WATER POLLUTION CONTROL
OIL AND HAZARDOUS MATERIALS PROGRAM SERIES OHM 72 os 002
Regulations, Practices and Plans for
the Prevention of Spills of Oil and
Hazardous Polluting Substances
VOLUME I
ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF WATER PROGRAMS
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REGULATIONS, PRACTICES AND PLANS
FOR THE PREVENTION OF SPILLS OF OIL AND
HAZARDOUS POLLUTING SUBSTANCES
VOLUME I
October 1971
Prepared By
A. E. Wechsler
J. I. Stevens
P. A. Huska
Arthur D, Little, Inc.
Cambridge, Massachusetts 02140
Under Contract 14-12-950
for
Division of Oil and Hazardous Materials
Office of Water Programs
Environmental Protection Agency
For sale by the Superintendent ol Documents, U.S. Government Printing Office
Washington, O.C. 20402 - Price $1.75
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EPA Review Notice
This report has been reviewed by the Office of
Water Programs, EPA, and approved for publication.
Approval does not signify that the contents
necessarily reflect the views and policies of
the Environmental Protection Agency, nor does
mention of trade names or commercial products
constitute endorsement or recommendation for
use.
ii
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FOREWORD
The enactment of the Water Quality Improvement Act of 1970 provided
the necessary legislative force required to set in motion a vehicle
designed to eliminate accicle'nti&JL spiels of -oil and. hazardous materials
through prevention. This study waif designed to provide a basic working
knowledge and understanding of existing rules and regulations, design con-
cepts and operating practices in spill prevention to satisfy basic require-
ments set forth in Section ll(j)(l)(C) and 12(G) of the Act.
The main elements of this study are intended to complement an earlier
study entitled, "Spill Prevention Techniques for Hazardous Polluting
Substances" under EPA Contract 14-12-927 and published by the Water
Quality Office, February 1971. This related report, "Regulations, Practices
and Plans for the Prevention of Spills of Oil and Hazardous Polluting
Substances," Volumes I and II, represents the results of a three-phase study
effort to: (1) review Federal, State, local, commercial and industrial rules,
regulations, standards and recommended practices to prevent the spills of oil
and hazardous polluting substances, (2) survey selected facilities and plants
in the field to document the state of the art in spill prevention technology
and critically evaluate the "cause and effect" relationship of spill preven-
tion technology to rules, regulations, and standards, (3) prepare a program
plan (prototype plan) that proposes a balanced Federal, State, local and
industry spill prevention program. Volume I presents the results of Phases 1
and 2; Volume II gives a summary of the program and presents the program plan.
In addition, this study shows that spill prevention for oil and hazardous
polluting substances is practiced mainly as a result of fire and safety codes.
There are, in fact, very few spill prevention programs for environmental
protection at the Federal, State and local levels of government. The data
documented in this study and the prototype plan could be used as a basis for
identifying problems associated with spill prevention.
It is hoped that this will provide the necessary direction and guidance
for all levels of government and industry to proceed with the development and
implementation of a balanced spill prevention program.
H. D. Van Cleave
Project Officer
Division of Oil & Hazardous Materials
Office of Water Programs
Environmental Protection Agency
iii
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TABLE OF CONTENTS
Page
List of Tables vi
I. SUMMARY 1
II. INTRODUCTION 9
A. Background 9
B. The Spill Prevention Problem 10
C. Approach 12
III. LAWS AND REGULATIONS FOR SPILL PREVENTION 17
A. Federal Regulatory Practice 17
B. State and Regional Regulatory Literature 22
C. Fire Laws and Fire Prevention and Underwriter Codes 30
IV. TECHNICAL AND TRADE LITERATURE 31
A. Causes of Spills 31
B. Equipment, Design Criteria and Procedures
for Spill Prevention 35
C. Industrial Utilization of Spill Prevention
and Control Techniques 47
V. FIELD SURVEY 49
A. Methodology 49
B. Survey Results 51
C. Comparison with Other Surveys 68
VI. ACKNOWLEDGMENTS 73
VII. REFERENCES 75
VIII. APPENDICES 77
v
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LIST OF TABLES
No.
1 Matrix for Contrasting and Ranking the Main
Functions or Areas in Liquid Handling Facilities 13
2 United States Geological Survey—Outer Continental
Shelf Regulations 21
3 Types of State Water Pollution Regulations 23
4 Specific State Spill Prevention, Rules, Regulations
and Laws 24
5 Sources Used in Literature Survey 32
6 Types, Causes and Remedies for Chemical Spills 33
7 Types, Causes and Remedies for Oil Spills 36
8 Hazard Factors in Chemical Plants 37
9 Professional Groups Establishing Equipment and
Fabrication Standards Pertinent to Spill Prevention . 40
10 Typical Publications on Handling Flammable and
Hazardous Materials 41
11 Case Study Examples of Procedures for Overcoming
Oil Pollution " 43
12 Typical Check List for Process Examination 44
13 Check List for Heater, Common Transport and
Storage Operations 46
14 Facilities, Agencies and Organizations Visited in ,
Field Survey 50
15 Summary of Spill Prevention Practices
in Storage Areas -53
16 Summary of Spill Prevention Practices
in Transfer Areas 57
17 Summary of Spill Prevention Practices Used
in Loading and Unloading Areas 50
18 Summary of Spill Prevention Practices Used in
Process Areas 53
19 Waste Treatment Practices Which Aid Pnin
prevention * /--^
20 Summary of Spill Prevention and Control
Practices at 107 Facilities 70
vi
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I. SUMMARY
PURPOSE AND SCOPE
The purpose of this program was to assess the state of the art of
technology for the prevention, detection and control of spills of oil and
other hazardous materials. More specifically, the goals were to:
• review and analyze "fail-safe" practices—regulations,
design concepts and criteria, equipment and operational
procedures used to prevent, detect or control spills or
leaks of oil and hazardous materials;
• determine the level of utilization of these practices in
industrial facilities and distribution systems;
• prepare a prototype plan for use in developing federal,
state and local regulations, policies and programs pertain-
ing to the prevention, detection and control of spills of
oil and hazardous materials.
We focused attention on prevention of accidental spills because pre-
vention is the first line of defense against environmental damage and
strongly influences the requirements for detection and control. Emphasis
was placed on methods for preventing spills of oil, other hydrocarbons
and hazardous chemicals at refineries, terminals, storage, distribution,
petrochemical, rubber, plastics, chemical and metal products facilities.
Prevention, detection and control practices in off-shore and on-shore oil
production were given only limited study because of their rather special-
ized technology.
APPROACH
To accomplish the program objectives, we undertook three tasks:
(1) a literature survey, (2) a field survey of industrial facilities com-
bined with discussions with industrial environmental managers and staff
members of federal, state, and local regulatory agencies as well as
designers/architects/engineers of industrial facilities, and (3) an analysis
of the information gained and synthesis of a prototype plan.
We reviewed the laws, regulations and operating orders of federal
agencies, such as the Environmental Protection Agency, Department of
Transportation, Department of Interior, Corps of Engineers; the environ-
mental and health agencies of about 40 states; and several metropolitan
districts. We reviewed the recent technical literature, concentrating on
those journals which represent the petroleum and chemical industries and
environmental and waste treatment technologies. We reviewed the publica-
tions of trade, safety, fire protection and insurance associations, and
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examined industry and government agency reports of spills. We also
examined a cross section of manufacturers' literature on spill prevention,
detection and control.
Our field surveys were conducted in four geographic locations:
Houston, Texas; California; the New York-New Jersey metropolitan area; and
the Illinois-Michigan area. We visited 23 operating facilities representing
petroleum refineries, bulk storage and distribution, petrochemical, chemical,
synthetic rubber, plastics and metal products industries to determine^the
level of spill prevention currently practiced. Many of those facilities
combined refineries, terminals, or several types of chemical processing and
materials handling methods. We discussed the present use of prevention,
detection and control techniques, procedures and equipment with plant
managers and pollution control staff, and requested information on future
needs of industry. We discussed regulatory practice and the state of the
art of prevention during visits with eight state, federal and/or local
regulatory agencies. We visited five architect-engineering firms res-
ponsible for the design and construction of new industrial facilities to
determine the spill prevention measures which they presently incorporate
in new facilities.
We examined and analysed the information derived from the litera-
ture and field visits, and summarized the prevention technology applicable
to five major "unit operations" encountered in industrial facilities—
storage, transport, loading and unloading, processing, and waste treatment
of oil and hazardous polluting materials. We compared our results with
previous surveys at different locations. From this state-of-the-art summary,
we developed a prototype plan which considers possible spill prevention
regulations, penalties and incentives; development of an integrated pre-
vention program; educational programs; and future equipment needs for
prevention, detection and control.
RESULTS AND CONCLUSIONS
Regulatory Literature
• Present federal regulations are directed at establishing water
quality and prohibiting spills of oil into the public waterways;
• The federal government has the mandate to study, encourage, and
establish methods for prevention of spills, but, with a few
exceptions, existing regulations provide little guidance or
detailed information on prevention practices.
• The prevention of spills during offshore oil production is
specifically addressed by the Department of Interior, U.S.
Geological Survey Operating Orders in which detailed prevention
practices are described.
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• The water quality regulations of the states vary considerably
in scope and content: emphasis is placed on water quality
standards and municipal treatment programs, not on industrial
waste treatment.
A majority of the states have regulations which provide for issuing
permits, determining compliance and revoking permits for both municipal
and industrial waste treatment facilities; one third of the states have
specific regulations pertaining to prevention spills of oil; less than
half of these also address spills of hazardous polluting materials.
• The major oil production states have specific .regulations con-
cerning the prevention of oil spills during production and
transport to processing facilities.
• Several states have recognized the potential for pollution by
oil and hazardous materials during transport and at terminal
operations and have provided guidelines or detailed specific
spill prevention procedures.
Trade and Technical Literature
* The principal causes of spills of oil and hazardous materials
during fluid handling are human error, operational failures and
equipment failures.
• Most of the technical literature on spill prevention is directed
at the prevention of hazards to personnel and property by fire,
explosion and toxic effects—protection of the environment is
discussed infrequently.
• Industrial codes and standards adequately address problems of
fire and design of equipment against mechanical failures; spill
prevention is not specifically addressed, but most of the
practices described in these codes and standards are valuable
adjuncts to spill prevention.
• Although complete descriptive literature data on "fail-safe"
equipment for spill prevention and instrumentation for spill
detection is sparse, the trade literature of manufacturers
indicate that an adequate number of devices are commercially
available.
Field ^urvey
General Observations
• The most sophisticated prevention, detection and control tech-
nology is applied to those substances most hazardous to people,
most damaging to property, or of high commercial value.
• The best developed containment, monitoring and treatment facili-
ties are usually installed at facilities where the consequence
of uncontrolled spills and leaks would be immediately evident
through such visual indicators as floating substances, massive
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fish kills, etc. The major attention has been given to oil,
because it is the largest volume handled in commerce and is
easily detected when spilled. _ _ _
Highly automated processing plants may have a significant poten
tial for spills or leaks of hazardous polluting substances
because the reduced number of operating personnel does not permit
visual observations throughout the facility and because even the
most sophisticated control systems are incapable of detecting
small leaks and spills which can be extremely hazardous if
allowed to enter the water.
Very little instrumentation is installed solely for the detection
of spilled substances; process instrumentation used in the trans
fer, storage and processing of hazardous polluting substances is
applicable to detecting large spills but of doubtful value in
detecting spills such as from small leaks.
Catastrophic occurrences with a high potential for large volume
spills, such as a tank rupture, receive the most public^atten-
tion and consequently greatest consideration of prevention;
chronic leaks and small spills which enter water probably have
a greater accumulative effect but are given less attention at
facilities.
Separating areas of high spill potential and using collecting
sewers and ditches that lead to containment areas where spilled
substances can be monitored, treated and recovered is the most
effective means of preventing hazardous polluting substances from
entering water courses.
Passive barriers for preventing the flow of spilled liquids are
a highly desirable method of containment; however, containment
dikes surrounding liquid storage tanks can often be breached or
overflowed when a catastrophic failure occurs.
Little consideration has been given to the possibility of ground
water pollution as the result of leaks and spills; however,
designs of modern facilities are giving this more consideration.
Wide variations exist in the maintenance, housekeeping and opera-
tional practices of facilities handling similar types and volumes
of hazardous polluting substances; therefore there is a broad
range of spill incidences and prevention measures.
Causes of Spills
Facility operators consider poor housekeeping practices and
failure of operating personnel to perform their assigned jobs
to be the principal causes of spills.
Although equipment failures are known and documented causes of
spills, they are probably less significant and more easily
corrected and prevented than failures of operating personnel to
perform satisfactorily.
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• The potential for spills of hazardous polluting substances
increases when facilities are being renovated or when repairs
are being made.
• Loading and unloading operations have the highest spill potential
because of the temporary nature of the connections between trans-
port vehicles and transfer equipment and the large volumes of
fluids transferred. The weakest points in transfer systems (pipe-
lines) are at connectors, flanges, joints, valves, pumps and
instrumentation inlets.
• Operating personnel generally have little awareness of the poten-
tial hazardousness of many substances when introduced into the
water environment. ' Little attention has been given to the role
of some actions, such as fire fighting in transporting spilled
substances into water courses.
Specific Prevention Practices Used
The following specific prevention, detection, and control practices
were observed most often in this field survey.
Practice
Dikes, fire walls or barriers around
tanks
Monitoring of waste system effluent
to aid in spill detection
Hard surfaces or surfaces sloped and
graded toward ditches or drainage
system
Curbing, gutters or drainage ditches
around tanks or areas
Separate process and storm water
sewers
Holding or diversion ponds or
lagoons
Specific procedure for diverting
or treating initial rainfall
Periodic inspection of all pipe-
lines for leaks, combined with
preventive maintenance
All pipelines located above
grade to facilitate inspection
Collection sumps and oil separators
at each area
Manual gauging of tanks at regular
intervals
Swivel joint loading arms or rigid
connectors
Area
Storage
Waste treatment
Process
Loading and unloading
Storage
Loading and unloading
Process
Storage
Waste treatment
Process
Storage
Waste treatment
Waste treatment
Transfer
Transfer
Loading and unloading
Process
Storage
Loading and unloading
Observed at
% of
Facilities
91
52
52
30
30
48
48
30
48
30
26
43
35
35
35
35
26
30
30
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Several of the facilities visited have established management practices
to aid spill prevention. These included: employee motivation programs,
placing responsibility for spills on individual operators, pollution contro
education programs, spill emergency reporting and specific training pro-
grams emphasizing pollution control.
In comparing the results of the present survey to similar surveys
at other locations, we found the following prevention practices most
commonly used:
% UTILIZATION OF PREVENTION PRACTICES
This rnrnpnsite Survey ,.
Practices Survey Chemical Facilities Total Facilities
(Number of Facilities) (23) (31) LLSLD
Complete Diked Storage 52 42 44
Tank Level Alarms 9 16 8
Above Ground Transfer Lines 35 23 H
Curbed Process Areas 48 52 22
Process Area Catch Basins 26 16 13
Holding Lagoons 43 42 17
Primary Waste Treatment 52 55 31
Secondary Waste Treatment 9 16 6
Spill Cleanup Equipment 13 3 16
Preventive Maintenance Program 35 33 18
Spill Control Plan 60 6.1 39
Prototype Plan
The prototype plan (Volume II) consists of a series of recommended
actions to raise the level of spill prevention- throughout government and
industry. Some of the most important recommendations are:
• Oil and hazardous polluting substances should be placed on the
same federal regulatory basis in terms of spill definition, pro-
hibiting spills, spill prevention measures, penalties and
incentives.
• States should be encouraged to evaluate, standardize and expand
their regulations and procedures for prevention of oil spills as
well as other hazardous materials to be commensurate with
federal regulations.
• Facility operators should be required, as part of their waste
discharge permit applications, to submit plans for preventing
and controlling spills in accordance with federal and state
regulations.
• Existing codes and regulations covering fire protection, pressure
vessels, and pipelines should be expanded to include provisions
for the prevention of spills of oil and hazardous materials.
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Fire, safety, building, and air pollution regulatory groups
should be encouraged to assist in water pollution prevention.
An educational program on spill prevention, detection and control
using several levels of communication media should be instituted
by government and industry—specific emphasis should be placed
on the individual's contributions to prevention, and in placing
environmental protection at the same level as safety.
Government and industry should cooperatively conduct demonstra-
tions of integrated spill prevention programs designed to
develop the required methodology and data and to show how best
to implement spill prevention. These programs should include:
assessment of hazards; establishment of short and long range
levels of spill prevention; evaluation of existing prevention,
detection and control technology; development and implementation
of additional required prevention measures; establishment of a
continuous program of quality control for spill prevention;
documentation and evaluation of the effectiveness of the program.
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II. INTRODUCTION
A. BACKGROUND
During the past several years, concern over water quality has been
strongly aroused by major pollution incidents and by a growing awareness
of the insidious environmental effects of the smaller leaks and spills
of oil and other hazardous materials that occur daily on the land and in
the water.
In response to this concern, government, industry and public groups
have proposed and conducted a number of programs aimed at controlling
spills of hazardous materials and at cleanup or recovery procedures.
The Environmental Protection Agency, the U. S. Coast Guard and some state
agencies are conducting broad programs to develop methods and equipment
that will eliminate or confine hazardous materials should these be re-
leased into the water. The petroleum companies, both individually and
collectively, are developing methods of cleaning oil from the water.
Other industrial organizations have sought means to identify spills,
control them, and clean them up. Public interest groups have contributed
through their exposition of environmental damage and their attempts to
assure passage of pollution control legislation.
Unfortunately, few of these efforts have been directed at the most
promising solution to the problem—stopping pollution at the source
through adequate spill prevention measures. Prevention makes both
economic and environmental sense. Cleaning up the pollutant during the
Santa Barbara incident, for example, may have cost as much as $5 million.
In the recent Shell fire, pollution and well damage reportedly added up
to more than $15 million. Of course, prevention of pollution equates to
prevention of environmental damage.
If we are to develop an effective means of preventing spills of oil
or other hazardous material, we need first to understand the nature and
causes of such spills. Why do they occur? Where? What kinds? How
big? Some of this information is already at hand; for example, a review
of both state and federal reports suggests there are four major causes
of spills: (1) human error, generally considered the greatest single
cause of pollution incidents; (2) inadequate operational procedures or
handling of hazardous materials; (3) poorly designed, inadequate, non-
existent, or faulty equipment; and (4) acts of nature. Data on other
aspects of spill causes and nature have been reported by Battelle
Memorial Institutef^, Arthur D. Little, Inc.[2] and Dillingham.[3]
Much data remain to be gathered or developed. Once these data have
been translated into methods and equipment, the equipment must be in-
stalled and the methods must be applied. Systems must be human engineered
to make them easy to operate. An on-going educational process must be
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instituted to make sure operators know how and why to use equipment
properly. A system of checks must be maintained to monitor operational
procedures. Regulations and construction codes must be drawn up and
enforced. A device will not be useful unless it is used; an alarm will
not be effective unless it is heeded.
B. THE SPILL PREVENTION PROBLEM
Spill prevention is primarily a materials handling problem of storing,
transferring, or processing liquids. Even when the potentially hazardous
substance is a solid it must often be handled in solution form or brought
into solution through contact with the water environment.
Although the greatest number of widely publicized spills have occurred
in the transportation phase of the petroleum industry, we have addressed
problems of spills of hazardous polluting substances as well as oil at
industrial sites for several reasons:
1. Spills of hazardous substances have been given much less
attention than spills of petroleum products, probably
because of their lower visibility and volume.
2. The spill potentials and problems of the transportation
industry have been approached in detail through the devel-
opment of codes and regulations, especially from the view
of personnel and property hazards.
3. Industrial facilities are less uniformly regulated than
transportation; a greater diversity of practices and systems
are needed for the prevention, detection and control of
spills.
In industrial operations handling or processing liquids which become
hazardous polluting substances upon entry into the water environment, a
number of practices and systems are found for the prevention, detection
and control of spills or leaks. Many of these were installed for rea-
sons other than environmental pollution—e.g.
• Personnel protection
• Property protection
• Compliance with fire and safety codes
• Preventing product loss because of its dollar value
Furthermore, each industrial facility, by virtue of its geographical,
topographical and climatological characteristics will have some unique
facets which will lead to unique spill prevention techniques not appli-
cable at similar plants at different locations. The process industries
have developed spill prevention techniques with varying degrees of
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sophistication, depending upon the specific materials handled, plant
locations, and process requirements. Nevertheless, any useful appli-
cation of technology to prevent, detect, and control spills must be
based on broad principles of equipment design and operating procedures
and practices.
