, through an open gate, and finally into the river. The
ditch leading from the sump is deeply eroded, suggesting a continuous and
prolonged flow has taken place. Surface runoff from heavy rainfall may be the
principal cause of the deep erosion (gullies); nevertheless, the runoff is
carrying the spilled product. Near the sump., an overhead pipeline, which
connects the river terminal with the main processing area, is leaking into the
drainage ditch. Note the brown stains on the pipes at (B).
Surface drainage at the organic chemical production facility shown in
Figure 31 has been engineered to bypass the large waste settling lagoons, at
least in the section of the facility photographed. As a result, surface
spills and rainfall runoff flow directly to the nearby creek. Spillage at (A)
flows to the sump (B) formed by a natural depression and the elevated roadway.
However, the sump overflows into a culvert under the road and ultimately to
the creek.
Figure 32 shows part of the extensive waste treatment facilities of a
large chemical manufacturing plant. Additional treatment facilities are
located beyond the edge of this photograph. This plant is bordered by a tidal
marshland in the foreground, and the photography reveals an extensive area of
dead and dying vegetation. The most likely cause is effluent from a drainage
44
-------
POINT OF DISCHARGE
Figure 29. Waste water treatment facility at a titanium dioxide production facility.
-------
LLSTA1N
WASJE'V^ttR
DISCHARGE
Figure 30. Waste water discharge at a small part of a large industrial chemical production
facility.
46
-------
- ; SPII^S U
V *\*
Figure 31. Surface drainage at an organic chemical production facility.
-------
4.-.
a
UNQdNTAINED TANKS (C)
Figure 32. Damaged vegetation from surface runoff at a large chemical plant.
-------
ditch leading from the plant. Figure 33 provides a closer view of the area
drained by the ditch. Product spill stains lead to the ditch network from a
large tank car rack (A), uncontained storage tanks at (B) and (C), an
uncontained drum storage area (D), and possibly a cooling facility (E).
The plant in Figure 34 also has extensive waste treatment facilities, but
much of the surface runoff is directed through ditches that bypass these
treatment facilities. These ditches drain a section of the plant that has
numerous spill stains and uncontained tanks and drums. Effluent in the
ditches passes through a separator, which presumably should draw off oil and
other floatable substances in the ditch. However, the turbid plume located at
the discharge point suggests that the separator is apparently ineffective for
soluble and suspended materials. Note also the damaged vegetation resulting
from spillage or dumping near the waste treatment facilities.
Liquid waste, spillage, and surface runoff in the large chemical
production facility in Figure 35 are collected by a network of canals and
ditches and emptied into a wetland area bordering the plant. This effluent
ultimately reaches a nearby river. An enlarged view of the center portion of
this plant (Figure 36) clearly shows that the canal bypasses a waste settling
pond. Note also that a boom has been deployed at one of the canal
intersections and has been effective in skimming off a considerable amount of
floating material.
Figure 37 is an enlarged photograph of an old chemical manufacturing plant
producing general and compounded products. Except for the deployment of two
surface containment booms at waste water discharge points, there are no
visible waste treatment facilities. The smaller boom has accumulated a small
amount of floating substance, which appears to be a white froth or foam, but
has not prevented the passing of the suspended materials in the effluent. In
contrast, note how well the second and larger boom has blocked the movement of
the turbid discharge. The turbid plume from this waste discharge can be
traced several hundred feet down river from this point.
The acrylic resins production facility shown in Figure 38 has no visible
waste treatment facilities. The waste water discharged from this plant
creates a large, visible plume that extends well into the river. A careful
analysis of this plume also revealed the presence of a very thin, oily sheen.
Drainage control at the small chemical packaging plant in Figure 39 is
inadequate to prevent any significant spill from reaching the nearby bay
waters. Spillage from the truck rack or loading dock would likely follow the
path defined by the flowing water, across the parking lot, into the storm
drain, and then to the bay.
Seepage from the waste dump at the fertilizer production facility in
Figure 40 has created a large oily sheen that extends as a plume several
hundred feet into the harbor waters. Standing spillage on the surface of this
dump/landfill site and leaching from the dump may both be contributing sources
of the plume.
49
U.S. GOVERNMENT PRINTING OFFICE: 1979—684-503
-------
on
O
TIDAL MARSH
Figure 33. Oblique enlargement of the facility shown in Figure 32.
-------
Figure 34. Waste treatment and drainage facilities at a large chemical processing plant.