1. Spill Areas
The handling and processing of liquids are difficult to categorize
precisely for the purposes of establishing designs and developing pro-
cedures for preventing or controlling spills. However, we believe
that four main areas of plant operations can be considered:
• Storage
* Transfer
• Loading and unloading
• Processing
These are characterized in this report as follows:
The Storage area is, virtually without exception, where the
greatest volumetric containment of liquid occurs. It is the area which
performs the prime function of providing for the reoccurring high
volume movement of liquids between plant and transport, as contrasted to
continuous and comparatively low volume flow of liquid to and from
processing areas. In the storage area, spills are more frequently of
large volume due to operational inattention or catastrophic failure and,
as a consequence, are more damaging upon entry into water courses.
The Transfer area of a liquid handling facility comprises pipe-
lines and the associated pumps, valves, and controls required in the
transfer function. Spills are almost always the result of equipment
failures in unattended areas. In this report, we refer to transfer
area as pipelines or conduits through which liquids flow. Making con-
nections with and discharging into tanks and permanent or temporary
storage facilities is considered to occur in the loading and unloading
area.
The Loading and Unloading area may be thought of as the interface
through which incoming raw materials and outgoing products pass. This
area is often the terminus of transfer pipelines which connect to raw
material and product storage tanks. As a consequence, large volumes of
liquids must be routed and the many temporary connections required in the
operation is a major problem.
A Processing area consists of equipment and facilities in which
raw materials are converted into products. In this area the major spill
problems are associated with the innumerable pumps, valves, instruments
and equipment failures associated with the physical and chemical changes
being carried out.
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Another area for spills is the waste treatment area. However, a
waste treatment facility is often a means for preventing spills in other
locations from reaching the water resources.
2. Spill Potentials
The potential and magnitude of spills and leaks from the major areas
discussed above is dependent upon a number of variables and these can-
not be generalized easily. However, there appear to be five major factors
contributing to the quantitative description of spill potential. (See
Table 1.) First is the inventory volume of liquid since the larger the
volume, the greater the potential hazards to a water environment from
a spill. A very low spill potential exists because of inventory effects
in a loading and unloading area while a very high potential exists in
the storage area.
The second descriptor of spill potential is the frequency of
operating cycles. Significantly greater potential exists at the beginning
and ending of operational cycles due to a variety of reasons including
mechanical ones such as the danger of loose connections, and operational
ones such as unsteady state conditions. A third descriptor of great
importance in loading and unloading areas is the high ratio of temporary
to permanent connections. Each time a pipeline is connected or discon-
nected, the potential exists for improper pipe fit, and for damage and
wear to the pipe connectors. In contrast, since a permanent connection
is made only once and often hydraulically tested before use, the low
ratio of temporary to permanent connectors gives the transfer,airea of ,a
plant a low potential for spills., , . '
The volumetric rate at which liquids are moved to and from storage
and processing areas can cause a high spill potential to exist, e.g.,
in the unloading of supertankers where transfer rates of 10,000 to 20,000
tons per hour may occur. Obviously, a pipeline break which is not
quickly detected can result in spilling large volumes of liquids. The
ubiquitous human factor in spills must be considered a very important
descriptor of spill potentials. The greater dependence upon the human
factor in general, the higher the spill potential. An overall ranking
of the spill potential of the four areas suggests that loading and un-
loading and storage areas represent the highest spill potential, followed
by processing and transfer operations.
C. APPROACH
Our investigation consisted of three parts—survey and analysis
of the regulatory, trade, and technical literature; field survey and
cvalaa.t. -t c± trlfe state cf the art of spill prevention, detection and
i-^.itt;:! ;fccrmoiogy; auu anaL>,.u and development of a prototype plan
describing fu«:v_s .-arses of action for the ^uviionmental Protection
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TABLE 1
MATRIX FOR CONTRASTING AND RANKING THE MAIN FUNCTIONS
OR AREAS IN LIQUID HANDLING FACILITIES
Inventory of
Contained Liquid
Frequency of
Operating Cycles
Ratio:
Temporary Con-
nections
Permanent Con-
nections
Loading &
Storage Transfer Unloading Processing
Very High Low
Very Low Low
Low
Moderate Very High Moderate
Very Low Very Low Very High Moderate
Dependence Upon
Human Factor-
Volumetric
Transfer Rate
Overall Spill
Potential
High
Low
High
Low
High
Very High High
High
Moderate High
Variable
Moderate
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Agency to further the "spill prevention" concept. We focused on acci-
dental spills and leaks of oil and other hazardous materials from large
and small industrial facilities. Only modest attention was paid to off-
shore and onshore petroleum production because these areas are so large
and complex, and have a separate technology base, that they are beyond
the scope of our present work.
We examined federal regulatory literature and the rules and orders
of agencies such as the Environmental Protection Agency, U. S. Coast
Guard, U. S. Geological Survey, Maritime Administration, and the Corps
of Engineers. Letters were written to over 30 state pollution control
and health agencies requesting information on rules, regulations and orders
pertaining to prevention of spills of oil and other hazardous materials.
Fire marshalls of several states and municipalities were contacted. We
reviewed the existing regulations to determine which provisions addressed
spill prevention—design criteria, "fail-safe" equipment, and procedures.
This survey was complemented by personal visits and telephone contact with
several state agencies.
We briefly examined the causes of spills reported in the literature,
the corrective actions taken, and preventive measures which might
eliminate these potential hazards in other facilities. Our attention
was focused on chronic spills of oil and hazardous materials at indus-
trial facilities because many reviews presented at oil pollution control
conferences and reports in the open literature have discussed the major
oil spills.[41 [51
Our review of the technical and trade literature was limited to
the last several years' publications. We examined publications of trade
associations such as the American Petroleum Institute and Manufacturing
Chemists Association; trade and technical journals such as the Oil and
Gas Journal, Journal of Waste Water Treatment, and Chemical Engineering;
and abstract indices such as Chemical Abstracts and Index to Government
Reports. Although much literature was available from manufacturers, most
of it described oil detectors, valves, level indicators, alarms, etc.
We did not feel that an extensive review of such equipment was warranted—
more important is the general knowledge that these devices are available
on the open market.
In our field survey, we visited 23 large and small facilities in
the petroleum refining, oil storage and distribution, petrochemical,
organic and inorganic chemical, plastics and rubber, and metal products
industries. (See Table 14.) The survey was conducted in four locations
Houston, Texas; Los Angeles and San Francisco, California; the New York-
New Jersey area; and the Illinois-Michigan area—representative of the variety
of geographical climatological, and industrial ranges encountered in the
United States. Visits to these facilities were arranged through the
Regional Offices of the Environnental Protection Agency, State Pollution
Control Agencies, and our own personal contacts in industry.
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The objective of these visits was to obtain information about the
level of spill prevention technology actually practiced in industrial
facilities and information about how spill prevention techniques might
be improved or further developed. Information exchange was facilitated
by our agreement with industrial representatives not to "single out" by
name specific organizations with limited or inadequate prevention pro-
grams, nor to disclose past problems with spills or present hazards, but
to focus on existing prevention techniques and how industry and government
can cooperate to improve the present situation.
Field surveys at working facilities were supplemented by visits
to five architect-engineering firms active in the design, development
and construction of industrial facilities. (See Table 14.) These dis-
cussions helped to identify the types of design criteria and equipment
for spill prevention that are used in new plant construction. We also
visited with several state and municipal water pollution control
agencies to determine their view of present pollution prevention practices,
The information gained from these visits was reviewed and summarized in
terms of the design criteria, equipment, operational procedures, and
practices used to prevent spills in the storage, transfer, loading and
unloading, processing, and waste treatment of oil and hazardous materials.
The last part of our program was the preparation of a prototype plan
for Environmental Protection Agency action. Several approaches were
considered—development and promulgation of new rules and regulations,
methods for determining the hazards and spill prevention requirements
of specific industries; educational programs for industry management and
operational personnel; spill prevention demonstration programs; and
determination and development of additional equipment required for spill
prevention. It was clear from our visits to industrial facilities that
a broad range of spill prevention technologies is being practiced
depending upon the type, size, age, and location of the facility as well
as the materials handled. Thus, we had to c^.isider programs which are
sufficiently flexible to be feasible within the diverse industrial
spectrum, yet lead to a more uniform and effective spill prevention
practice.
Regulations must be enforceable, procedures must be adaptable to
specific industries, equipment must be usable in both old and new facili-
ties. Thus, our efforts were directed to development of a plan which is
guided and enforced by government, implemented and accepted by industry,
and provides the necessary spill prevention for environmental protection.
The prototype plan is given in Volume II of this report.
15
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III. LAWS AND REGULATIONS FOR SPILL PREVENTION
One objective of this program was to review the status of laws,
rules, and regulations pertaining to the prevention and control of spills
of oil and hazardous polluting substances. Because of the multi-agency
jurisdiction over spills of oil and hazardous materials, we examined laws
and regulations of federal, regional, state, and municipal water quality
and health agencies. We requested information on pertinent laws, regula-
tions and orders from 30 state water pollution regulatory agencies, 20
individual environmental engineers at state agencies, 17 state or city
fire marshalls, 6 intergovernmental groups and 23 industry associations.
(See listing given in Appendix A.) We also reviewed pertinent regula-
tions of the United States Geological Survey for offshore petroleum
wells, the Hazardous Materials Regulation Board of the Department of
Transportation Bureau of Land Management, rules of regulatory agencies in
oil producing states, and fire and insurance underwriter codes.
This review established that: (1) most laws and regulations are
directed toward the protection of personnel and property from the
consequences of spills of oil and hazardous substances, (2) the regula-
tions for maintaining water quality consider detection, surveillance,
and cleanup of spills once these have occurred, but rarely specify
detailed prevention measures, (3) most regulations are concerned with
oil spills; other hazardous materials are mentioned infrequently. These
conclusions are amplified in the discussion on thfe following pages.
A. FEDERAL REGULATORY PRACTICE
1. Federal Water Pollution Control Act
The Federal Water Pollution Control Act clearly recognizes the
requirements for prevention within the overall concept of water quality
"Section. 1. (a) The purpose of this Act is to enhance the
quality and value of our water resources and to establish
a national policy for the prevention, control, and abate-
ment of water pollution."
"...it is hereby declared to be the policy of Congress to
recognize, preserve, and protect the primary responsi-
bilities and rights of the States in preventing and
controlling water pollution..."
"Sec. 4. (a) The Secretary shall encourage cooperative
activities by the States for the prevention and control
of water pollution..."
17
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These provisions both recognize the need for prevention and indicate that
a joint federal-state effort is desirable and required for the prevention
of pollution. The provisions listed below call for research investigation,
training and dissemination of information on the subject of prevention of
pollution:
"...conduct in the Department of the Interior and
encourage, cooperate with, and render assistance to
other appropriate public (whether Federal, State,
interstate, or local) authorities, agencies, and
institutions, private agencies and institutions, and
individuals in the conduct of, and promote the
coordination of, research, investigations, experiments,
demonstrations, and studies relating to the causes,
control, and prevention of water pollution."
"...provide training in technical matters relating to
the causes, prevention, and control of water pollution
to personnel of public agencies and other persons with
suitable qualifications."
"...collect and disseminate basic data on chemical,
physical, and biological water quality and other infor-
mation related to water pollution and the prevention and
control thereof."
"...enter into contracts with, or make grants to, public
or private agencies and organizations and individuals for
(A) the purpose of developing and demonstrating new or
improved methods for the prevention, removal, and control
of natural or man made pollution in lakes..."
Note that training is recognized as an important aspect of water pollution
control. As demonstrated elsewhere in this report, many pollution inci-
dents are the results of human error. Some of these could be eliminated
through training programs, either industry or government sponsored, that
point up the importance of each individual in the total prevention program.
The Act clearly indicates that discharges of oil should be prevented.
"...the Congress hereby declares that it is the policy
of the United States that there should be no discharge
of oil into or upon the navigable waters of the United
States, adjoining shorelines, or into or upon the waters
of the contiguous zone."
The Act continues to specify penalties for persons discharging oil, to
provide for the National Contingency Plan, and contains provisions for
18
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cleanup and control of oil pollution. The requirements for new regula-
tions on prevention are cited in Section 11 (j), as follows:
"...Consistent with the National Contingency Plan...,
the President shall issue regulations consistent with
maritime safety and with marine and navigation laws...,
(C) establishing procedures, methods, and requirements
for equipment to prevent discharges of oil from vessels
and from onshore facilities and offshore facilities..."
Section 12, which deals with control of hazardous polluting substances,
provides for the designation of hazardous substances and methods for
removal of these materials.
"Sec. 12. (a) The President shall develop, promulgate,
and revise as may be appropriate, regulations (1) de-
signating as hazardous substances, other than oil as
defined in Section II of this Act, such elements and
compounds which, when discharged in any quantity into
or upon the navigable waters of the United States or
adjoining shorelines or the waters of the contiguous
zone, present an imminent and substantial danger to the
public health or welfare, including, but not limited
to fish, shellfish, wildlife, shorelines, and beaches;
and (2) establishing, if appropriate, recommended
methods and means for the removal of such substances."
Under Section 12 the President is also to study methods and mea-
sures for controlling hazardous substances to prevent discharge. Under
the provisions of the Federal Water Pollution Control Act, the designation
of hazardous substances is proceeding.
2. Executive Order 11507
Under Executive Order 11507,[7] the federal government is charged—
in the design, operation and maintenance of its facilities—with pro-
viding leadership in the nationwide effort to protect and enhance the
quality of our air and water resources. Two parts of this Executive
Order are important statements relating to the prevention of pollution
by oil and hazardous materials:
"...Heads of agencies shall ensure that all facilities
under their jurisdiction are designed, operated, and
maintained so as to meet the following requirements:
(2) Actions shall be taken to avoid or minimize wastes
created through the complete cycle of operations of
each facility."
19
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"(4) The use, storage, and handling of all materials,
including but not limited to, solid fuels, ashes,
petroleum products, and other chemical and biological
agents, shall be carried out so as to avoid or minimize
the possibilities for water and air pollution. When
appropriate, preventive measures shall be taken to
entrap spillage or discharge or otherwise to prevent
accidental pollution."
These can be interpreted as calling for an evaluation of operations (i.e.,
processes, procedures, equipment, etc.) at each facility to avoid or mini-
mize waste and thereby minimize the waste pollution problem. They
also imply a "fail-safe" concept, i.e., preventive measures to entrap
spillage or discharge or otherwise prevent accidental pollution. These
two sections, if expanded and applied to industrial facilities, would be
a major force in preventing pollution by oil and hazardous materials.
3. United States Department of the Interior
Some of the most specific regulations for preventing pollution
from accidents have been promulgated by the Department of the Interior's
U. S. Geological Survey in regulations concerning the conduct of mineral
operations and developments in the Outer Continental Shelf (30 CFR Part
250).[8,9] in addition, these regulations are made a part of the leasing
program administered by the Bureau of Land Management as outlined in 43
CFR, Part 3380.[10] The outer Continental Shelf Orders have been issued
by the Gulf Coast and Pacific regions of the Branch of Oil and Gas
Operations, Conservation Division of the U. S. Geological Survey. The
intent of these orders in each region is similar; however, the specific
conditions and language employed varies. Although these orders are
specifically addressed to oil, gas and sulfur producing wells on the
Outer Continental Shelf, we found these to contain more specific con-
ditions and procedures useful in preventing and controlling spills than
in any other federal regulations and have recorded in the following
Table 2 the ones we judge as most pertinent.
4. Department of Transportation
The Hazardous Material Regulation Board of the Department of
Transportation has established safety regulations for the design, con-
struction, operation, and maintenance of pipelines carrying hazardous
materials and petroleum products in liquid form. These regulations are
issued as 49 CRF, Part 195—Transportation of Liquids by Pipelines.
These regulations fall into the following categories:
• Sub Part A - General
• Sub Part B - Accident Reporting
• Sub Part C - Design Requirements
• Sub Part D - Construction
• Sub Part F - Operational Maintenance
20
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TABLE 2
UNITED 5TATEV. GEOLOGICAL S'JRVKt -OLTE-. CONTHSE'ITAL SHELF RECVLAUJNS.
UNITED STATES GEOLOGICAL SURVKY
Items
1. Well Casing and Cementing
A. Drive or Structural Casing
B. Conductor and Surface Casing
Specific Depths
C. Intermediate Casing
D. Production Casing
E. Pressure Testing
2. Blowout Prevention
A. Equipment
B. Mud Program
3. Plugging and Abandonment of Wells
Gulf Coast Region
OCS No. 2—Item 1A
DCS No. 2—Item IB
OCS No. 2—Item IB
OCS No.2—Item 1C
OCS No.2—Item ID
OCS No.2—Item IE
OCS No. 2—Item 2
OCS No.2—Item 3
OCS No.3
4. Storm Choke or Similar Subsurface Safety Device OCS No.5
5. Procedure for Completion of Oil & Gas Wells
6. Pollution and Waste Disposal
A. No Oil into Water
B. No Harmful Liquid Waste into Water
C. All Pollution Control Equipment Must Be
Maintained
D. All Platforms & Structures, Curbed and
Drained to Tank or Sump
E. Operating Personnel Thoroughly Trained
F. Pollution Inspections (Manned-Daily,
OCS No.6
OCS No.7—Item LAI
OCS No.7—Item 1A2
OCS No.7—Item 1C1
OCS No.7 —Item 1C2
OCS No. 7—Item 1C3
unattended-frequently) OCS No.7—Item 2A
G. Reporting of Spills and Leaks
H. Spill Emergency Plan—Corrective Action
I. Spill Control Equipment
1. Booms
2. Skinning Apparatus
3. Approved Dispersants
Production Platform Requirements
A. Gas Detector and Alarm System
B. Approved Fire Fighting System
C. High and Low Level or Pressure Alarms and
Shutdown; Devices in all Production Vessels
and Water Separation Devices
D. Remote and Local Automatic Platform and
Well Shutdown Devices
OCS No. 7—Item 2B
OCS No.7--Item 3A1
OCS No.7—Item 3B
OCS No.7—Item 3B
OCS No.7—Item 3D
OCS No.8—Item 2A7
OCS No.8—Item 2A6
OCS NO.8—Item 2AI
OCS No.8—Item 2A2
E. High 4 Low Pressure Oil Pipeline Alarms
& Control Devices to Shutdown Shipping Pumps
& to Shut in all Well in Event of Actuation OCS No.9—Item LAI
F. Approved Sewage Disposal System
G. Auxiliary Power Supply Equipment
H. Approved Waste Water Handling and
Disposal System
8. Gathering Pipelines
A. Automatically Controlled Shutoff Valves
B. Corrosion Protection
C. Check Valves
D. Other Spill Preventing Equipment
OCS No. 8— Item 2A9
OCS No.8--Item 2A4
OCS No. 8 — Item 2AS
OCS No. 8— Item 2A2
Pacific Region
OCS No.10—Item 1A1
OCS No. 10—Item 1A2
OCS No. 10—Item lA2-ii
OCS No.10— Itrm 1A4
OCS No.10—Item 1A5
OCS No. 10—Item 1A6
OCS No. 10—Item 1B1
OCS No.10—Item 1C
OCS No.3
OCS No.10—Item 2
OCS No.6
OCS No.7
OCS No.7
OCS No. 10—Item 5-7
OCS No. 8— I td
2A2
OCS No.10—Item 6
OCS No. 10—Item 6
OCS No. 10—Item 6
OCS No. 10—Item 5-1
OCS No. 10—Item 5-2
OCS No. 10—Item 5-3
OCS No. 10—Item 5-4
OCS No. 10—Item 5-5
OCS No. 10—Item 5-6
OCS No. 10—Item 5-8
OCS No.10 —Item 5-9
OCS No.10—Item 3-1
OCS No. 10—Item 3-2
OCS No.10—Item 3-3
OCS No. 10—Item 3-4
21
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While these regulations include many standards which are principally
responsible for insuring that adequate safety precautions are realized
in design, construction, operation and maintenance of pipelines, the
only portion directly pertinent to pollution control is the requirement
of telephonic notice of leaks at the earliest practicable moment following
discover)'' that resulted in pollution of any stream, lake, river, or other
similar body of water.
B. STATE AND REGIONAL REGULATORY LITERATURE
Within the scope of the present study it was not possible to
investigate the latest regulatory literature of all states in great detail.
As a preliminary exercise, we reviewed the State Water Quality Laws, as
compiled in the Environment Reporter issued by the Bureau of National
Affairs, Inc., to determine which state agencies have specific authority
to regulate spill prevention techniques. The types of regulations and
the fraction of states which have regulations are shown below:
% of States
with these
Types of State Regulations Regulations
1. Develop programs for treatment and disposal 48
2. Establish Water Quality Standards 60
3. Examine plans and give approvals for wastewater 64
treatment
4. Issue permits, determine compliance, and revoke 92
permits
5. Adopt rules and regulations to abate and prevent 68
pollution
The pertinent information for each state is given in Table 3. Although
over 2/3 of the states have regulations which cover pollution abatement
only a few have specific regulations pertaining to spills of oil and
hazardous materials. Table 4 indicates those states for which specific
spill regulations were found as the result of direct inquiries (see
Appendix A for list of contacts and responses) or from information
received during field interviews. From this review, we conclude that
pollution by discharge of oil or petroleum products is addressed in
greater depth and more frequently than pollution by hazardous materials
While major oil producing states have specific regulations concerning
production of oil and the prevention of oil pollution during product
a limited number of states have recognized the potential for pollut' '
22
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TVPKS OF STATK WAT1.K I'OLUTIOH K1CULATIONS
Alabaioa
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New York.
New Mexico
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Develop
Programs tor
Treatment
'and Disposal
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Eat.-.bllsli
Water
Quality
Standards
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Examine Haass
and Approve
WjstevatPT
Treatment Pitas
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Issue Permits
Determine
Compl innce,
Revoke Permits
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Ailopt Rules 4
Regulations
to Abate & Pre-
vent Pollution
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
23
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TABLE 4
SPECIFIC STATE SPILL PREVENTION,
RULES, REGULATIONS AND LAWS
Spill Prevention Regulations
National or Local
State OH Other than Oil Contingency Plan
Alaska X X
California X
Colorado Reporting only
Florida (in Litigation)
Louisiana X
Maine X
Maryland In Preparation
Massachusetts Filed
Michigan Being Considered X
Nebraska XX X
New Jersey X Being Adopted
New York X X
Pennsylvania X
Rhode Island X
Texas X
Wisconsin X Planned
24
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by oil and hazardous materials during transport and at terminal operations
by providing both guidelines and in some cases specific procedures to pre-
vent pollution. The most l pertinent and applicable state regulations for
spill prevention, including those which provide for specific procedures,
methods and equipment for preventing spills of oil and hazardous materials,
are reviewed on the following pages.
1. Specific Preventive Measures
The regulations of several state agencies describe specific pro-
cedures, methods, and equipment to be used for preventing spills of oil
and hazardous materials. Some of these are reviewed below.
The Rhode Island Department of Healthful provides many specific
regulations concerning procedures and equipment pertaining primarily to
transfer of oil from a vessel to shore or from shore to vessel, and at
storage and terminal operations. Some examples of the regulations are
the pressure testing of flexible hoses used in transfer operations, the
use of drip pans under hose connections, proper support for hoses and
sufficient length to avoid any strain, illumination of wharves or pier
areas during transfer operations, check valves in discharge lines, closing
of valves in dike surrounding tanks, storage tank inlets, overflows and
vents, etc. Because of the broad scope of these regulations, they have
been reproduced in Appendix B.
Massachusetts' Division of Water Pollution Control I 12 J has filed
rules pertaining to marine oil transfer operations, terminal and bulk
plants and other oil handling installations, spills, and other accidental
discharges. The marine oil transfer operation specifies procedures and
equipment such as: plugging of scuppers, blanking ends of hoses, drip
pans, checking connections, flanges and joints, curbs on, wharves or piers,
etc. Other parts of the regulations require dikes or retaining walls
around tanks or tank batteries, use of oil traps in terminal areas,
and granting of licenses to terminal operations. Parts of these regula-
tions are included in Appendix C,
Alaska, 13 j_n its oil and gas conservation regulations and statutes,
provides for prevention of leaks and breaks in wells and piping as well
as other prevention measures. There is also a list of regulations per-
taining to the prevention of industrial waste pollution. General guide-
lines are given for industries as varied as meat packing plants and
canneries, metal industries, and pulp and paper mills. Most of these
regulations ; ":a general but specific procedures for oil separation and
collection are given. The broad potential of these regulations is illus-
trated by the section entitled "Oil Transportation Equipment."
"...Tankers, railroad tank cars, tank trucks, or other
facilities and for the loading, unloading, storage, and
transportation of oil shall be equipped for the collec-
tion of the drips from hose cr ether connections and
25
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the excess oil contained in hose and pipelines, wherever
there is a possibility that this oil will find its way,
either directly or indirectly, into a body of water.
Provision shall be made, also, for catching accidental
spills, and these facilities shall be of such a capacity
as to hold the maximum quantity of oil possible from
any one spill."
The provision indicates that facilities should be available to hold the
maximum quantity of oil that could be released in any spill; implementa-
tion of such regulation could prevent many accidental spills which might
otherwise make their way to the water.
Louisiana's Stream Control Commission has rules governing disposal
of waste oil, oil field brine, and all other materials resulting from the
drilling for, production of, or transportation of oil, gas or sulphur. U^J
The most pertinent of these from the viewpoint of spill prevention are as
follows:
"1. Crude oil, waste oil, oil sludge, oil-water emulsion,
or oil bearing mixtures of any kind shall be gathered and
destroyed by burning or otherwise on the lease where the
wastes originate, and in such manner as to eliminate any
pollution hazard.
"2. No oily fluids shall be discharged to, or allowed
to flow on the ground, or be carried from the original
lease in open ditches, or discharged or allowed to flow
into any stream, lake or other body of water."
"3. a. Each producing well, except those over marsh
and water, all oil booster pumps, and any pump used to
move oil or oily fluids, shall be provided with a sur-
rounding gathering ditch or equally effective device,
to prevent the escape of oily wastes from the location,
such ditch to be graded to a gathering sump which shall
be cleaned regularly by removal and destruction of oily
wastes. All spillage of oil shall be promptly gathered
and destroyed.
b. On all pumping wells, over water or marsh,
there shall be installed an adequate impervious deck
or other device with a catch tank installed around the
wellhead. The catch tank should be equipped with a
"stiff-leg" to enable the operator to dispose of
excess rainfall.
26
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c. All drilling barges, whether for workover or
drilling new wells shall be equipped with a device
at the open end or ends of keyways to prevent oil or
oil fluids from escaping therefrom. This device
shall be so installed as to be adjustable for tidal
changes and all oil collected within keyways shall
be picked up and disposed of in compliance with para-
graphs 1 and 2."
"4. Each permanent oil tank or battery of tanks that
are located within the corporate limits of any city,
town, or village or where such tanks are closer than
500 feet to any highway or inhabited dwelling or
closer than 1000 feet to any school or church, or
where such tanks are so located as to be deemed a
hazard by the Stream Control Commission, must be
surrounded by a dike (or fire wall) or retaining
wall of at least the capacity of such areas where
such dikes (fire walls) or retaining walls would be
impossible such as in water areas. At the discretion
of the Stream Control Commission, fire wall of 100%
capacity can be required where other conditions or
circumstances warrant their construction. (As
Amended December 13, 1964.) Tanks not falling in
the above categories must be surrounded by a retain-
ing wall, or must be suitably ditched to a collecting
sump, each of sufficient capacity to contain the
spillage and prevent pollution of the surrounding
areas."
"5. Oil gathering lines, or any other lines used for
transporting oil, shall be regularly inspected and all
leaks shall be immediately repaired. Waste from leaks
shall be collected and destroyed immediately upon dis-
covery. All barges used for the transportation of
crude oil or petroleum products shall be in first class
condition. Leaking barges shall be repaired before reuse.
Loading racks, barge-loading outlets, and similar instal-
lations shall be operated at all times with full precau-
tion against spillage. Such installations shall be sur-
rounded by a ditch graded to a gathering sump, or shall.
be provided with an impervious deck surrounded by a steel
gutter leading to a sump, or with such other equipment
adequate for the accomplishment of the same purpose as
may be approved by the Stream Control Commission. All
such gathering sumps shall be cleared regularly by re-
moval and destruction or other safe disposal of the oily
waste. After each operation of barge or tanker loading
equipment, loading hose and connections shall be care-
fully drained, and the gathering sumps shall be emptied,
preferably to the barge or tanker."
27
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In Texas, Statutory Authorization, Article 7621d, Section 10(c)(4),
places sole responsibility on the Railroad Commission of Texas for the con-
trol or disposition of waste, and abatement and procedures of pollution of
water, both surface and sub-surface, resulting from activities associated
with the exploration, development, or production of oil or gas. The com-
mission issues its rules and regulations under the title "General Conserva-
tion Rules and Regulations of Statewide Application, State of Texas".lljJ
Many of these are similar to those of the USGS's Outer Continental Shelf
Regulations. The directly applicable regulations are found in Rule 8,
Water Protection given in Appendix D.
The following four state laws specifically apply to prevention of
discharge of hazardous materials and other wastes and provide a mechanism
for state regulation of prevention and control procedures.
State of New York. Item 13, Section 10, Article 2 of
Chapter 140 of the Laws of New York. "The Department
of Environmental Conservation...shall have power to:
13, Prevent pollution through the regulation of the
storage, handling, and transport of solids, liquids and
gases which may cause or contribute to pollution."
Commonwealth of Pennsylvania. Section 402, Potential
Pollution, Article IV, Clean Stream Law as Amended,
July 31, 1970.
a. Whenever the board (Department of Environmental
Resources) finds that any activity, not otherwise requir-
ing a permit under this Act, including but not limited
to the impounding, handling, storage, transportation,
processing and disposing of materials or substances,
creates a danger of pollution of the waters of the
Commonwealth or that regulation of the activity is
necessary to avoid such pollution, the Board may, by
rule or regulation require that such activity shall be
conducted only pursuant to a permit issued by the
Department or may otherwise establish the conditions
under which such activity shall be conducted, or the
Board may issue an order to a person or municipality
regarding the particular activity. Rules and regula-
tions adopted by the Board pursuant to this section
shall give the persons or municipalities affected a
reasonable period of time to apply for and obtain any
permits required by such regulations.
Commonwealth of Virginia. Article 3—Regulation of
Industrial Establishment, Section 62.1-44.16
28
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1. Any owner who erects, constructs, opens, reopens,
expands or employs new processes in or operates any
establishment from which there is a potential or actual
discharge of industrial wastes or other wastes to state
waters shall first provide facilities approved by the
Board for the treatment or control of such industrial
wastes or other wastes.
62.1-44.17"...shall upon request of the Board install
facilities approved by the Board or adopt such measures
approved by the Board as are necessary to prevent the
escape, flow or discharge into any State waters when the
escape flow or discharge of such other wastes into any
State waters would cause pollution of such State waters."
The State of Rhode Island in its pollution regulations
provides a mechanism for adoption of pollution prevention
procedures, following an incident in which pollution has
occurred. This order reads as follows:
"••-Order to adopt pollution prevention systems —If any
person is polluting the waters of the state, and if after
such investigation the director shall so find, he shall
make his findings in writing to that effect and may enter
an order directing such person to adopt or use or to
operate properly, as the case may be, some practicable and
reasonably available system or means to prevent such
pollution, having due regard for the rights and interests
of all persons concerned. Such order may specify the parti-
cular system or means to be adopted, used or operated; pro-
vided, however, that where there is more than one such
practicable and reasonably available system or means, such
order shall give to the person complained of the right to
adopt or use such one of said systems or means as he may chose."
Other laws are less specific in that they prohibit pollution but do
not provide for spill prevention control, for example:
State of Nebraska. 71-3007. Unlawful Acts
1. It shall be unlawful for any person:
a. To cause pollution of any waters of the state
or to place or cause to be placed any wastes in a
location where they are likely to cause pollution of
any water of the state...
29
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State of New Jersey.
4. The discharge of hazardous substances, debris, and
petroleum products into or in a manner which allows flow
or runoff into or upon the waters of this State and the
banks or shores of said waters is prohibited.
From this review of state water quality laws we conclude that
specific legislation permitting regulatory bodies to establish rules and
regulations directed at methods for preventing spills from occurring and
from entering water courses is inadequate to insure that the handlers of
hazardous polluting substances are taking actions necessary to prevent
spills of hazardous substances from polluting the Nation's water resources.
C. FIRE LAWS AND FIRE PREVENTION AND UNDERWRITER CODES
The laws and regulations for fire protection are primarily for
protection of people and property, especially in the handling of flammable
liquids. Although the requirement of dikes around any tank storing
flammable liquids is an excellent regulation from the viewpoint of
preventing widespread pollution upon rupture of a tank, the reasons for
this requirement are solely for protection of people and property. Conse-
quently, fire laws and codes can be considered as valuable but specific
adjucts to rules and regulations required to decrease the potential for
spills of hazardous substances entering water courses; however, they are
only that—valuable adjuncts.
30
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IV. TECHNICAL AND TRADE LITERATURE
We surveyed recent technical and trade literature to determine
(1) the recorded causes of spills of hazardous polluting substances,
(2) equipment, design criteria and procedures for spill prevention and
(3) indication of the extent to which techniques and equipment are used
to prevent and control spills of hazardous materials. The results of
this survey formed a basis for establishing the direction of the plant
surveys in which we sought additional information for evaluating the
practices of industry in preventing and controlling spills. Literature
sources for this survey are listed in Table 5 and were limited primarily to
publications of the last three years since previous work bad indicated
that prior to 1967, few articles had reported on spills of oil and hazardous
materials. We specifically contacted 23 professional and trade associa-
tions to obtain their publications. (See Appendix A.)
A. CAUSES OF SPILLS
We concentrated on obtaining information on hazardous materials
other than oil because the latter have been well documented and we were
' -i*? ing information on much broader types of materials. Table 6 illus-
ti ct?3 the types and causes of spills. The preventative actions that
have' been recommended by the investigating groups to eliminate subsequent
failures are also listed in Table 6. These actions deal primarily with the
correction of equipment failures; however, consideration of the nature of
the failures suggests that more attention to inspection, maintenance and
general good housekeeping could have prevented many of these accidental
spills.
The failures recorded in Table 6 that resulted in accidental spills
of chemicals are similar to those reported as causes of oil spills entering
the River Thames outside of London.[19] of 394 reported oil spills, 30%
resulted from storage of oil, 10% from oil pipelining, 10% from the dis-
posal of waste oil, 11% from engines, auto service stations vehicle depots,
railroad and air fields, 5% from road tank-truck accidents, 23% from
general spillage, and the remaining 11% being unknown. Of 90 small and large
spills originated from oil storage installations, 35 were caused by over-
filling of tanks and 51 by leaky valves or from valves that had been
damaged deliberately. At least 74 of these incidents could have been
avoided if elementary precautions had been taken in designing the tank
storage area. Nearly all of the spills from oil tanks were attributable
to human error. Pipeline failures were due to corrosion, a lack of catho-
dic protection, or by structural damage during road construction. Most of
the spills in industrial facilities were caused by careless use of oil,
spillage or improper disposal by employees.
31
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TABLE 5
SOURCES USED IN LITERATURE SURVEY
Abstracting and Indexing Services
Engineering Index
Oceanic Index
Applied Science and Technology Index
U. S. Government Research and Development Reports Index
Technical Abstract Bulletin Index
Chemical Abstracts
Nuclear Science Abstracts
Air University Library Index to Military Periodicals
Department of Interior, Office of Water Resources Research, Water
Resources Research Catalog
Federal Agencies
Government Printing Office Monthly Catalog: GPO Price Lists, #42,
Irrigation, Drainage and Water Power, and #58, Mines, Explosives,
Fuel, Gasoline, Gas, Petroleum, Minerals
Various Agencies and Departments: Department of the Interior (FWQA, USGS) ;
Office of Water Resources Research; Department of Transportation (USCG) ;
Department of Commerce (NOAA); AEC; Council on Environmental Quality,
Environmental Protection Agency; National Science Foundation; Water
Resources Council; National Council on Marine Resources and Engineering
Development
Scientific and Technical Societies
American Petroleum Institute
American Chemical Society
American Institute of Chemical Engineers
American Institute of Mining, Metallurgical and Petroleum Engineers
American Nuclear Society
American Society for Metals
American Society of Civil Engineers
American Society for Testing and Materials
American Society of Mechanical Engineers
Compressed Gas Association
Manufacturing Chemists Association
National Academy of Sciences, National Academy of Engineering, National
Research Council
American Insurance Association, Engineering and Safety Department
Selected Journals
Chemical Engineering Environment
Chemical Engineering Practice journal of Water Pollution Control Federation
Oil and Gas Journal Pollution Engineering
Chemical Engineering Progress Environmental Science and Technology
Ocean Oil Water and Waste Engineering
Oil, Gas and Petrochem Equipment Industrial Water Engineering
Chemical and Engineering News
32
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TABLE 6
TYPES, CAl'SLS ASP READIES FOP CHEMICAL ?PILLS
CHEMICALS INVOLVED
Caustic Soda
FAILURE
Flexible pipe breaks loose while
loading caustic soda into tankcar
PREVENTIVE MEASURES
Redesign loading device and install safety i/ljrcp
Review facilities for handling hazardous ch^nic.ils
Aimonla
Scale tanks overfilled with
ammonia; relief valve popped spray-
ing liquid ammonia into atmosphere
Install high-level alarms on scales
Install high-level cut-off valve on distribution
tank
Aniline
Aniline stripper ruptures due to
plugged vent line
Install double valves and tell-tale bleeds
Install instrumentation-!.e. level
and pressure recorders, alarms
Redesign safety seal
Monomer
Tank overflow during filling; loss
of 13,127 Ib. of monomer; cause:
plugged vent pipe
Inspect and clean vent pipe regularly
Sulfuric Acid
Hose bursts during transfer of
acid
Do not use hoses foi sulfuric acid loading; use
pipes and swivel joints
Oleum
Rupture in flexible Teflon vtw hose;
isket failure
Install expansion valve
Install pressure relief valve
Ammonia
Relief valve discharged improperly
handled
Pipe discharge to ditch
Line to vent pressure to keep pressure below
relief valve setting
Caustic Potash
Drum overflowed into sewer; re-
acted with sulfides in sewer-* H$
Redesign sewers to prevent "mixing" of hazardous
materials that may react undesirably
Caustic Soda
Failure of gate valve and check
valve
Redesign valves
Redesign to prevent chemical contamination of
steam and water supplies
Aranonia
Leaks in two manual block valves
and automatic control valve
Replace/repair valves
More frequent inspection
Phosphorous Acid
Failure of butterfly-type valve
due to corrosion
Careful inspection of system
Possible-redesign of piping
Phthalic Anhydride
Tank overflow during filling
Install more reliable level indicators on tanks
Phosphorous Acid
Sulfuric Acid
Valve failure (defective valve)
Repair/replace valva
Hose rupture allows H2S04 to enter
sewer
Replace with permanent piping to appropriate drainage
location
Sodium Sulfhydrate
Pump failure; sodium sulfhydrate
enters sewer
Repair pump
Install sump pump
Formaldehyde
Spring valve failed
Replace spring valve with gate valve
Phenol
Overloading of still due to failure
of gauge
Redesign gauges to prevent inaccurate readings due; to
clogging
Sulfuric Acid
Leaking valve due to pressure
buildup
Installation of vent line to relieve pressure
buildups
Nitric Acid
Sulfates
Toluene
Faulty hose connect and leaking
cock In line
Replace hose with permanent pipe
Replace/repair cock
Hot sultatc' slurry cvtrHovs due
to pump failure
Investigate different pumps to handle slurry
Sight glass in stripper kettle line
failed
Install now pressure-type sight glass
Clean and inspect periodically
Redesign to eliminate sight glass
33
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TABLF 6 (Continued)
CHEMICALS :NVUVF.:>
Caustic Soda
Acrylonitrili
Anhydrous Ammonia
Sulfuric Acid
Hazardous, flammable
chemical in polymerization
reaction (pilot plant)
Anhydrous Ammonia
Acid Cement
Corrosive Chemical
Vinyl Chloride
Chloroacetic Acid
Acetanilide
Ammonium Nitrate
Phenol
Ammonia
Liquid Organics
Sodium Cyanide
Methyl Alcohol
Caustic and Peroxide
Unspecified Poison
Textile Waste
Industrial Waste
Adhesives
FAILURE
Failure o£ cock valve while caustic
soda being loaded
Water seals on reactor agitator
bleu
Hose ruptured a fitting
Cast iron pipe ruptures
Safety disc rupture; escaping
materials did not vent out proper
vents
Rupture of flexible hose on tank
truck
Frozen valve failed to bleed off
pressure when opened; accumulation
of cement prevented second valve
from being closed
Gate valve failure (valve stem)
Sight glass failure
Mechanical failure of valve
Valve blows under pressure
Valve failure due to pressure
buildup
Frozen valve; plugged cock
Safety valve failure; failure of
pressure gauge
Overflow of surge tank
Dumping of cleaning agent in sewer
Tank truck wreck; contents spilled
into river
Pipeline failure
Employee washed containers used
for poison storage in river
Insufficient waste treatment plant
Lagoon banks rupture
Spills into floor drains enter
river
PREVENTIVE MEASURES
Inspect cock valves before each use
Redesign cock valve
Redesign water seals
Resize reactor vents to relieve pressure without
blowing
Replace leaking block valve
Install permanent piping
Redesign piping system replacing cast iron pipes
with PTFE-llned carbon steel piping
Temperature controller Installed
Review procedures to guard against future
pressure buildups
Install check valve on tank line
Replace valves
Valves to be kept warm with use of propane heaters
Replace valves with more suitable type valves
Replace sight glass with one rated for pressures
developed in reactor
Redesign valve
New valve design
Orifice restriction to be Installed to limit flow
Inspection and repair of valves and cocks
Replace faulty valve; review design of gauge and
possibly replace with better one
Installation of alarm to signal overfill
New treatment plant constructed
~
Repair and inspect pipeline
Change housekeeping procedures
Reuse of plant waste and redesign of treatment system
Reconstruct lagoon; fence in area
Divert waste to sewage disposal system
Acid Waste
Breakdoum in lime pumps for
neutralization resulted in acid
v.iste discharge
Replace pump and add standby unit
Data Sources: References 10, 17, 18; Reports of Accidents maintained at the South
Ontrai Region Office of the Environmental Protection Agency.