-------
\ '
J _i \ - /
..,-.?*! i SETTLING
POND -
-- ;--*lll
-------
oo
Figure 36. An enlarged, oblique view of a section of the drainage system shown in Figure 35.
-------
(Jl
L .
CONTAINMENT
BOOMS
Figure 37. Untreated waste water discharged into river.
-------
UNCONTAINED TANKS
Figure 38. Waste discharge from an acrylic resins production facility.
55
-------
TANK CARS
COVERED
TRUCK RACK *
Figure 39. Inadequate drainage control at a chemical packaging facility.
56
-------
Figure 40. The waste dump at this facility is the source of the oil sheen extending over the
harbor waters.
Surface drainage at the large plant in Figure 41 has been engineered to
gather surface runoff and transport it directly to a nearby river. Product
spillage from several sources can be seen, some of which has entered the
drainage ditches. Analysis of the film over this plant showed no visible
waste treatment facilities. Rainfall runoff would most likely flush much of
the product spillage in this plant into the ditch system.
The tank farm and associated tank car racks at a large chemical
manufacturing facility located on very flat, poorly drained terrain is shown
in Figure 42. Any major spill would follow the drainage ditch system
annotated on the photograph. There are several locations within the facility
boundary where the path of spillage could be readily blocked or dammed if
equipment and materials were on hand. Upon exiting the facility boundary, the
ditch enters the natural drainage system. The large storage tank in the right
foreground has a high containment dike that would hold the capacity of the
tank. There is standing water in the dike that appears to be draining into
the natural drainage through the drain at (A) and into the facility ditch
network at (B). A potential spill situation is posed at this facility by the
open, untended drains and the absence of materials and equipment to contain or
prevent spillage from entering the natural drainage system.
57
-------
SURFACE
^ DRAINS
Figure 41. Engineered drainage gathering surface runoff and product spillage for eventual
discharge into a nearby river.
58
-------
WATER
Figure 42. Engineered drainage posing a threat to an adjacent creek.
59
-------
REFERENCES
1. Attaway, L. 0. Hazardous Material Spills, The National Problem. In:
Proceedings of the 1972 National Conference on Control of Hazardous
Material Spills, Houston, Texas, March 21-23, 1972. pp. 1-4.
2. Department of Transportation, United States Coast Guard. Polluting
Incidents In and Around U.S. Waters, Calendar Year 1972. Washington,
D.C. p. 3.
3. Department of Transportation, United States Coast Guard. Polluting
Incidents In and Around U.S. Waters, Calendar Year 1976. CG-487,
Washington, D.C. p. 8.
4. Moen, G. J. Magnitude of the Chemical Spill Problem, A Regional View.
In: Proceedings of the 1978 National Conference on Control of Hazardous
Material Spills, Miami Beach, Florida, April 11-13, 1978. pp. 4-8.
5. U.S. Environmental Protection Agency. Digest of EPA's Monitoring-Related
Statutory Authority. Office of Monitoring Systems, Office of Research
and Development, Washington, D.C., USGPO, 1974. 79 pp.
6. Lewis, J. L. and A. R. Tarsey. EPA's Hazardous Spill Control
Regulations. In: Proceedings of the 1978 National Conference on Control
of Hazardous Material Spills, Miami Beach, Florida, April 11-13, 1978.
pp. 1-3.
7. U.S. Environmental Protection Agency. Oil Pollution Prevention,
Non-Transportation-Related Onshore and Offshore Facilities. Federal
Register, V. 38, No. 237, Part II, December 11, 1973. pp. 34163-34170.
8. Welch, R. I., A. D. Marmel stein, P. M. Maughan. An Aerial Surveillance
Spill Prevention System. In: Proceedings of the 1972 National
Conference on Control of Hazardous Material Spills, Houston, Texas,
March 21-23, 1972. pp. 137-140.
9. Rudder, C. L., et al. Aerial Spill Detection Key, Petroleum Refineries.
Unpublished report for the Office of Research Monitoring, Environmental
Protection Agency, Washington, D.C., by McDonnel Douglas Corporation,
October, 1972. 146 pp.
60
-------
10. Rudder, C. L. and 0. Jones. Environmental Imagery Keys for Hazardous
Materials Detection. In: Proceedings of the 1974 National Conference on
Control of Hazardous Material Spills, San Francisco, California, August
1974. pp. 287-291.