34
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The same type of accidents and causes are found in the list of
types and causes of oil spills (Table 7) in Rhode Island during the period
of July 1, 1968 to June 30, 1969, and for incidents taken from the Environ-
mental Protection Agency's South Central Region Office. Thus, we conclude
that the causes of spills are essentially the same regardless of country
and geographical location and are primarily related to human error, either
in design or operation.
The best documentation of failures of equipment and operational
errors in handling hazardous materials was found in a systematic[20]
survey of several hundred fires and explosions in the chemical industries
over the past 20 years. On the basis of these case histories, the investi-
gators suggested a series of hazards factors as the principal causes or
contributors to these accidents. Although the study was concerned with
fire and explosion losses, the same hazard factors often result in spills
of hazardous materials. Those factors that we believe are most significant
in spills of oil and hazardous materials are underlined in Table 8.
Previous work[l»2>3>^J suggests that the last four causes given in Table
8—material movement problems, operational failures, equipment, and in-
effective loss prevention programs—are probably the most important cause
of spills of oil and hazardous materials. These hazard factors are well
known to fire and safety engineers; careful consideration of them by
environmental specialists may be an approach to help prevent spills.
B. EQUIPMENT, DESIGN CRITERIA AND PROCEDURES FOR SPILL PREVENTION
The results of our literature survey confirmed our original hypothesis
that little specific technical information is available on equipment and
design criteria solely for prevention of oil and hazardous material spills.
Because liquid handling methods and systems are devised from equipment
components, the most detailed design criteria and equipment specifications
are based on achieving certain standards of design and fabrication to
meet specified operational conditions. Furthermore, the specificity of
these standards becomes more rigorous and the degree of permitted varia-
bility becomes less broad for either unusual operating conditions, e.g.,
temperatures and pressures significantly above or below ambient, or where
hazards to property and personnel are high such as from fire or toxicity.
Literature references on equipment are principally restricted to con-
tainment -and removal devices for spilled oil and not on equipment for
spill prevention. We determined that the best approach to the equipment
aspect of spill prevention is adherence to manufacturing, construction and
performance standards commensurate with the potential for spills to occur
and to enter water resources because the Iiteraturell6,17,18] indicated
that spills could not be overcome solely through reliance on improved equip-
ment and because of the impracticality of devising generally meaningful
equipment configuration and designs for all spill prevention problems.
35
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TABLE 7
TYPES, CAUSES AND REMEDIES FOR OIL SPILLS
SPILL TYPE
Black oil in river
Black oil in river
Black oil in river
Oil at wharf
Light fuel oil at terminal
Light fuel oil
Heavy fuel oil
Heavy fuel oil
Heavy fuel oil
Light fuel oil
Bunker C
Crude oil
Crude oil
Crude oil
SPILL TYPE
Crude oil
Crude oil
Crude oil
FAILURE OR CAUSE
Vandals emptied fuel tank iAto plant floor drain;
entered river
Breakdown of heating unit causes oil to be dis-
charged through floor drain
Break of fuel oil coupling in plant, oil dis-
charged through drain
Improperly maintained oil spearator leaked
Leaky hatch covef
Pipeline rupture of unknown cause
Barge went aground
Overflow of storage tank during transfer; flowed
through yard drain
Improper ballasting procedure caused spill of oil
Overflow storage tank, valve in diked area left
open
Tank overflow during storage
Pipeline break caused by pile driving in area
Heater-trcater malfunction
Oil In dike from overfilled tank; dike valve open
FAILURE OR CAUSE
Storage tank rupture, dike valve open
Drop in high tide resulted in siphoning oil from
separator
Farmer broke pipeline while plowing field
CORRECTIVi: ACTION *
Place vali-e in floor drain
Use separator for floor drain
Terminate floor drains in dry sump
Repair or replace separator
Mechanical repairs
Build retaining walls around pipeline
and transfer pumps
Seal yard drain
Close valve; update inspection
procedures
CORRECTIVE ACTION *
* Recommended in state report.
36
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PROBLEM
1. Plant Siting
2. Plant Layout
3.
Non-Conforming
Structures
4. Material Evaluation
5. Process
TABLE 3
HAZARD FACTORS IN CHEMICAL PLASTS
FACTORS
• Unusual exposure to natural forces
such as windstorms^ floods, earth-
quakes
• Poor locution with respect to water
and utility supplies
• Hazards from nearby plants
• Unreliable public fire and emergency
protection
• Difficult traffic conditions for
emergency equipment
• Inadequate waste and disposal facili-
ties
• Climatic conditions requiring indoor
installation of hazardous processes.
• Congested process and storage areas
• Inadequate Isolation of extra hazar-
dous operations
• Exposure of high-value, difficult to
replace equipment
• Lack of proper emergency exits
• Insufficient space for maintenance or
emergency operations
• Ignition source too close to hazards
• Critical plant areas exposed to hazards
• Inadequate designation of plant hazard
areas
• Disregard of building codes
• Inadequate fire restrictive structural
supports
• Failure to provide blast walls or cub-
icles for extra hazardous operations
• Inadequate explosion venting
• Inadequate building ventilation
• Insufficient exits
• Electrical equipment not in confor-
maoce to required codes
• Insufficient evaluation of fire,
health and stability characteristics
of materials
• Lack of established control for
quantities used
« Inadequate assessment of processing
conditions on hazardous character-
istics
• Lack of information on dust explosion
potentials
* Toxicologies! hazards not properly
evaluated
• Incomplete inventory of hazardous
materials
• Iffipror'f-r packaging and labeling
* Lack of information on effects of
process temperature and pressure
vari al i^pj?
• Lack of inf ormat i-in on hazardous by-
products or sl;ie react ions
• JkiaJi^niiato knowledge of process
r_e:.>c t^ion r^t >.>;-;_
• Failure to Identify possible
explosive reactions
e Jnailfvjual:<• J?V;ili">«.J_on__of environment
• Fail'tre to prrvKV {or extreme process
c.-iiidlt ions
EXAMPLES OF 11-V,' FACTORS COULD
AFFECT SPILLS
« Weathered contaminants could
be washed into drains
• Insufficient wash water
available
• Hazards could cause spill
situations
• Incomplete cleanup of process
waste
» Insufficient room for curbing
or dikes
• Poor maintenance could lead
to chronic leaks
• Fire or explosive hazards
could cause spills in adjacent
areas
Inadequate materials usage
could yield spills, e.g.
incorrect materials of
construction for storage
Excess quantities of mater-
ials could exceed prevention
measures, e.g. dikes, sumps
Processing could change com-
monly spilled non-hazardous
materials to hazardous
Can lead to Inadequate spill
prevention plan
Could lead to spills from
process equipment
Materials of unknown hazard
could be spilled
37
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TABLE 8 (Continued)
7. Operations
6. Material Transport « Lack of control during processing
• Inadequate controls for dust hazards
• Piping problems
• Improper identification of hazardous
materials
• Loading and unloading operations
• Flammability
• Heat transfer control
• Pneumatic conveyor explosions
• Waste disposal and air pollution
problems
• Lack of detailed operating instruc-
tions and procedures
• Inadequate operator training programs
• Poor supervision
* Inadequate start-up and shut-down
procedures
* Poor inspection and housekeeping
programs
• Inadequate operating permit program
for hazardous materials
• Lack of emergency ccr.trol plans
• Inadequate drills in operating emer-
gency procedures
• Hazards inherent in design
• Corrosion or erosion
• Metal fatigue
* Defective fabrication
* Inadequate control
• Process conditions exceeded design
limits^
• Poor maintenance
• Inadequate repair and replacement
* Lack of "fail-safe" instrumentation
• Inadequate inspection for adherence
to construction criteria or material
specifications
* Lack of assigned responsibility
8. Equipment Failure
9. Loss Prevention
Program
* Ineffective explosion prevention and
control programs
• Lack of emergency plans
• Poor check on boiler and machinery
risks
• Poor coordination of operating group
with other plant groups
• Ineffective accident investigations
Spills from processing units
could occur
Could result in chronic
piping leaks
Could result in spills at
loading/unloading areas
• Can lead to open valves,
unwanted discharges etc.
• Unexpected spills are common
in start-up and shut-down
• Spill control plan lacking
All equipment failure factors
which can result in fires can
result in spills
Operations may not have been
given responsibility for
factors which could cause
spills
Spill prevention must be
integral part of plant
operations
38
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Standards for mechanical, electrical, fabrication, chemical and performance
can be found among the societies shown in Table 9 to meet virtually any
desired specification. These vary from standards such as nominal diameter,
material, and type of connection for small diameter piping to detailed
codes for the manufacture of pressure vessels subjected to independent
certification. Our literature survey of equipment and design criteria con-
firmed the availability of types of equipment, materials of construction,
design criteria, and manufacturing standards to achieve the construction
of high integrity liquid handling systems. Consequently, the major efforts
of our literature search were devoted to determining what spill prevention
procedures existed.
The most pertinent literature references for spill prevention and
control through specified operational procedures are based on controlling
substances classified as hazardous because of the potential for fires and
explosions or because of human toxicity. Safety in the petroleum and
chemical industries has received the most attention by organizations such
as the American Petroleum Institute, Manufacturing Chemists Association,
Underwriters Laboratories, American Insurance Association, and the National
Fire Protection Association. Technical publication of these organizations
are oriented toward procedures and standards for equipment manufacture,
installation and operation for preventing fires and explosions and for
providing for personnel safety and minimizing property damage. These
reports and studies present both detailed and broad general guidelines
and specific procedures for fire protection. Typical examples of the
subjects covered are shown in Table 10. None of these procedures and
standards are directed toward spill prevention from the viewpoint of
environmental protection; however, many of these jfire and hazards pre-
vention procedures will indeed prevent spill :pollution incidents. The
following is an example of a typical codet^lJwhich has applicability to
prevention of pollution by oil and hazardous materials.
"Drainage and Diked Areas: The area surrounding a tank
or a group of tanks shall be provided with drainage as
in Paragraph 2172, or shall be diked as provided in
Paragraph 2173, to prevent accidental discharge of
liquid from endangering adjoining property or reaching
waterways, except that in particular installations these
provisions may be waived or altered at the discretion of
the authority having jurisdiction when the tanks under
consideration do not constitute a hazard to adjoining
property."
"...The drainage system shall terminate in vacant land or
other area or in an impounding basin having a capacity
not smaller than that of the largest tank served. This
termination area and the route of the drainage system
shall be so located that, if the flammable or combustible
liquids in the drainage system are ignited, the fire will
not seriously expose tanks or adjoining property."
39
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TABLE 9
PROFESSIONAL GROUPS ESTABLISHING EQUIPMENT AND
FABRICATION STANDARDS PERTINENT TO SPILL PREVENTION
American Petroleum Institute
American Society of Mechanical Engineers
American Society for Testing and Materials
U. S. A. Standards Institute
American Water Works Association
American Iron and Steel Institute
American Welding Society
Association of American Railroads
Valve Manufactures Association
Welding Steel Tube, Institute
Manufacturers Standardizations Society of the Valve
and Fittings Industry
National Association of Pipe Nipple Manufacturers,
Inc.
National Certified Pipe Welding Bureau
Pipe Fabrication Institute
Tubular Exchanger Manufacturers Association
Manufacturing Chemists Association
Society of Automotive Engineers
Hydraulic Institute
40
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TABLE 10
TYPICAL PUBLICATIONS ON HANDLING
FLAMMABLE AND ITAZARDOUS MATERIALS
SPONSORING ORGANIZATION
American Petroleum Institute
American Petroleum Institute
American Petroleum Institute
American Petroleum Institute
Manufacturing Chemists
Association
Underwriters' Laboratories
Standards for Safety
Underwriters' Laboratories •-'
Standards for Safety
National Fire Protection i s
Association
American Insurance Association
American Insurance Association
American Insurance Association
National Board of Fire
Underwriters
National Board of Fire
Underwriters
American Petroleum Institute
American Petroleum Institute
TITLE
Recommended Practice for Cleaning
Petroleum Storage Tanks
Recommended Practice for Cleaning
Tank Vehicles Used for Transportation
of Flammable Materials
Guide for the Storage and Loading of
Heavy Oil, Including Asphalt
Practices for Bulk Liquid Loss
Control in Terminals and Depots
(covers evaporated losses)
MCA Cargo Information Card—Manual
for Bulk Dangerous Cargoes
Hose for Conducting Gasoline
Steel Underground Tanks for Flammable
and Combustible Liquids
National Fire Codes, Volume I,
Flammable Liquids
Highway Transportation of Extra-
Hazardous Commodities
Liquefied Petroleum Gas, Safe
Handling and Use
Supervisor's Safety Memo, Emergency
Planning; and Supervisor's Safety
Memo, Accident Prevention
Processes, Hazards and Protection
Involved in the Manufacture of
Spirituous Liquors
Fire Hazards and Safeguards for the
Metal Working Industries
Safe Maintenance Practices in
Refineries
Tank Vehicle Bottom Loading and
Unloading
41
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"...Where provision is made for draining water from
diked areas, drainage shall be provided at a uniform
slope of not less than one per cent away from tanks
toward a sump, drainbox or other safe means of
disposal located at the greatest practical distance
from the tank. Such drains shall normally be con-
trolled in a manner so as to prevent flammable or
combustible liquids from entering natural water
courses, public sewers, or public drains, if their
presence would constitute a hazard. Control of
drainage shall be accessible under fire conditions."
"Piping systems shall contain a sufficient number of
valves to operate the system properly and to protect
the plant. Piping systems in connection with pumps
shall contain a sufficient number of valves to control
properly the flow of liquid in normal operation and in
the event of physical damage. Each connection to pipe
lines, by which equipment such as tank cars or tank
vehicles discharge liquids by means of pumps into
storage tanks, shall be provided with a check valve
for automatic protection against back-flow if the
piping arrangement is such that back-flow from the
system is possible."
The literature on procedures for detection, prevention and control of
spills is primarily focused on oil and petroleum products. These pro-
cedures are most often incorporated in rules and regulations, such as
reviewed in Chapter III, or in publications of professional societies
dealing with the control of waste water influence from industry. For
example, a report by the American Society of Lubrication Engineers £22]
defines the oily-waste control program and methods for evaluating the
quality of the program. It discusses control of oily waste generation
at the source and presents general procedures for prevention and control
of oily-waste pollution. Two examples of problems and solutions have
been condensed into Table II. The overall picture that developed from
our literature surveys showed that most procedures for spill prevention
and control programs must be based on design criteria, engineering
judgment, facility construction and good housekeeping procedures. An
increasing need to step back and take an "unbiased view" of the operations
from a number of viewpoints such as pollution potential in case of fires,
power failures, flooding or other natural disasters, sabotage, operator
inattention and so on, has resulted in a check list such as given in
Table 12.123j An example of a simple safety check list for heater
operations, transport and storage in the chemical and allied industries
is shown in Table 13, taken from a hazard survey 120] by the American
Insurance Association. It is apparent that a system designed to be "fail-
safe" will be less prone to pollution causing incidents when spills of
hazardous materials occur under less severe circumstances.
42
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TABI.K 11
CASE STC1JY laVlfLUS OF PKOCKDrlll.S 1'CS OVKKCOMKW Oi!. POLLUTION
soLmoss
Petrochemical plant located on
Gulf Coast Bay v,is dlnrhitrglng
excessive aniounlb of oil In
waste vati>r stream. All plant
effluent passuJ through
-------
TABLE 12
TYPICAL CHECKLIST FOR PROCESS EXAMINATION
FOR THE OVERALL PROCESS
1. List all highly toxic materials used or formed in the process. For each
material:
• List the conditions necessary for it to be reJ.eased to the
atmosphere or to surface or underground waters. (Does it
normally occur in the process as a vapor, as a highly volatile
liquid, as a nonvolatile liquid, or as a solid? If it Is not
easily vaporized, what process conditions could cause it to be
sprayed into the atmosphere as a liquid aerosol or dust cloud?)
• List the time-concentration levels in the atmosphere that will
produce an effect on human health. List the exposure level in
water as a function of event duration at which toxic effects
to marine life and to human health become apparent. Are the
toxic effects reversible or permanant?
2. For all materials used or produced in the process and other nearby processes,
consider chemical reactions that could take place in the atmosphere or in
sewers and streams between possible chemical species to produce other, highly
toxic materials not present in the process. For any such compounds that
could be produced, list the same information as for Item 1 above.
FOR CONSIDERATION OF INDIVIDUAL PROCESS ITEMS REQUIRING DETAILED STUDY
1. List those pieces of equipment containing sufficient toxic material to
produce a hazard if their contents were suddenly released to the environment.
2. List those items that could produce hazardous quantities of toxic material
through interaction if the contents of two vessels were released simultaneously.
3. List equipment containing design elements likely to leak hazardous materials
such as pump packing, tank vcr.ts — or leaks that might be caused by corrosion
of equipment, etc. For each item listed, indicate what safeguard has been
taken to prevent normal leakage, such as packless pumps, double rotary seals,
vents connected to a scrubber, etc. Is each safeguard adequate and reliable?
DETAILED STUDY
For each item retained on a list under the individual process items, consider the
following:
1. For each process vessel:
• What are the utilities required? What could happen if
one of these, utilities were suddenly and permanently
interrupted? If temporarily interrupted?
What would happen if tnc flow of one or morc Qf
process streams cutting or leaving the vessel were
interrupted? What if it were twice the desired
quantity? W.iat would happen if the. normal outlet
connections from the vessel became plugged?
44
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TABLE 12 (Continued)
• Is the collection efficiency adequate to prevent hazardous
conditions under normal operating conditions? What
abnormal plant conditions can impose the greatest load
on this equipment? For how long is it possible for these
abnormal conditions to persist? What would be the collection
efficiency under these conditions of increased or decreased
flow? Would it be adequate?
• What would happen in case of utility failure or flow
stoppage (loss of motive force
collection device?
• What would happen to the collection device if surrounded
by fire? Could it suffer an internal fire? What then?
• What can happen on collection-
malfunction?
• In case of a small leak caused by corrosion, what
would happed to the leaking material? Would it
produce an environmental hazard? How long might
it leak before being detected? Would the leak hasten
the corrosion and failure of the vessel?
• In case of failure of the vessel, how would the
content be contained? If volatile, what would be
done to prevent its vaporization?
• What would be the effect of overpressure? If
protected by overpressure release devices, how
would the materials released be contained? What
would be the effect of overheating? Of overcooling?
Could the vessel be surrounded by flames from burning
material released because of failure of other equipment
in the area'! If so, what would happen if the fire
lasted for many hours?
• What would be the effect on vessel and contents from
sudden plant flooding, violent storms, or earthquake?
• What operator error or instrument failure could en-
danger the loss of vessel contents?
2. For instrumentation on equipment that handles hazardous materials:
• What would happen upon power or motive force failure
to one instrument, or a group of instruments? To
all instruments? What position would control valves
seek? Is this the best position to minimize hazards?
• For each instrument, what can happen in case of sensor
failure? In case of control valve seizing? Would the
operator receive warning in time to take corrective
action? Should it be clear to a poorly trained operator
what corrective action is needed, or can the situation
be handled with built-in automatic overrides?
3. For material-collection, containment or pollution-prevention equipment
(scrubbers, dust collectors, condensers, flares, combustion incinerators, etc.);
45
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TABLE 13
.CHECK, USX FOR HEATER, COMMON TRANSPORT
AND STORAGE OPERATIONS
1. Have the potential hazards of all materials involved been
evaluated?
2. Are precautionary measures taken to guard against acci-
dental release of flammable or toxic liquids, gases or
combustible dusts?
3. Are unstable chemicals handled in such a way as to mini-
mize exposure to heat, pressure, shock or friction?
4. Are the unit operation facilities properly designed,
instrumented and controlled to minimize losses?
5. Have all heat transfer operations been properly evaluated
for hazards.
6. Have all transport operations been checked for operator
safety?
7. Are shipments of chemicals from the plant packaged,
labeled and transported in accordance with current regu-
lations?
8. Are waste disposal and air pollution problems handled in
accordance with current regulations?
46
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From this survey we conclude that the most detailed design criteria,
equipment specifications, and operational procedures are for either unusual
operating conditions, e.g., temperatures and pressures significantly
above or below ambient, or where hazards to property and personnel are
high such as from fire or toxicity.
C. INDUSTRIAL UTILIZATION OF SPILL PREVENTION AND CONTROL TECHNIQUES
Literature sources provided no basis for establishing the fre-
quency with which industry utilizes available techniques for prevention
and control of spills in its handling of hazardous substances. The only
spill control technique that could be ascertained as used with high fre-
quency is dikes around tanks holding flammable materials. However,
the usage of dikes is primarily to meet fire and safety regulations.
Consequently, it was concluded that the type and frequency of industrial
utilization of spill prevention and control equipment and techniques
would have to be developed from plant inspections.
47
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V. FIELD SURVEY
A, METHODOLOGY
For our field surveys we selected facilities to obtain a cross-
section of geographical locations and types of processing industries.
We included large integrated plants with continuous operations, for example,
petroleum refineries; plants handling small volumes of hazardous polluting
substances, for example metal plating; and plants handling a multiplicity
of substances. In other studies we had developed inventories of major
transport, transfer, and storage facilities for hazardous polluting sub-
stances at four geographical locations in the United States: Texas City,
Texas; Baltimore, Maryland; Charleston, West Virginia; and San Pablo Bay
and Suison Bay, California.f24,25] Inasmuch as these areas had been
surveyed rather thoroughly, we selected additional sites to survey
practices and procedures in order to complement the earlier work: Nex^r
York - New Jersey, Houston, Texas, Los Angeles and San Francisco, and
Illinois - Michigan.
Using our experience in process design and project management and
the experience of our past surveys, we established an outline of the
pertinent questions to ask and the types of observations to be made.
(See Appendix E.) We also discussed with process design and construction
companies (architect-engineering firms) the spill control procedures they
incorporate in their designs. We visited a number of local and state
regulatory groups, as well as the Environmental Protection Agency Regional
staff, and discussed the need for additional regulations as envisioned by
these groups.
In our survey and discussion program we contacted 37 companies and
organizations. At many of the individual facilities, we observed several
different operations or manufacturing processes; for example, bulk oil
storage and distribution was often a part of an oil refinery storage and
complex at which site petrochemicals were also being manufactured. The
surveyed facilities cannot be separated easily into concise categories
because of the complexity of the process operations, the number of loca-
tions at which hazardous polluting substances were handled, and the number
of these substances. Consequently, we have listed the number of facilities
and groups under eight general categories (Table 14). However, the total
is greater than the number of visits because of the multiple operations
that were often found.
As we visited the plants and analyzed and compiled the data obtained,
it became clear that the results could be presented and summarized in
at least three ways: by type of industry; by type of prevention approach—
design criteria, procedures, equipment, etc.; and by "unit operations"—
storage, transfer processing, etc. Of the three, we selected the last.
The first method would present information from only a few sources thought
to be representative of large industrial sectors. It could easily lead
49
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TAW.K 14
I'Aai.rnrs, ACKNCIKS AND OUCANI/ATION:; vismn IN nn.n SURVEY
Bulk
Oil Oil
Plant
Storage Refinery UeslRners
and Storage Rubber and
Distri- and Petro- or Metal Regulatory Con-
bution Complex QirMnlcjl Chemical Plastics Products Agencies structors
Y
Badp.cr Company, Inc.
StoiH' ami Webster Lngincerlng Corp.
The Lummus Company
Fluor Corporation
Bechtel Corporation X
Texas Water QualHy Board x
Trx;is Railroad Commission x
California State iJalcr Control Board x
California Fish & C^rae x
EPA— F.dison Lab x
EPA--Pacific Divlsic-n x
Louisiana Wildlife i Fisheries Cora. x
Metropolitan San. Ulst. of Chicago x
Coodyoar Chemical Company X X
Ethyl Corporation X X
Atlantic Richfield Ompany XX X
Shell Chemical Company X X
Mobil Oil Corporntic.i X X
General Motors Corpr-ration X
Dow Chemical Company X
Union Oil Company X X
Proctor and Gamble Company X
U. S. Steel Corporation X
General American Transportation Corp. X
Standard Oil Company of California X . X X
Hercules, Inc. X
Curliss-WrJght Corporation X
Amcrad.1 Hess Corporation X X
Humble Oil and Refining Company (2 loca- XX X
Humble Oil and Refining Company tlons) X X
Stauffer Chemical Company X
The Upjohn Company X
Enjay Chemical Company XXX
U. S. Industrial Chemicals Company X
Olin Corporation—Agricultural Division X
Du Pont Company X X
TOTAL 87 7 12 238 5
50
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to repetition because many prevention methods are similar throughout
Industry. In the second, we would fare the Inherent dirfieultv of trying
to decide whether a "prevention practice" is a design criterion, equipment,
or a procedure. For example, is the use of a dike with a closed drain
valve around an oil tank a design criterion or an example of equipment;
is the practice of closing the valve an operational procedure?
We found that the industrial facilities we visited could be readily
classified into unit operations: storage, transfer, loading and unloading,
processing, and waste treatment. Each type of unit operation has basic
elements or spill prevention techniques regardless of the type of facility
or products handled. Thus we have summarized the results of our surveys
in terms of these operations even though the details of practices used
at each facility were expected to differ. Finally we have combined the
results of this survey with those obtained in earlier investigations to
obtain a better overview of the spill prevention measures presently used
by industry.
B. SURVEY RESULTS
The results of the field survey are presented in a series of tables
given in Appendix F. Each table in Appendix F lists the major design
criteria, operating procedures, and equipment used at each facility for
the prevention of spills of oil and other hazardous materials. In some
facilities, it was not difficult to determine the principal practices
used; in others, the concern of the plant management for outside visitors
or the proprietary nature of the operations may have prevented full dis-
closure of all the measures used. Also, we found that in some facilities
equipment and procedures which could be used to prevent spills were con-
sidered routine and not specifically mentioned by the facility personnel.
Thus, these tables are not totally complete. Of course, one would expect
a considerable variation of methods and equipment because of the diversity
of types, locations, ages of the facilities visited, and the different
processes and hazardous materials used.
In order to make a more comprehensive presentation of the results of
the plant visits, we have summarized in tabular form the principal design
criteria, equipment, and procedures we observed in each operational area—
storage, transfer, loading and unloading, processing and waste treatment.
The tables show the number of facilities in which we observed each practice;
this provides an indication of the acceptance of this practice by industry.
The number should not be regarded as precise, but shows the relative use
of the different practices. A brief discussion of the practices is also
given. Another table is given to summarize "management procedures" which
plant management personnel thought were effective in preventing spills of
oil and hazardous materials.
51
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1. Storage
Table 15 summarizes the major practices for spill prevention In
storage areas. In addition to these, at least one facility used each of
the following practices:
• Log of condition of valves on all tanks and dikes
• Impermeable membranes around tanks
• No bottom pipe connections in tanks
(load and unload from top entry pipes)
• Gravity loading of tanks
We note that none of these procedures is fail safe by itself; a combin-
ation of design criteria, procedures and equipment is required.
a. Spill Prevention
Because storage tanks have a very long service life, most
facility operators inspect tanks for corrosion and weakening by
nondestructive and destructive testing methods. Visual inspec-
tion from the outside of the tank is often coupled with other
routine maintenance, such as painting, but unfortunately is
not regularly scheduled in most facilities. Ultrasonics is a
good, but very time consuming and tedious means of determining
the wall thickness of a tank non-destructively. This method is
applicable to an empty or filled tank but normally is used for
spot checks rather than to scan the entire area of the tank.
Although diligent inspection can prevent a corrosion-induced
tank rupture, a tank may fail because of the pressure differential
created between the inside and outside when the tank is emptying
and the vent becomes clogged. This kind of catastrophic spill
event can be prevented by simple maintenance and inspection of
vents and vent lines on storage tanks, to insure that they are
open, and also by monitoring pressure in the vapor space at the
top of these tanks. The vapor space pressure was not measured
in any of the facilities we visited; however, a low pressure
alarm system could prevent the occurrence of this infrequent,
but catastrophic spill event.
Spills resulting from overfilling a tank can be avoided with a
gauging system that displays or indicates the instantaneous
liquid level in the tank—such information is acted upon by the
personnel charged with controlling the operations of the storage
facility. However, these types of level indicators and associated
transmission and read-out instrumentation were found not to be
used frequently because of malfunctions. A more universal pro-
cedure was for plant personnel once each day to measure the
liquid level in each tank by means of a dipstick. Plant opera-
tors believe this kind of activity not only prevents accidental
52
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PRACTICE
Dikes, fire walls, or earthen
barriers around tanks
Drainage ditches and graded
surfaces surrounding tanks
Manual gauging of storage tanks
at regular intervals
Separate drainage
diked tanks
>,vstem for
Planned inspection o£ all tanks,
dikes and equipment in storage
area at regular ±nfervals
Automatic level garging in
tanks; or gauging manifolds
Automatic high and low level
alarms (or pressure alarms) for
storage tanks
Specified procedures for removal
of rain water from diked areas
Locked or sealed valves on drain
lines in diked areas
No drain lines in diked area;
sumps and pump out systems used
Equipment (trucks) available
(mandatory) during tank cleaning
Written procedures followed in
transferring to or from all
storage tanks
Spare tanks or catch basins
specifically designated for e
storage tank
Specific overflow lines from
storage tanks to sumps or catch
basins with alarms
Tank contents analysed before
transfer
TABLE 15
Sl'MMARY OF SPI1.I. PRFVKOTION PRACTICES
IN STORAGE AREAS
TYPE
Design criteria,
equipment
NUMBER OF
FACILITIES*
21
Design criteria 7
Procedure 7
Design criteria 6
Procedure 5
Equipment
Equipment
Procedure
Procedure
Design criteria
equipment
Equipment
Procedure
Procedure
Procedure
Design Criteria
Design Criteria
Equipment
Procedure
REMARKS
Usually required by fire codes; may
be used only for flammable or hazardous
materials
Ditches may be part of the storra water
sewer or process sewer systems
Dip sticks used as positive level
measure; often prior to and after transfer
Any spills in and around diked area can
be diverted to retention ponds or other
facilities without overloading waste
treatment facilities
Frequently a written inspection plan
by maintenance staff to examine area
for potential failure points
Measurement system to display tank
contents to operator in central location
Most alarms indicated in central control
rooms or supervisory locations which
are manned 24 hours/day
Insures that dike valves are normally
closed and prevents spills from emptying
Into vaste treatment stream
Prevents spills from leaving diked area
Both rainwater and spilled material must
be pumped to treatment area
Prevent release of sludge or waste, and
reduce waste runoff during next rain
Other facilities had procedures for
special situations or materials
These could be used in emergency
situations
Provides both indication of overfilled
tank and prevents loss of material
Basically a safety measure to prevent
mixing hazardous materials and loss
of product quality
* A total of 23 facilities were visited.
53
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overfill but also helps to detect a leak which might go unnoticed
during the normal routine. The measurement also detects errors
in or malfunctioning of instrumentation and control equipment
used to operate the tank farm facility. Level alarms on tanks
were not observed often in our survey, apparently because of
questionable reliability of these systems. Two of the five
architect-engineer firms we visited recommended automatic
gauging or alarms.
Storage tanks used for crude petroleum and certain other
organic intermediate and refined products collect a heavy thick
sludge on the tank floor and must be drained periodically and
cleaned. Several facilities we visited have well established
procedures for the cleaning process, including the use of vacuum
trucks for removal and precautions to insure that any excess
spilled material will remain in the diked area or be treated
effectively in a waste handling system.
b. Spill Detection
The only effective way of detecting spills in storage tank
areas reported in our survey is planned visual inspection by
the operating personnel frequenting the area. Discussions with
architect-engineering firms, and with several companies in the
chemical processing industries indicate that good design in
storage tank farm facilities includes the strategic location
of one or more instruments or controls which require the
periodic checking and data recording by plant personnel. These
controls are deliberately located in such a way that plant
personnel must periodically traverse the storage tank farm area
and thus help insure rapid visual detection of leaks. This is
a good example of current state of the art, where good design
practice is short of total automatic data acquisition and
transmittal and process control, and where the human element
deliberately included as a "fail-safe" aspect.
The larger and more modern storage tank farm facilities are now
being designed with sensing devices such as liquid-level
detectors in all of the tanks, with data transmission systems
connected to a central control room. A computer can keep track
of an instantaneous inventory and material balance and show any
spill of sizable proportions as an unaccountable loss. Although
the computer system is used primarily for inventory control, the
potential for spill detection is inherent in the system. One of
the facilities we visited was in the process of installing such
a system. Another plant was considering the use of closed circuit
T.V. to help detect spills in storage areas.
54
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c. Spill Control
Insurance, safety, and fire codes typically require that above-
ground storage tanks used for flammable liquids be surrounded
by a fire wall or dike sufficiently high (with some maximum height
normally specified) to contain at least 100% of the maximum
storable or usable tank volume. Fortunately these dikes also
provide the primary means of spill control in storage areas.
In almost all of the facilities we visited, tanks containing
oil were diked. Those containing flammable organics were also
diked, but those containing inorganic materials were usually
not diked, even if their contents were hazardous.
Dikes are usually penetrated by one or two drainage lines
equipped with shutoff valves on the outside of the dike or
fire wall. These valves should normally be closed, so that
spills and contaminated rainwater do not flow into undesirable
channels. Inspection, valve locks, seals and other means were
used in several facilities to assure this does not happen.
Another approach used in a few small facilities was a sump
and pump operation to drain dikes, thus precluding gravity flow
of spilled material. After a heavy rainfall, plant personnel
normally inspect the rainwater contained in each dike for
evidence of contamination. Several facilities had detailed
procedures for sequentially discharging rainwater after inspection.
In most facilities, if the water appeared clean it was sent
directly to clean-water discharge from the plant. In several
facilities, the discharge from diked areas was routinely sent to
the waste treatment facility, a more conservative and fail-safe
approach.
Dikes or fire walls can be very effective means for controlling
small spills or leaks from storage tanks. However, the normal
dikes or fire walls used today have been totally ineffective in
containing some major and catastrophic leaks from large storage
tanks which resulted in the generation of a large high-velocity
jet of liquid issuing from the side wall of the tank. Such
spills have been known to rapidly wash out a dike at which it
was directed and render the dike ineffective. Also the high level
of kinetic energy associated with a large jet of liquid issuing
from the side of a storage tank has been known to cause a jet
of liquid to simply wash over the top of a dike, since dikes
are designed to restrain and confine a gradually deepening pool
of liquid rather than a stream of liquid moving a high velocity.
Evidence is now accumulating that dikes require more engineering
consideration due to their failure to withstand shock loading.
Reinforcement and overhang design should aid in controlling dike
failures.
55
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A backup control system found In about one1-fourth of tin1
faculties we visited was to u.se drainage ditches around the
storage area which were either (1) separate from the remainder
of the plant or (2) formed a part of the chemical waste disposal
system. Thus any leaks from the storage area, or leaks through
valves in dikes, would be conveyed to a waste treatment facility
rather than discharged with storm water.
2. Transfer
Table 16 summarizes the major practices for spill prevention in the
transfer process. (As noted in the Introduction, we have defined transfer
as the piping between storage and process areas, and related pumps, etc.
Other practices are given later which are more specific to loading and
unloading areas.) In addition to these, one or two facilities used the
following:
* Flange bonnets on all pipeline flanges
to Samples analyzed prior to transfer in line
f> Planned attempt to reduce the number of flanges in pipelines
• Low pressure shut off in pipelines
Two of the architect-engineering firms visited recommended above grade
piping throughout the plant with appropriate drainage system underneath.
All of the architect-engineering firms visited recommended welded piping
systems for both process and transfer areas to help reduce leaks from
flanges.
a. Spill Prevention
Management personnel of the facilities we visited indicated that
preventive maintenance is a necessary and most effective means
of preventing spills from failure of pipes, pumps, valves, and
other components. The proximity of a large number of pipelines
running a parallel course on common supporting structures
greatly facilitates routine painting and inspection programs.
Surveillance by plant personnel is generally intensified on
those pipe transfer systems whose color code indicates that
they carry the more hazardous liquids. Therefore, the visual
examination of pipelines is probably increased in direct propor-
tion to the hazard of the liquid being transferred. Another
form of preventive maintenance found useful to some plant
operators is routine inspection and periodic replacement of com-
ponents which past operating practice has indicated have a limited
service life—for example, valve seals and shaft seals on pumps,
which wear out with a rather predictable frequency. Use of
welded pipe joints rather than flanges helps eliminate part of
this problem.
56
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TAB1.K 1(>
SUMMARY OF SIM I.I. I'KI-VliNTION PRACTICES
IN TRANS]-ER ARK\K
PRACTICE TYPE
Planned periodic inspection of all
pipelines, combined with preventive Procedure
maintenance
All pipelines located above- grade
to facilitate inspection and Idonli- Design criteria
flcation of leaks
Concrete ditcher »:nder pipelines,
lead to chemical vaste system or Design criteria
waste water syr.ttr;,
Vlant procedures require operators
to walk pipelines on daily basis for Procedure
inspection
Pressure relief valves in portions
of pipeline Equipment
Written procedures for pipeline
transfer Procedure
Leak detection n>rtcr. usinR
computer monitored flow meters and Equipment
tank level indicators
Check valves and storage tanks
at ends of pipelines specifically Equipment
for spill prevention and control
Cathodic protection system for
underground pipelines Design criteria
*A total of 23 facilities were visited
NUMBER OF
FACILITIES*
REMARKS
Most inspections include some hydro-
static pressure tests or ultrasonic
tests
Generally found in newer facilities
In mcst cases, these act to drain plant
area as well as conduct any spills to
treatment area
Strategic placement of valves, meters,
etc. require operator to survey pipeline
These were not fail-safe measures in
themselves, but valve opened to channel
which led to waste treatment facility
Also, telephone procedures for several
plants with long pipelines or inter-
plant pipelines
These systems were found in large
refinery operations
Most likely oiany facilities used cathodic
protection but only 2 indicated that it
vas a spill prevention measure
57
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Another prevention practice we observed in several facilities
is the use of seals on valve handles which normally should remain
in some particular position. Any movement of the valve handle
breaks the seal and alerts operating and maintenance personnel
that the valve is no longer in the desired position.
Several plants use written procedures for transfer of fluids by
pipeline. This practice seems to be becoming more standard.
b. Spill Detection
Simple visual inspection is the most commonly used means of
detecting spills associated with transfer of liquids. Plant
personnel frequently travel along and under the pipe racks.
Pipeways are often laid out not only so personnel can easily
inspect them but also so personnel must frequently pass the
pipeways on their way to perform other unrelated tasks. This
practice increases the exposure of plant personnel to the
actual physical transfer pipeline facilities.