11. Jones, D., R. Landers, and A. Pressman. Aerial Photographic Applications
in Support of Oil Spill Cleanup, Control, and Prevention. In:
Proceedings of the 1977 Oil Spill Conference, American Petroleum
Institute, New Orleans, Louisiana, March, 1977. pp. 221-222.
12. Duggan, J. Application of Remote Sensing for Oil Spill Prevention,
Control, and Countermeasures Compliance Monitoring. Unpublished report
presented to the American Society of Photogrammetry, Fall Technical
Meeting, Little Rock, Arkansas, October, 1977.
13. Charleton, T. J., et al. Relating Handling of Hazardous Materials to
Spill Prevention. In: Proceedings of the 1978 National Conference on
Control of Hazardous Material Spills, Miami Beach, Florida, April 11-13,
1978. p. 32.
14. Amson, J. E., and J. L. Goodier. An Analysis of the Economic Impact of
Spill Prevention Costs on the Chemical Industry. In: Proceedings of the
1978 National Conference on Control of Hazardous Material Spills, Miami
Beach, Florida, April 11-13, 1978. pp. 39-45.
Glatty, J. E. Spill Control and Contingency Response Plan. In:
Proceedings of the 1978 National Conference on Control of Hazardous
Material Spills, Miami Beach, Florida, April 11-13, 1978. pp. 13-1?
16. Goodier, J. L. Aerial Observation of Potential Oil and Chemical Spill
Sources. Unpublished report, Arthur D. Little, Inc., Cambridge,
Massachusetts, August 1976.
61
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-600/4-79-027
2.
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
AERIAL RECONNAISSANCE OF HAZARDOUS SUBSTANCES
SPILLS AND SPILL-THREAT CONDITIONS
5. REPORT DATE
April 1979
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
H. V. Johnson
8. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Lockheed Electronics Company, Inc.
Remote Sensing Laboratory
Las Vegas, Nevada 89114
10. PROGRAM ELEMENT NO.
2BD 144
11. CONTRACT/GRANT NO.
EPA 68-03-2636
12. SPONSORING AGENCY NAME AND ADDRESS
U.S. Environmental Protection Agency--Las Vegas, NV
Office of Research and Development
Environmental Monitoring and Support Laboratory
Las Vegas, Nevada 89114
13. TYPE OF REPORT AND PERIOD COVERED
Final Project Report
14. SPONSORING AGENCY CODE
EPA/600/07
15. SUPPLEMENTARY NOTES
Clay Lake, Project Officer, Remote Sensing Division,
Support Laboratory, Las Vegas, Nevada 89114
Environmental Monitoring and
16. ABSTRACT
to
The U.S. Environmental Protection Agency's Environmental Monitoring and Support
Laboratory in Las Vegas, Nevada, conducted aerial reconnaissance over a number of
industrial facilities engaged in the production, storage, and handling of hazardous
substances that are located near navigable waters of the United States. The purpose of
this project was to demonstrate that aerial reconnaissance procedures currently
utilized in monitoring oil production, refining, and storage facilities can be applied
to monitoring chemical production and storage facilities to show whether spills and
spill-threat conditions exist within chemical production and storage facilities, and
provide annotated photographic examples of spill conditions. Typical in-plant
facilities covered in this reconnaissance include: (1) product storage facilities,
including storage and holding tanks, drum storage and staging areas, and dry-product
stockpiles; (2) product transfer facilities, such as marine and river terminals, and
tank car and truck loading racks; and (3) plant drainage and wastewater treatment
facilities.' The photographic examples can serve as photo interpretation keys to aid
both experienced remote sensing specialists and inexperienced personnel in monitoring
chemical facilities for compliance with anticipated spill prevention regulations to be
issued under authority of the Federal Water Pollution Control Act (FWPCA) as amended in
1977.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COS AT I Field/Group
Aerial Surveys
Hazardous Materials
Environmental Monitoring
Aerial Reconnaissance
Remote Sensing
Aerial Photography
Aerial Cameras
Photo Interpretation
Spill-Threat Conditions
Chemical Facilities
Shipping Terminal
Hazardous Substance
Storage
Phntn Tntprprptatinn
D I TV ^ I1 A ^c» /I— - —
13C,D,F,H
68A,C,D,E
70A
82 B
18. DISTRIBUTION STATEMENT
RELEASE TO PUBLIC
19. SECURITY CL'ASS (This Report)
UNCLASSIFIED
21. NO. OF PAGES
76
20. SECURITY CLASS (Thispage)
UNCLASSIFIED
22. PRICE
A05
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION is OBSOLETE
------- |