Unfortunately, newer and highly automated production plants
are designed to be staffed by a minimum of personnel. It is
not uncommon for a large, highly automated chemical plant to be
operated by five to ten operating personnel who spend a large
part of their time in a central control room. Therefore, an
accidental event such as the rupture of a pipeline might be
detectable only through data transmitted to and displayed within
the control room—drop in pressure or a change in flow rate for
example. Only a few of the plants we visited had enough monitor-
ing equipment for routine detection of pipeline spills from
control rooms.
Classical inventory control permits detection of spills in some
plants. The more refined, accurate, and frequent the inventory
balances, the more quickly a spill can be detected, and the more
sensitive the technique is to detecting even smaller spills.
The availability of large and effective digital computer systems
to industry has made possible the means for maintaining almost
continuous and very close surveillance of the flow rates of
liquid into and out of all the active pipelines at a large
chemical-processing plant. Two of the plants we visited have
installed such systems, several others were considering
developing this kind of system capability. The primary purpose
for this kind of inventory control system is to optimize the
utilization of production facilities and the scheduling and
movement of liquids and various bulk carriers to and from the
plant. A direct "spin-off" of this kind of monitoring and
surveillance system, however, is the potential for detection
of spills.
58
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A simple, yet apparently effective, approach that we found used
in several plants and considered in others is a pressure-sensing
device and associated system to actuate automatic valves and seal
the pipeline at strategic points to minimize Hie total spill.
c. Spill Control
In addition to the strategic location of manual or automatically
actuated valves along pipelines, the most commonly accepted
practice for control of spills from piping is to place a concrete
or hard surface ditch under pipeline racks. The ditches normally
drain rainwater to storm water disposal systems, but are usually
arranged so that a spill from a pipeline, once detected, can be
diverted to a chemical or oil waste disposal system or an impounding
area. In locations where ditches or gutters are not suitable,
graded hard surfaced areas are frequently used to direct any
spilled material into chemical or storm water sewers. Many
pumping areas are curbed and graded to help contain chronic leaks
or spills and direct them to a waste treatment facility.
3. Loading and Unloading
Table 17 lists the principal p-ractices used at loading and unloading
areas. In addition, the following were used in one or more facilities.
Cargo sampling before loading and unloading
Remote pump shut down capability
Shut off valves upstream and downstream of pumps
Different types of couplings for different fluids
Gravity overflow lines to sump or spare tank
Excess flow valves (to shut off flow if limits were exceeded)
Routine valve check before and after loading operations
Because of the apparently high potential for spills, and high spill
incidence, in loading and unloading areas, the number of different tech-
niques to prevent, detect and control spills is large. Most plant oper-
ators believe that spills are frequent during loading and unloading because:
1. Each move of liquid involves one or more temporary pipe
and/or hose connections to be made.
2. This functional area is highly labor intensive, and thus
very susceptible to human error.
3. Loading hoses, loading arms, and other pieces of equipment
in this area are subject to severe use and therefore have
a high propensity to wear and/or be damaged.
59
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TABLE 17
SIW1ARY OF SPILL PKCTKNTION PRACTICES HSKI>
IN LOADING ASM) ('^LOADING AREAS
TtVY_
Curbing, gutters, or ditches around Design criteria
loading and unloading areas
Collection sump with pump and/or Design criteria,
oil separator in each loading/ Equipment
unloading area
Hard surfaced loading and Design criteria
unloading area
Articulated swivel joint loading Equipment
arras or rigid connectors for
loading
Loading areas sloped and graded Design criteria
toward sumps or chemical process
sewers
Standard procedure^ for draining Procedure
fill lines (gravity drain, bjow
back etc.)
Written procedures and check Procedure
sheets for loading/unloading
operations
Weighing of tank cars, trucks, Equipment,
or tanks with autot.'>.tic shut off Procedure
at preset levels
Drip pans, scupper plugs, etc. Equipment,
used during vessel unloading and Procedure
loading
Neutralization tanks locally Equipment
available for spills during loading
and unloading
Company purchased booms available Equipment
Level jlarms on tankage used in Equipment
loading and unloading
Seals on normally closed valves Equipment,
nt loading site Procedure
Testing and certification of Procedure
hoses at scheduled intervals
Clean up truck on site during Equipment
loading operation
Gravity flow during loading and Design criteria
unloading
NUMBER 0V
KAC.VUT1KS*
11
RKMARK_S
System used depended on apt? oi plant
and layout of loading/unloading area
Used with hard surfaced, graded and
curbed loading areas.
Plants installing new equipment preferrs
this over flexible hoses
Used primarily in terminal operations
Several additional plants had written
procedures for materials thought to be
especially hazardous
Meter loading of tank cars was practic
at two other plants
Only found in oil unloading operations
Used in facilities with acid and caustic
tanks at loading sites
These were on site ready to be deployed
Mainly for large transfer hoses for oil
Oil loading only
Gravity flow for first half hour or hour
to check for leaks
* Total number of facilities visited was 23
60
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4. There, is a high potential for poor communications between
those on both ends of a move, for example, the terminal
operators onshore and the crew on a vessel.
5. The temporary connections often are suspended directly
over or close to waterways. Therefore, the difficulty in
controlling a potential spill is maximized.
Our survey indicated that the more hazardous the nature of the
liquid being handled at the loading and unloading facility, the more
likely that various safety codes and regulations will have the indirect
benefit of reducing the spill potential.
a. Spill Prevention
The most frequently used prevention measure was the increased
use of articulated swivel joint arms at loading sites. Plant
operators believed that the use of metal loading arms signi-
ficantly reduce accidents, particularly in ship and tank car
loading. At most of the facilities we visited, we were
informed that new installations would use articulated arms
rather than hoses.
The increased use of strict written procedures for implementing
all loading practices—such as making connections, testing for
leaks, using gravity flow for initial loading with the second
round of leak checks, turning the loading pumps on and making
a third round of leak checks, draining or blowing out the
residual liquid from the loading hoses or loading arm after
the liquid transfer is made, etc.—was felt to be the most
important practical method of preventing spills. Examples of
specific procedures are given in Appendix G.
Good communications between the shore and any ship or vessel
being loaded or unloaded were thought to be critical. The
persons in charge of the onshore facilities and the ship end
of the transfer must be able to communicate fluently in a common
language.
Automatic shutoff in loading operations were not used as fre-
quently as we expected. Most shutoff devices consisted of an
automatic shutoff valve actuated by a pre-set control meter or
scale. These were used to stop loading after the tank car or
tank truck had been loaded to almost maximum capacity, say 95%
of the fill. The remaining 5% would be added manually. Since
only a few percent of the total fill need be monitored by an
operator, the attention span demanded of the operator was short
and there should be less risk of an overfill.
61
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Although no I spec I I leall v expressed hv manv operators, we
believe that prevenlntIvo maintenance. Inspection of hoses.
valves, pumps, Baskets, etc. Is an Important spill prevention
practice and shouJd be placed on a more rigorous schedule.
b. Spill Detection
The principal and almost exclusive method of spill detection in
loading and unloading is by visual observation of the operating
personnel. Rigorous requirements for operating personnel being
present during all phases of the operation is perhaps the most
valid method used today for spill detection.
c. Spill Control
The most common and useful spill control measures used were
curbing or ditches around loading areas and pitched, hard sur-
faced areas leading to sumps or chemical process drains. More
than half of the plants visited used one or more of these methods.
Procedures for drainage of lines or blow back into vessels also
was used frequently. We found that booms were also used as a
control measure; they were not typically deployed until some
spill had occurred. Drip pans and other catchment devices were
used to control minor leaks, but were not used as a prime pre-
ventive or control measure.
4. Process Areas
Table 18 summarizes the major practices used in process areas. Many
of these are similar to those used in loading and unloading and storage
areas (for example, many tanks in process areas are diked). In addition,
the following practices were used In one or more facilities:
No bottom connections on tanks
Overflow lines to process sewers
Cooling towers replace once through process water
Operator on duty 24 hours/day in process area
Total elimination of drains in process area
Automatic level indicators in process tanks
a. Spill Prevention
In addition to the specific prevention methods listed in Table
18— primarily level alarms, locked valves, inspection procedures,
elimination of bottom connections—we found several general
practices are used in the process area for purposes other than
spill prevention, which plant personnel believe have an important
impact on spill prevention.
1. Equipment design and specification—general adherence to
established construction codes and recommended design
62
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TABLE 18
SUMMARY OF SPILL PREVENTION PRACTICES USED IS PROCESS ARFAS
NUMBKR OF
PRACTICE TYPE FACILITIES*
Concrete or other hard surface Deaiiin criteria 12
under process area
Curbing around process areas Design criteria 11
Graded surfaces with ditches or Design criteria 10
chemical sewers around process
areas
Separate process and storm water Design criteria 7
sewers in process area
Sumps or holding basins located in Design criteria 6
process areas
Level or pressure alarms on process Equipment 5
tanks
Neutralization i*nks at Individual Design criteria 4
process sites
Oil skinaners oc separators at Design criteria 4
process sites equipment
Separate collection (sewer) system Design criteria 4
for especially hazardous materials
Monitor;' ,g of process waste water Equipment 4
for evi -rce of. spills at process
site
Procedures for directing Initial Procedure 3
rainfall in process area to waste
treatment system
Scheduled Inspection of all process Procedure 3
area spill prevention measures
Written procedures for process Procedure 2
operation
Sampling procedures planned to Procedure 2
minimize spills
Locked or sealed valves in process Equipment 3
area
practice bv toui' »'t i"ivo
arohitect/eny, Imvr (np, t' Inns
Recommended by all architect/engineering
firms visited
Spills must be directed to process
sewers
Fluids pumped to waste treatment area
Specifically used for spill prevention,
not process control
Found in facilities handling large quanti*
of acids and alkalis
Reaiove oil before spilled fluid enters
waste treatment system
Aids detection of spills and spill
location
In addition to normal preventive
maintenance
Specifically mentioned as a spill
prevention measure
Saopling of process streams
* A total of 23 facilities were visited
63
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practices to insure physical integrity of the process
system has the secondary effect of preventing spills.
2. Process control procedures and equipment—use of pressure,
temperature, flow, level and composition detection and
control systems, planned for maintaining product quality
and controlling throughput, have a secondary effect of
preventing spills.
3. Operational procedures—most process operations have written
or carefully planned operational procedures to maintain
product quality and production rate. Such procedures can
and sometimes do include spill prevention measures as a
spin off.
4. Preventive maintenance—as in other plant areas, preventive
maintenance to maintain production can help in elimination
of potential spill causes.
b- Spill Detection
Although visual inspection for spills and leaks is the most
common method of spill detection, small spills and leaks—e.g.,
from pump seals, valve packing, flange connections, rivets and
seams easily go undetected. Plant personnel admit that appro-
priate action is often not taken to control these leaks.
Unfortunately, this usually stems from a lackadaisical attitude
on the part of operating personnel, poor housekeeping habits,
and a failure to comprehend the possible catastrophic effects of
even a few pounds of some hazardous polluting substances on the
aquatic environment. The value of visual detection is increased
greatly by a well directed and enforced spill prevention program.
Plant personnel believe that leaks and spills can also be detected
by means of alarms located within the process system. The most
valuable and most frequently usable in-process alarms are based
on instruments that measure flow, pressure, or level of substances
in the process system. Most of this instrumentation is based
on measuring and controlling a dynamic system and often initiates
corrective action which may control or limit the spillage. These
systems are most useful in detecting the likely onset of a large-
volume spill due to catastrophic accidents; however, small leaks
and spills are probably not detectable or alarmable.
Alarms which are independent of the process system are utilized
principally to detect materials hazardous to personnel or property
such as high concentrations of hydrocarbon vapors. These
detectors usually initiate a combatant action, such as foam
blanketing an area where high concentrations of explosive
64
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hydrocarbons are detected, or Initiating water deluges us tire
protection. Such action may be useful from the personnel
hazard view but incorrect from the environmental protection
view.
The most common process area instrumentation for spill detection
is installed in the process area's drainage systems, such as
process and storm sewers. These include pH, hydrocarbon, TOG,
TOD indicators. Large maintenance costs and poor reliability
of these instruments are the principal reason for their present
limited use;
c. Spill Control
The most commonly used methods for controlling spilled substances
in process areas is the installation of graded hard surfaces,
passive barriers, collecting sewers, or surface drains, which
will prevent the substances from entering water courses. In-
stallation of curbed areas around processing equipment and
catch pans and basins under areas where chronic leaks are
expected, e.g., under pumps, is most often practiced. Drains
from the processing areas are generally segregated from storm
water sewers. Catch basins or sumps are frequently located
within the process area. Several plants have specific sewage
systems for very hazardous materials, separate from other
chemical waste and storm water. Several facility operators
indicated that a more formalized spill control plan for the
process area would be the most important addition to current
practices.
Methods for controlling spills and leaks in a processing area
depend greatly on the age of the facility. In new plants,
separate process area and land drainage sewers can be readily
provided and are recommended by architect/engineers. However,
such provisions would be very expensive for old plants. These
costs would be analogous to the costs for separating sanitary
and storm water sewers in many of our older cities. Consequently,
many older processing plants must consider alternate methods
for the control or rapid removal of spilled substances, for
example, providing secondary containment barriers near the points
at which there is a high potential for spills and leaks, providing
local sumps for spilled fluids, etc. An alternative is to enclose
the process area while maintaining fire and safety measures.
5. Waste Treatment 'and Disposal
The waste treatment and disposal system of an industrial facility
can be a spill prevention and control measure in itself. Although we did
not examine waste treatment facilities from the view of the quality of
the effluent discharge in our field survey, we attempted to obtain
65
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information on the methods by which the operation of the waste treatment
system help prevent spills from entering the water environment. Table 1.9
summarizes the principal practices associated with waste treatment which
are related to spill prevention and control. In addition, the following
practices were used at one or more facilities:
• Hourly inspection of oil traps and skimmers
• Only specific employees permitted to discharge any water
• Membrane liners around holding lagoons
• Analysis of water obtained from well points surrounding holding
lagoons
• Waste treatment system operator on duty 24 hours/day
All of the architect/engineers we visited recommended holding
lagoons, separate sewer systems in critical areas for storm water and
process waste (or spills), and effective use of a waste treatment system
as a bac'cup measure for spill prevention and control.
6. Management Practices
Our discussions with facility management and supervisory personnel
during the field survey revealed several types of management practices
which rfere believed to be major factors in the prevention and control
of spills. The following practices were conducted at one or more facilities:
• Employee motivation program aimed at reduction of spills and
keeping oil from entering the water
• Management emphasis on placing responsibility for spills on
individual operators
• Educational program aimed at process unit operators to make
them aware of the consequences of spills and that they have
the ultimate responsibility for spill prevention
• Plant wide spill reporting—emergency communication system
• Formation of an independent pollution control group with
broad authority
• Establishment of company wide pollution control education
programs
• Specific training programs, with emphasis on pollution control,
with written and oral exams to obtain operator status
• Random program of monitoring effluent and waste product streams
in various parts of the process areas to alert operators to the
need for control of chronic spills and leaks
• Requirement for 24 hour/day operator availability in high
potential spill areas
The use, effectiveness and acceptance of these practices were
influenced to a large degree by management desire to preserve water re-
sources as well as to create an acceptable public image.
66
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TABLE 19
WASTE TREATMENT PRACTICES WHICH AID SPILL PREVENTION
PRACTICE
Monitoring of waste system
effluent (pH, BOD, TOD, etc) to
aid in spill det'ction
Separate sewer system for storm
water and process or trade water/
waste
Holding or diversion lagoons, ponds
or tanks for lirge spills
Specific protic'du-e and facilities for
diverting or treating initial
rainfall
Single sewer system and treatment
plant for all plant water—process
runoff, etc.
Centrally located oil separators
and skimmers in storm water and
process water systems
Neutralization facilities centrally
located for all water systems
Separate sewer system and waste
treatment facility for very
hazardous materials
TYPE
Equipment,
procedure
Design criteria
Design criteria
Procedure,
design criteria
Design criteria
Equipment
Design criteria
Design criteria
NUMBER OF
FACILITIES*
12
11
10
REMARKS
tot installed specifically for spill
detection but for effluent quality
Hast have available methods to direct
•pills to process waste system
Same facilities have up to five diversion
lagoons; others have capability of
diverting up to one week process and
rainwater
May also use process and storm water
sewers and diversion ponds
All used water and plant effluent is
bandied by one system
Used in plants which handle large
volumes of oil
Systems generally located at process
areas
A total of 23 facilities were visited
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C. COMPARISON WITH OTHER SURVEYS
In order to make the results of the present survey more useful,
and to include a larger and more diversified data base, we have re-examined
the results of several other plant surveys made in Boston, New York,
Baltimore, Charleston, W. Va., Texas City, Los Angeles, San Francisco,
and Houston by our staff for the Environmental Protection Agency and
others. The facilities visited, 107 in total, varied from small repack-
aging or formulating plants handling relatively small volumes (hundreds
of gal.lons) to petroleum and petrochemical companies processing or
storing hundreds of millions of gallons.
In summarizing observations of our survey teams, we found that a
very !<>ng list of methods, equipment, and procedures would be required
to describe all plants at all locations. The selection of the techniques
encountered most frequently also must have a certain degree of subjectivity
based on our experiences and observations. Furthermore, we could not be
sure tna: all methods, equipment and procedures were reported to us in
these -/ioits. Nevertheless, we found the following spill prevention
practice:, were used most frequently.
1, Diked areas around storage tanks. For flammable substances
these are required; however, as a passive barrier to tank
rupture, and tank and pipe connection leaks, a diked tank
storage area is considered the first line barrier to contain-
ing and reducing the spread of large volume spills.
2. Tank level indicators and alarms. The sounding of alarms at
prescribed levels during tank filling was expected by plant
personnel to minimize the common occurrence of overflow
when reliance is on manual gauging for control.
3. Above ground transfer lines. Above ground installation
permits rapid detection of pipeline failures and if used
with hard surfaced ditches underneath, minimizes polluting
ground waters. Although increasing the possible mobility
into surface waters, long term considerations are believed
to favor above ground transfer lines.
4. Curbed process areas. Spills from processing equipment must
often be removed rapidly from the area but should be prevented
from spreading widely in the immediate area, consequently,
curbed areas connected to collecting sewers are used.
5. Area catchment basins orjlop tanks. For containment of small
spills and leaks in the immediate area thereby effecting removal
at the highest concentrations, local catchment basins can
provide significant flexibility in preventing spills from
entering water courses.
68
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6> Holding lagoons for general plant_area. Holding lagoons, which
can be used to segregate spills and prevent them from passing
into wastewater treatment plant or water courses, give the
surge capabilities necessary for handling large volume or highly
toxic spills.
1' Primary wastewater treatment. For removal of floating sub-
stances or for the chemical neutralization or destruction of
spilled materials, the primary wastewater treatment plants
serve to ameliorate the more drastic effects of spills in
receiving waters.
8- .Secondary wastewater treatment. The removal of soluable sub-
stances usually through biological action, where possible,
can insure that the plant wastewater discharges have a high
degree of uniformity at acceptable quality regardless of
in-plant variations such as would occur from spills.
9, Availability of spill cleanup equipment. Vacuum trucks,
booms, neutralizing chemicals, etc. represent obvious con-
tingency planning to cope with spills.
10. Routine preventative maintenance schedules. Because literature
sources and plant staff indicated that the cause of many fires
and spills in the chemical industry could be traced to failures
that might have been avoided by a thorough preventative
maintenance program, it was recognized that this program could
be an indicator of the possible reduction in spill potential.
11. Spill control plan. The formalization of a plan for coping
with spills and the training of personnel in courses of
action similar to plant safety programs, was reasoned to be
a prime indicator of the operational possibility of coping
with spills in a manner which would avoid entry into water
courses.
Using the prevention factors outlined above, we have tabulated the
results of 107 plant surveys. In this total number there were 31 plants
which we categorized as chemical plants. The remaining 76 plants included
a broad spectrum of industry except that the surveys of oil refineries
were disproportionately low in comparison to the volume of fluids handled.
This selection was deliberate because the petroleum industry handling
operations are more closely regulated than any other industry. Three
integrated oil refineries and 21 oil terminals or storage areas were
surveyed. Included in our survey were facilities of industries such as
Pharmaceuticals, paper, steel, food, beverages, detergents, paints, waste
processes, rubber, and textiles. The results of these surveys are shown
in Table 20.
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TABLE 20
SUMMARY OF SPILL PREVENTION AND CONTROL PRACTICES AT 107 FACILITIES
Chemical Plants (31)
This Study (231
Practices
Complete Dikec Storage
Tank Farm Level Alarms
Exclusive A'love Ground Transfer Lines
Curbed Process Areas
Process Area Catch Basins
Holding Lagoot.s
Primary Treatment
Secondary Treatment
Spill Cleanup Equipment
Preventative Maintenance Program
Spill Control Plan
LJL. A. * •*•
No.
47
8
12
23
14
18
33
6
17
19
42
Percent
44
8
11
22
13
17
31
6
16
18
39
No.
13
5
7
16
5
13
17
5
1
10
19
Percent
42
16
23
52
16
42
55
16
3
32
61
No.
12
2
8
11
6
10
12
2
3
8
14
Percent
52
9
35
48
26
43
52
9
13
35
60
70
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We note that in general, chemical plants have a higher utilization
of spill prevention and control practices than the average plant. This
is probably caused by the greater number of hazardous materials handled
by these plants and the inherent potential hazard to personnel and
property. In the present study, about one half of the facilities visited
were chemical plants. Therefore in the present survey, the utilization
of practices is closer to those reported for chemical plants than for
the average of all plants, of which only 29% were chemical plants.
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VI. ACKNOWLEDGMENTS
The authors gratefully acknowledge the asistance and cooperation of
many staff members of federal, state and local regulatory agencies and
industrial facilities during this program. We are particularly indebted
to Mr. H. D. Van Cleave of the Division of Oil and Hazardous Materials,
Water Quality Office, of the Environmental Protection Agency for his
support and guidance. Mr. Howard Lamp'l of the Edison Laboratories,
Mr. Anthony Resnick of the California-Nevada Basins Region, Mr. Almo
Manzardo of the Great Lakes Regional Office, and Mr. John Latchford,
Clarence Johnson and William Gross of the Texas Water Quality Board
assisted us in making arrangements for plant visits. The discussions
and comments with Mr. Joseph Teller of the Texas Water Quality Board, and
Mr. Charles Bournes of the Pacific Regional Office, Environmental Pro-
tection Agency, also helped us establish a meaningful field survey.
Finally we are most appreciative of the cooperation and assistance pro-
vided to us by the more than 50 operating facility personnel who devoted
much of their time in frank and helpful discussions of water pollution
prevention methods with us and conducting us on surveys of their
facilities. Cooperation such as this between industry and government
will ultimately be the basis for a valid pollution prevention program.
73
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VII. REFERENCES
[1] Spill Prevention Techniques for Hazardous Polluting Substances,
an Inventory and Survey of Hazardous Chemical Facilities in
Charleston, West Virginia; Baltimore, Maryland; Texas City, Texas;
and the Suisan Bay-Delta area, California; report prepared by
Arthur D. Little, Inc., under Contract 14-12-927 for the Environ-
mental Protection Agency, Water Quality Office, Division of Oil
and Hazardous Materials, February 1971.
[2] The Prevention of Spills of Oil and Chemicals into Baltimore Harbor
and Environs. Report to Maryland Environmental Service, by Arthur
D. Little, Inc., May 1971.
[3] Systems Study of Oil Spill Cleanup Procedures, Vol. I, Analysis
of Oil Spills and Control Materials, The Dillingham Corp., Final
Report to American Petroleum Institute, February 1970.
[4] Proceedings of the Joint Conference on Prevention and Control of
Oil Spills, American Petroleum Institute and the Federal Water
Pollution Control Administration, December 1969.
[5] Abstract of Proceedings of the Hazardous Polluting Substances
Symposium, sponsored by the Department of Transportation, United
States Coast Guard, September 1970.
[6] Federal Water Pollution Control Act as amended by the Federal Water
Pollution Control Act Amendments of 1961, the Water Quality Act
of 1965, the Clean Water Restoration Act of 1966 and the Water
Quality Improvement Act of 1970.
[7] Executive Order 11507 - Prevention, Control and Abatement of Air
and Water Pollution of Federal Facilities, February 4, 1970.
[8] Conservation Division, Branch of Oil and Gas Operations, Pacific
Region, United States Geological Survey,Outer Continental Shelf
Order No. 10, dated May 28, 1969.
[9] Conservation Division, Branch of Oil and Gas Operations, Gulf
Coast Region, United States Geological Survey, Outer Continental
Shelf Order No. 1-10, dated August 28, 1969 and October 30, 1970.
[10] Code of Federal Regulation, Title 30, Mineral Resources, Part 250,
and Title 43, Public Lands, Part 3380.
[11] State of Rhode Island and Providence Plantations, Oil Pollution
Control Rules and Regulations, Rhode Island Department of Health,
effective September 1, 1957.
[12] Division of Water Pollution Control, "Rules for the Prevention and
Control of Oil Pollution in the Waters of the Commonwealth ,
Publication No. 5131, Commonwealth of Massachusetts-
75
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REFERENCES Continued
[13] Water Pollution Control, Subchapter 4, Prevention of Industrial
Waste Pollution, Alaska Health and Welfare Commission, July 28,
1959.
[14] The Stream Control Commission, State of Louisiana, "Rules
Governing Disor.^1 or waste Oil, Oil Field Brine, etc.", as
Amended January 27, 1953, Title 56, Section 1435, Chapter 3
Part 1.
[15] Railroad Commission of Texas, Texas Oil and Gas Conservation
Laws, Title 102, January 1971.
[16] Manufacturing Chemists Association, "Case Histories of Accidents
in the Chemical Industry", Volume 1, 1962, Volume 2, 1966,
Volume 3, 1970.
[17] North Carolina Department of Water and Air Resources, Fifth
Biennial Report, July 1, 1966-June 30, 1968.
[18] State of Rhode Island and Providence Plantations, Department
of Health, Environmental Health Services, Division of Water
Supply and Pollution Control, Report for the 12 Month Period,
July 1, 1968-June 30, 1969.
[19] Livingstone, F. C.,"Combating the Menace of Oil on Rivers",
Water and Sewage Works, February 1971, p. 58.
[20] "Hazard Survey of the Chemical and Allied Industries", Technical
Survey No. 3, American Insurance Association, 1968.
[21] National Fire Code, Volume I, "Flammable Liquids", National
Fire Protection Association, Boston, Massachusetts 1969-1970.
[22] Industrial Oily Waste Control, prepared by the American
Petroleum Institute and American Society of Lubrication
Engineers, 1969.
[23] Crocker, B. B., "Preventing Hazardous Pollution During Plant
Catastrophes", Chemical Engineering, May 4, 1970, p. 97.
[24] Spill Prevention Techniques for Hazardous Polluting Substances,
and Inventory and Survey of Hazardous Chemical Facilities in
Charleston, West Virginia; Baltimore, Maryland; Texas City,
Texas; and the Suisan Bay-Delta area, California; report prepared
by Arthur D. Little, Inc., under Contract 14-12-927 for the
Kuviror .mental Protection Agency, Water Quality Office, Division
DJ.' Oil ana Hazardous :.c.i.erials, February 1971.
[25] The Prevention of Spills of Oil and Chemicals into Baltimore
Harbor and Environs. Report to Maryland Environmental Service,
by Arthur D. Little, Inc., May 1971.
76
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VIII. APPENDICES
Page
A. Associations and Agencies Contacted by Letter 79
Table 1: Technical and Trade Associations
Contacted by Letter 80
Table 2: State and Municipal Agencies
Contacted by Letter 81
B. Rhode Island Oil Pollution Control Rules and Regulations . . 85
C. Selections from "Rules for the Prevention and. Control
of Oil Pollution in the Waters of the Commonwealth of
Massachusetts" 95
D. Selected Regulations of the Texas Railroad Commission .... 101
E. Survey Guide 107
F. Detailed Results of Field Survey 113
G. Typical Procedure (Job Standard) for Transfer
Operation in Chemical Industry - Typical Operating Standard
and Check List for Loading and Discharging of Ships 195
77
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APPENDIX A
ASSOCIATIONS AND AGENCIES CONTACTED BY LETTER
79
-------
TABLE A-l
TECHNICAL AND TRADE ASSOCIATIONS
CONTACTED BY LETTER
REPLY NO REPLY
ASSOCIATION RECEIVED RECEIVED
AIME X
American Association of Oil Well Drilling
Contractors X
American Foundrymens Society X
American Iron and Steel Institute X
American Paper Institute X
American Petroleum Institute X
American Society of Civil Engineers X
Asphalt Institute X
Chemical Specialties Manufacturing Association X
Institute of Paper Chemistry X
Lead Industries Association X
Manufacturing Chemists Association X
Metallurgical Society of AIME X
National Agricultural Chemists Association X
National Canners Association X
National Paint, Varnish and Lacquer Association X
National Petroleum Refiners Association X
Portland Cement Association X
Rubber Manufacturers Association X
Synthetic Organic Chemical Manufacturers Association X
USA Standards Institute X
Western Oil and Gas Association X
Zinc Institute X
80
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TABLE A-2
STATE AND MUNICIPAL
CONTACTED BY LETTER
REPLY RECEIVED
ALABAMA
Water Improvement Commission No
Bureau of Environmental Health No
ALASKA
Department of Health and Welfare Letter forwarded to Department of Environ-
mental Conservation
Department of Environmental Conservation Yes
ARKANSAS
Arkansas Pollution Control Commission Yes
State Department of Health Yes
CALIFORNIA
State Vater Resources Control Board Yes
Department of Public Health Referred to Department of Conservation,
Division of Oil and Gas
Fire Marshall Letter forwarded to State Water Resources
Control Board
Department of Conservation, Division of Oil and Gas Yes
State Wator Resources Control Board Yes
COLORADO
Colorado Department of Health Yes
Fire Marshall No
CONNECTICUT
State Water Resources Commission Yes
State Department of Health No
Fire Marshall No
DELAWARE
Delaware Water and Air Resources Commission Yes
State Board of Health No
Department of Natural Resources and Environmental Control Yes
FLORIDA
Department of Air and Water Pollution Yes
State Board of Health Yes
Department of Natural Resources Yes
State Fire Marshall No
GEORGIA
State Water Quality Control Board No
Department of Public Health Yes
ILLINOIS
State Sanitary Water Board Ko
Department of Public Health Forwarded to Illinois Environmental Pro-
tection Agency
Environmental Protection Agency Yes
Chicago Fire Department Yes
State Fire Marshall No
81
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TABLE A-2 (Continued)
INDIANA
Scream Pollution Control Board
State Board of Health
State Fire Marshall
KANSAS
Kansas State Department of Health
Water Pollution Control Section
Fire Chief
City-County Community Health Department
MARYLAND
REPLY RECEIVED
No
Yes
Yes
No
No
No
No
State Department of Water Resources Yes
Maryland State Department of Health and Mental Hygiene Forwarded to Department of Water Resources
MICHIGAN
Water Resources Commission
Department of Public Health
Fire Marshall
MINNESOTA
Minnesota Pollution Control Agency
Division of Environmental Health
Fire Marshall
NEBRASKA
Nebraska Water Pollution Control Council
Department of Environmental Control
Fire Marshall
NEW JERSEY
State Department of Trl?:alth
Department of Environmental Protection Agency
Water Quality Branch, Delaware River Basin
Fire Marshall
SEW MEXICO
New Mexico Water Quality Control Commission
NEW YORK
Fire Marshall - New York City
Fire Marshall - Buffalo
New York Department of Environmental Conservation
Health Department
New York State Petroleum Council
OHIO
Water Pollution Control Board
Department of Health
Fire Marshall
Yes
Referred to Water Resources Commission
Yes
Yes
No
Yes
Referred to Department •;£ Environmental Control
Yes
Yea
No
Yes
Yes
Yes
No
No
Yes
Yes
No
Yes
No
Yes
Yes
82
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TABLE A-2 (Continued)
REPLY RECEIVED
OKLAHOMA
Department of Health No
Department of Pollution Control Ho
RHODE ISLAM)
Department of Health Yes
Water Supply and Pollution Control No
Fire Marshall No
TENNESSEE
Fire Marshall Yes
Tennessee Stream Pollution Control Board No
Department of Public Health No
VIRGINIA
State Wattr Control Board Yes
Department of Health Yes
Fire Marshall Yes
WASHINGTON
Fire Marshall No
Washington Water Pollution Control Commission Yes
Department of Health So
WEST VIRGINIA
Fire Marshall Yes
Department of Health So
Department of Natural Resources Yes
WISCONSIN
Department of Natural Resources ^es
Department of Health No
NOTE: other states—Pennsylvania, Maine, Massachusetts—were contacted by phone; written information
was received.
83
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APPENDIX B
RHODE ISLAND OIL POLLUTION CONTROL
RULES AND REGULATIONS
85
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fttatr of Ulfo&r inloub mt& Jlrantbrttre JHautnttnuu
OIL POLLUTION CONTROL
RULES AND REGULATIONS
Effective September 1, 1957
Rhode Island Department of Health
State Office Building, Providence, R. I.
1957
86
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Rhode Island Department of Health
RULES AND REGULATIONS
OF THE
Department of Health
To Prevent the Discharge or Escape of Any Petroleum, Gasoline,
Kerosene, Tar, Asphalt, Oil, or Any Product or Mixture Thereof,
into the Waters of the State of Rhode Island
1. As used in these rules and regulations the word "person" shall
be held to mean and include every individual, firm, co-partnership, asso-
ciation, private corporation and municipal corporation, whether acting as
principal, agent or servant, and whether acting personally or by agents or
servants, and these rules and regulations shall apply to each and every
such person.
2. As used in these rules and regulations the term "oil" shall be
held to mean any petroleum, gasoline, kerosene, tar, asphalt, oil, or any
product or mixture thereof.
3. As used in these rules and regulations the term "oil' carrying
vessel" shall be held to mean a vessel equipped to carry more than 5,000
gallons of bulk oil as cargo or as fuel for her own use.
4. No person shall discharge, or cause, suffer or procure to be dis-
charged, or cause or suffer to escape, any liquid waste, including storm
water runoff, or other waste, into any of the waters of the state from any
new oil refinery, new oil storage tank farm, new industry manufacturing
petroleum products, or new industry whose liquid waste or storm water
runoff or other waste may contain oil, placed into operation after these rules
and regulations are established by order, unless plans and specifications and
a description of a system or means to be installed to prevent the escape of
oil which may be present in such liquid waste, storm water runoff or other
waste have been submitted to the Department of Health, and an order of
approval of the same has been entered by said department.
5. No person shall discharge, or cause, suffer or procure to be dis-
charged, or cause or suffer to escape, any oil into any of the waters of
the state; provided however that this rule shall not apply to any waste
waters passed through any oil separating or treatment equipment approved
by the Department of Health, and operated in a manner acceptable to
said department and in conformance with any standards of operation
contained in said department's order of approval.
6. No person shall deposit, or cause, suffer or procure to be de-
posited, any oil in any place on the bank or shore of any of the waters
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of the state or on any wharf or pier in any such waters, where the same
shall be likely to be washed into any of the waters of the state either by
heavy rains, high tides, or storms, except hurricanes, or in any place where
the same shall be likely to be discharged or to escape into any of said
waters.
7. No person shall pump or discharge, or cause, suffer or procure
to be pumped or discharged into any harbor, river, bay, inland waters or
any of the waters of the state, bilge or ballast water from any oil carrying
vessel or from any other ship, barge, tanker, boat or vessel whereby any
oil shall be liable to be discharged or to escape into any of the waters
of the state.
8. No person shall scrape, wash, scrub, scour or swab, or cause, suffer
or procure to be scraped, washed, scrubbed, scoured or swabbed, any part
of any ship, barge, tanker, boat or vessel, or any tank or receptacle thereon,
while such ship, barge, tanker, boat or vessel is in any harbor, river, bay,
or other waters of the state or on any shore thereof or in any dry dock
within the state, or any oil tank or oil receptacle in any place, whereby any
oil shall be liable to be discharged or to escape into any of the waters of
the state.
9. No person shall transfer, or cause, suffer or procure to be trans-
ferred, any bulk oil from any oil carrying vessel to shore, or from shore
to any oil carrying vessel, or ballast or cause, suffer or procure to be
ballasted any oil carrying vessel unless the scuppers of any such vessel are
plugged watertight during the oil transfer or ballasting operation.
10. No person shall transfer, or cause, suffer or procure to be trans-
ferred any bulk oil from any oil carrying vessel to shore or front shore to.
any oil carrying vessel unless the following precautionary measures against
oil spillage into the waters of the state during the transfer have been taken:
a) Any flexible hose used in the transfer which has not been in
regular use shall have been tested at a pressure in excess of that
to which it will be subjected in use, and such test shall be made
within one month previous to such use.
b) Drip pans are placed under hose connections on the oil carrying
vessel, and drip pans or a tight wharf or pier section enclosed
by a curb raised to not less than four inches above the deck level
is provided under the hose connections on the wharf or pier. If
drip pans are used they must be in place before tight blank, as
provided in f) of this rule, is removed and they must remain in
place until blank is replaced and hose is moved. This rule shall
not prevent the instalation of e. drain to a tight curbed wharf or
pier section for the removal of storm water, provided the drain
is tightly closed during any oil transfer and no oil contaminated
drainage from the tight section is discharged into the waters of
the state, when the drain is open.
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c) I loses are supported so as not to become crushed between the
ship and the wharf or pier.
d) Hoses are long enough so that they will not be strained by any
movement of the ship if the ship's mooring lines are adequately
tended.
e) Mooring lines are tended frequently to prevent excessive move-
ment of the ship at the wharf or pier.
f) Hose ends are blanked tightly when hoses are moved into position
to be connected, and also immediately after they are disconnected,
before they are moved away from their connections.
11. No person shall transfer, or cause, suffer or procure to be trans-
ferred bulk oil from any oil carrying vessel to shore or from shore to any
oil carrying vessel unless a man is stationed on the deck of such vessel in
sight of the hose and its vessel connections, and another man stationed on
shore in sight of the hose and its shore connections continuously during
the transfer; provided, however that in the case of the transfer^of oil to
or from an oil barge, one man stationed where he can have a clear view
of both the deck and the dock will suffice.
12. No person shall transfer, or cause, suffer or procure to be trans-
ferred bulk oil from any oil carrying vessel to shore or from shore to any
oil carrying vessel after sunset and before sunrise unless decks and the
wharf or pier area at the point of transfer are brightly illuminated during
the transfer.
13. No person shall transfer, or cause, suffer or procure to be trans-
ferred any bulk oil from any oil carrying vessel to shore unless:
a) All cargo risers not intended for use in the transfer afe blanked.
b) Sea valves connected to the cargo piping, and stern loading con-
nections are tightly closed and sealed with a numbered seal.
c) Lines and valves in the pumprooms and on deck are checked by
the ship's master or senior deck officer to see that they are prop-
erly set for discharging cargo. An additional check is made for
the same purpose each time the setting is changed.
d) Means of communication with shore facilities are checked and
thoroughly understood.
e) Discharging is started slowly until shore lines are proven clear.
f) A check valve to prevent backflow is located in the discharge line
of each oil cargo pump of a centrifugal type; the check valve
shall be located at a point in the discharge line ahead of any
connection the line makes with the discharge line from any other
cargo pump on the vessel.
g) A copy of the "Declaration of Inspection" required by the United
States Coast Guard has been handed to the terminal superinten-
dent or his representative, who shall on demand be given the
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opportunity to satisfy himself that the condition of the vessel is
as stated in the "Declaration of Inspection."
14. No person shall transfer, or cause, suffer or procure to be trans-
ferred any bulk oil from shore to any oil carrying vessel unless:
a) All sea valves connected to the cargo piping, stern discharge, and
ballast discharge valves are closed and sealed with a numbered
seal.
b) All hose riser valves not to be used are closed and blank flanged,
and all air valves on headers are closed.
c) Means of communication between ship and shore are ascertained
and all signals between ship and shore thoroughly understood.
d) Loading is started at a slow rate and an inspection made of the
ship's tanks to determine that all is going according to plan before
loading is increased to desired rate.
e) No more tanks are loaded at one time than can be safely watched
and controlled.
f) Special attention is paid during the topping-off process to the
loading rate, the number of tanks open, the danger of air pockets
and the inspection of tanks already loading.
g) To allow time for orderly control, the slow down for topping-off
is anticipated and notice given to shore personnel.
h) Water around the ship's side is inspected frequently, especially
in the way of the seacocks, to insure that no oil is escaping
overboard.
i) Upon completion of loading, all tank valves and loading valves
are closed. After draining, hoses are disconnected and hose risers
blanked.
15. No person shall ballast, or cause, suffer or procure to be ballasted
any oil carrying vessel unless:
a) The transfer of cargo has been completed and all hose riser valves
have been closed and connections blanked.
b) If ballast is to be pumped in, whether through deck lines or bottom
line; valves on the lines used are set first, then the valves to the
tanks to be ballasted are opened, the necessary valves in the
pumprooms, except seacocks, are set next, and cargo pumps are
started before opening seacocks.
c) If ballasting is done by gravity, ballast is pumped in first for ten
minutes in accordance with the procedure outlined above in b)
to clear all bottom lines of oil.
d) When ballasting is started, all tanks are inspected to see that only
toe tanks intended are receiving ballast.
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e) The same attention is given to ballasting as to topping-off tanks
when loading cargo.
f) When completing the loading of ballast, seacocks are closed before
stopping the pumps.
The provisions of a), b), c), f) of this rule shall not apply to any
vessel whose ballast piping system and ballast pumps are wholly indepen-
dent and not connected to the cargo system,
16. No person shall discharge, suffer or procure to be discharged,
the exhaust steam from any coil or other device used to heat oil, into
the water of the state or into any public sewer or storm drain, or into
any private drain which empties into any of the waters of the state or onto
the banks of any of these waters unless such exhaust steam is first passed
through an oil removal system approved by the Department of Health.
17. No person shall discharge the drainage from any Underground
pipe gallery used as a conduit for oil pipes, or the drainage frpm the floor
of any boiler room where oil burning equipment is located, into a public
sewer or storm drain or into the waters of the state or onto the banks of
these waters without first passing the drainage through an oil removal
sysem approved by the Department of Health. This rule shall apply only
to the drainage from business and industrial establishments.
13. No person maintaining a dike around an oil storage tank shall
have any openings in such dike that will permit the escape of drainage
from behind the dike into any sewer or drain or into the waters of the
state.
An opening such as a pipe provides, may be placed in the dike provided
it is kept closed at all times except for periods, no longer than are necessary,
to remove accumulated drainage. When it is necessary to remove such
drainage it shall be passed thru an oil removal system approved by the
Department of Health, unless it is wholly oil free. If free of oil it may be
discharged as desired. If temporary openings in the dike are made to permit
doing work on or inside the same, provision must be made while the open-
ings exist to convey 4rainage from the dike to an oil removal system ap-
proved by the Department of Health, or other provision made to prevent
such drainage from reaching the waters of the state without the removal
of any oil it may contain.
19. Every person operating a terminal for the transfer of oil from
ship to shore or from shore to ship shall, when a spillage of oil occurs at
his terminal, take steps immediately to contain the spilled oil, and remove
it from the water if any has reached it. For this purpose he shall have
readily available adequate essential equipment approved by the Department
of Health and personnel familiar with such salvage operations.
20. Every person operating a terminal for the transfer of oil from
ship to shore or from shore to ship shall inspect every ship using his ter-
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minal and fill out the inspection report supplied to him by the Department
of Health, and submit the same to said department promptly when the
ship has led the terminal.
21. Every person who handles oil shall, when a spillage of oil occurs
on his premises, take steps as promptly as possible to prevent the spilled
oil from reaching a public sewer or drain or in any way any of the waters
of the state.
22. No person shall discharge the drainage from any bulk oil plant
yard, refinery area, or other outdoor area where large volumes of oil (more
than 21,000 gallons) are received or stored or shipped, and where by
accident or otherwise oil may escape or be spilled into any public sewer or
drain or into any of the waters of the state, without first passing such
drainage through an oil removal system approved by the Department of
Health. This rule shall not prevent the discharge into any publfc sewer
or drain or into the waters of the state of any oil free drainage from such
areas if means are provided to retain the drainage for inspection befort it
is discharged and only oil free drainage is so discharged.
23. No person shall maintain a vent to any oil storage tank located
on the premises of a business or industrial establishment that is filled through
an opening in the top of the tank except one carried at least three feet
higher than the opening, in order that the oil will first overflow at the inlet
to the tank if the tank is filled beyond its capacity. This rule shall not
apply to a tank used to store only fuel oil of a grade which will -flow at
all times without being heated.
24. No person shall maintain an inlet to an oil storage tank located
on the premises of a business or industrial establishment except one so
located or protected that should the tank overflow accidentally on filling,
the oil will be retained near the tank and will not reach any public sewer
or drain or the waters of the state. This rule shall not apply to a tank
used to store only fuel oil which will flow at all times without being heated.
25. No person shall permit any oil pipe to leak oil in any location
where the oil may be washed or drained into a storm drain or sewer or into
the waters of the state.
26. Every person shall post and keep posted such 'warning signs or
copies of extracts of these rules and regulations as may be provided to him
by the Department of Health, in a conspicuous place where the same may
be easily read, at each of the wharves and piers owned, leased, operated
or controlled by such person, and at each separate parcel of land owned
or leased by such person which borders on, or any part of which is within
one hundred feet of any of the waters within the state, and whereon there
is deposited or stored at any one time, any oil, in greater quantity than
twenty-one thousand gallons.
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27. These rules and reputations shall be in full force and effect on
and afler the first day of September A.D. 1957 and any previously issued
orders establishing rules and regulations to prevent the discharge of oil
into the waters of the state are hereby declared to be null and void, on
and after that date.
Ordered on the twelfth day of August A.D. 1957.
Violations of an order of the Department of Health are punishable by
a fine of not more than five hundred dollars ($500.00) or by imprisonment
for not more than one (1) year, or by both such fine and imprisonment.
(Section 14, Chapter 12, Title 46, General Laws of 1956).
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APPENDIX C
SELECTIONS FROM "RULES FOR THE PREVENTION AND CONTROL
OF OIL POLLUTION IN THE WATERS OF THE COMMONWEALTH OF MASSACHUSETTS"
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Section /«.n--MAR!NF. Oil. TERMINAL TRANSFER OPERATIONS
Particular care is essential to prevent oil pollution cause by
spills during transfer of bulk oil from a vessel to shore, or from
shore to a vessel or during ballasting.
Section 4.01--PRE-TRANSFER CONFERENCE
Prior to commencing oil transfer operations, the following items
shall be understood and agreed by both vessel and shore personnel in
responsible charge of operations:
a. Cargo sequence for loading or discharging products.
b. Handling rate at which oil will be transferred. Reduced
rates are required when commencing ransfer, changing the
lineup, topping off tanks, or nearing completion of transfer.
The amount of standby time to be given when the vessel or
terminal desires to start, stop, or change the rate of flow
must be agreed upon.
c. Adequatp communication and signal systems must be established
and checked, and must be readily available during transfer
operations.
d. Emergency procedures to be followed in order to stop and con-
tain any spillage must be understood.
Section A.02—VESSEL OPERATIONS
During oil transfer operations, the following procedures shall be
followed by vessel personnel:
a. A licensed officer or certified tanker-man who has full know-
ledge of the vessel's tanks and cargo handling system shall
be in charge of cargo handling.
b. A sufficient number of adequately-trained men shall be on duty
during cargo operations.
c. The vessel shall be moored with adequate lines to prevent sur-
ging, and the mooring lines shall be properly tended to pre-
vent the lines from either parting or developing excess slack.
d. All scuppers shall be plugged during transfer operations. If
scuppers must be unplugged to drain water from the deck area,
they shall be tended constantly and the plugs replaced immediately.
No oil or emulsion shall be discharged through scuppers.
e. The ends of hoses or other connecting devices shall be blanked
while being put in place. A drip-pan shall be used at the cargo
or bunker manifold when removing the blank and making up the
connection. The drip-pan shall be left in place during transfer
operations. Connections shall be secured to insure against
leakage. Flanges, joints and hoses shall be checked visually for
cracks, weak spots or points of excessive stress.
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f. Before commencing transfer operations, the initial lineup
shall be checked from the deck manifold connection through
the system to the first tank valve to see that rilTOs are
properly set. All valves which are not involved in initial
transfer operations must be closed tightly. Sea-valves con-
nected to cargo or bunker piping systems, stern discharge
and ballast discharge valves shall be closed and sealed
during transfer operation.
g. During transfer operations, a man or men shall be stationed
where vessel connections, hose and terminal connections can
be observed. Regular inspections shall be made of the trans-
fer lineup,of water around the vessel, and of connections
and other points subject to leakage.
h. On completion of transfer operations, hoses or other connect-
ing devices shall be vented, blown down, or sucked out to
drain the remaining oil. A drip-pan shall be used when
breaking a connection, and the end of the hose or other con-
necting devices shall be blanked off before being moved.
i. During ballasting, pumps shall be started before opening
sea-valves, and pumps shall be stopped after closing sea-valves.
Section A.03—TERMINAL OPERATIONS
a. Procedures outlined in Section 4.02 for vessel operations also
apply to terminal operations where appropriate.
b. A tight wharf or pier section enclosed by a curb is satisfactory
in place of drip-pans, provided no oil-contaminated drainage is
discharged into the waters of the Commonwealth.
c. Before commencing discharge of dirty ballast or slop-oil to
terminal facilities, the system and lineup shall be checked.
During transfer the system shall be checked regularly for
leakage.
d. Where waste oil collection and separation facilities are in-
stalled, the separator shall be checked regularly for proper
operation.
e. Care shall be taken to prevent leakage or 'spillage of oil from
drip-pans when they are dumped for disposal.
f. Terminal operators shall have a maintenance inspection and test-
ing program for all oil-handling hoses and equipment in order
to detect faulty equipment.
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Section 4.04--USE AND CARE OF HOSE
a. Any hose used in oil transfer service shall be of a grade
suitable for oil service and be designed to withstand pressure
of the shut-off head of the pump or pump relief valve setting.
Such hose shall be tested annually at a pressure In excess of
that to which It Is subjected In use.
b. Hoses shall be supported during transfer operations so as not
to be crushed between the vessel and wharf or to be subjected
to strain due to excessive curvature.
c. Hose lines shall be sufficiently long and adequately supported
so as not to be strained excessively by any movement of the
ship due to tides or change in draft during oil transfer
operations.
d. Hoses shall not be permitted to chafe on the dock or ship, or
to be in contact with hot surfaces such as steam pipes, or to
be exposed to other corrosive sources*
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Section 5.0—TERMINALS. BULK PLANTS & OTHER INSTALLATIONS HANDLING OIL
5.01 All terminals and bulk plants shall be so located and constructed
as to provide against flooding by high water and the accidental
discharge of oil to water courses.
5.02 Proper maintenance measures shall be provided and due caution
exercised to prevent any spills or discharges of oil to water
courses.
5.03 Any drainage which may contain oil in such amounts as to cause, or
contribute to, a condition in contravention of the established water
quality standards must first be passed through a properly maintained
and adequate oil-trap or other oil removal system approved by the
Division. '
This shall include, but not be limited to:
a. Surface drainage from any oil-contaminated area of a terminal,
bulk oil plant yard or other outdoor area where large volumes
of bulk oil are received or stored, or shipped.
b. Drainage from any pipe trench or pipe gallery used as a conduit
for oil pipes.
c. Exhaust steam, condensate or water from any device used to heat
or cool oil.
5.04 Each permanent oil storage tank or battery of tanks must be sur-
rounded by a dike or retaining wall of sufficient capacity to con-
tain spillage and prevent pollution of the surrounding areas. Ac-
cumulated drainage shall be removed through a properly maintained
and adequate oil-trap or other oil removal system approved by the
Division.
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APPENDIX D
SELECTED REGULATIONS OF THE TEXAS RAILROAD COMMISSION
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RULE 8. WATEft gROTECTlOK
(A) Fresh Watet to be Protected
Freeh water, whether above or below the surface, shall
be protected from pollution whether lit drilling, plugging, pro-
ducing, or disposing *£ salt water already produced.
(B) Exploratory Wftlla
Any oil or gas well or w«ll drilled for exploratory pur-
poses shall be governed by the provisions of statewide or field
rules which are applicable and pertain to the drilling, safety,
casing, production, abandoning and plugging of wells, and all
>
operations in connection therewith shall be carried on so that
no pollution of any stream or water course of this State, or any
subsurface waters, will occur as the result of the escape or re-
lease or injection of oil, gas, salt water or other mineralised
waters from any well.
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(As added by Order No. 20-56,8Hl, effective 1-1-69).
(C) (1) All operators conducting oil and gas. development and
production operations are prohibited from using salt water disposal pits
for storage and evaporation of oil field brines and mineralized waters.
(a) The provisions of this rule do not affect the use of
burning pits which are used exclusively for the burning of tank bottom
waste accumulation.
(b) Impervious collecting pits may be approved for use in
conjunction with approved salt water disposal operations, provided that
authority must be received for use of such pits from the Commission.
(c) Discharge of oil field brines and mineralized waters into
a surface drainage water course, whether it be a dry creek, a flowing
creek or a river, except where permitted by the Commission, is not an
acceptable disposal operation and is prohibited.
(d) Disposition of oil field brines and mineralized waters
through off-lease facilities where transportation is by tank trucks, pipe-
lines or other means, is the initial responsibility of the lease operator
and shall not be initiated until such method of disposition is permitted
by the Railroad Commission. Such permit shall be subject to review and
cancellation should investigation show that the permitted method of
disposition is abused.
(2) Exceptions to the provisions of this rule may be granted
by the Railroad Commission on special request where good and sufficient
cause is shown.
(3) Penalty for non-compliance with any part of this rule
shall be pipeline severance for each lease operated in violation of this
rule.
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(U) In any instance where a salt water disposal pit is
presently in use and is abandoned, due to cessation of flow of salt
water thereto, whether voluntary or mandatory, such pit shall be back-
filled and compacted.
(D) Pollution Prevention
(As added by Order No. 20-59,200, effective 5-1-69)
(1) The operator shall not pollute the waters of the Texas
offshore and adjacent estuarine zones (salt water bearing bays,
inlets, and estuaries) or damage the aquatic life therein.
(2) All oil and gas well drilling and producing operations
shall be conducted in such a manner to preclude the pollution of the
waters of the Texas offshore and adjacent estuarine zones. Particular-
ly, the following procedures shall be utilized to prevent pollution.
(a) The disposal of liquid waste material into the Texas
offshore and adjacent estuarine zones shall be limited to salt water
and other materials which have been treated, when necessary, for the
removal of constituents which may be harmful to aquatic life or
injurious to life or property.
(b) No oil or other hydrocarbons in any form or combination
with other materials or constituent shall be disposed of into the
Texas offshore and adjacent estuarine zones.
(c) All deck areas on drilling platforms, barges, work-
over unit and associated equipment both floating and stationary subject
to contamination shall be either curbed and connected by drain to a
collecting tank, sump or enclosed drilling slot in which the contain-
ment will be treated and disposed of without causing hazard or pollution;
or else drip pans, or their equivalent, shall be placed under any equip-
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ment which might reasonably be considered a source from which
-?:>
pollutants may escape into surrounding water. These drip pans must
bc« piped to collecting tanks, sumps or enclosed drilling slots
designed to accommodate all reasonably expected drainage. Satisfac-
tory means must be provided to empty the sumps or enclosed drilling
slots to prevent overflow or prevent pollution of the surrounding water.
(d) Solid combustible waste may be burned and the ashes
may be disposed of into Texas offshore and adjacent estuarine zones.
Solid wastes such as cans, bottles, or any form of trash
must be transported to shore in appropriate containers. Edible garbage,
which may be consumed by aquatic life without harm, may be disposed of
into Texas offshore and adjacent estuarine zones.
(e) Drilling muds which contain oil shall be transported
to shore or a designated area for disposal. Only oil-free cuttings
and fluids from mud systems may be disposed of into Texas offshore
and adjacent estuarine zones at or near the surface.
(f) Fluids produced from offshore wells shall be mechan-
ically contained in adequately pressure-controlled piping or vessels
from producing well to disposition point. Oil and water separation
facilities at offshore and onshore locations shall contain safeguards
to prevent emission of pollutants to the Texas offshore and adjacent
estuarine zones prior to proper treatment.
(g) All deck areas on producing platforms subject to con-
tamination shall be either curbed and connected by drain to a. collect-
ing tank or sump in which the containment will be treated and disposed
of without causing hazard or pollution, or else drip pans, or their
equivalent, shall be placed under any equipment which might reasonably
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be considered a source from which pollutants may escape into surround-
ing water. These drip pans must be piped to collecting tanks or sumps
designed to accommodate all reasonably expected drainage. Satisfactory
means must be provided to empty the sumps to prevent overflow.
(h) Any person observing water pollution shall report such
sighting, noting size, material, location and current conditions to
the ranking operating personnel. Immediate action or notification shall
be made to eliminate further pollution. The operator shall then trans-
mit the report to the appropriate Commission district office.
(i) Immediate corrective action shall be taken in all cases
where pollution has occurred. An operator responsible for the pollution,
shall remove immediately such oil, oil field waste, or other pollution
materials from the waters and the shore line where it is found. Such
removal operations will be at the expense of the responsible operator.
(3) The Commission may suspend producing and/or drilling opera-
tions from any facility when it appears that the provisions of this
rule are being violated.
(U) (As added by Order No. 20-60,2lU, effective 10-1-70)
The foregoing provisions of Rule 8(D) shall also be required
and enforced as to all oil and gas operations conducted on the inland
and fresh waters of the State of Texas, such as lakes, rivers, and
streams.
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APPENDIX E
SURVEY GUIDE
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SURVEY GUIDE
A. STORAGE. TRANSFER. LOADING AND UNLOADING
These facilities are intended to include tank farms for raw and
refined products from which transfers are made for transportation to
non-contiguous areas for use or further processing. In the case of petro-
leum products or certain other hazardous, combustible products, a number
of legal requirements exist as to the location of tanks within diked areas
of definad configurations. However, many tank farms for hazardous pollut-
ing substances do not now have such protection against movement of spilled
liquids and the interviewer should consider questions of the following
s
type:
(a) What are typical fail-safe procedures and equipment employed
for filling and emptying storage tanks, e.g., are the pumps
equipped for automatic shutdown on high-level indication in
a tank being filled; are lines entering the tanks located so
•i
that siphoning effects are prevented in the case of line
breakage; in the case of long lines of large diameter, what
provisions are made for liquids draining out in case of
rupture, etc.?
(b) In diked storage tank areas, how is rainfall runoff handled,
i.e., is there an installed drainage system which is pro-
vided with normally shut valves; is ground seepage adequate
to remove rainfall—if so, what about ground water pollution?
Does the rainfall go to a holding basin or through a waste-
water treatment plant before it can enter water courses?
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(c) Are tanks equipped with remote level sensing and alarming
systems sounding into a central location?
(d) What administrative procedures are in effect concerning
notification of spills?
(e) Are there any unique regulations based on experience or
safety requirements that dictate certain design procedures,
for example, the generation of electrostatic charges by
discharging the entering liquid above the surface of the
liquid in the tank?
(f) What design standards are presently used for the trans-
portation equipment of concern, i.e., are these standards
developed by an industry group, promulgated by insurance
companies, defined by the carriers, or established by the
equipment owners?
(g) Are operators of transportation equipment familiar with
the type of cargo, methods for controlling and combating
spills, and/or know how and where to seek rapid assistance
in the case of an accidental spill? For example, is the
MCA's Chem-Card Manual utilized?
(h) Since an accidental spill of a hazardous polluting substance
is most often best combated by containment in a localized
area followed by removal for disposal, what types of equip-
ment are carried for effecting such an operation? For
example, a tank truck operator might be expected to have
available shovels for creating small dikes to prevent rapid
migration into water courses.
(i) What fire, explosion and personnel safety requirements are
now demanded by regulatory groups and how do these
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requirements affect the prevention or detection of spills
and leaks?
B. PROCESSING PLANTS
Questions should be based on the fail-safe concepts of operation
and hardware that are presently installed to meet (1) personnel safety
regulations, (2) preventing loss of valuable materials, (3) fire insur-
ance or other codes, and (4) protection of equipment. Interviewers
should be especially alert to in-plant procedures for coping with spills
especially to such operations as water flushing for safety or removal
reasons and what procedures are utilized to prevent spilled hazardous
polluting substances (HPS) from entering surface and ground waters.
(a) What fail-safe procedures are incorporated in the process
designs and operational procedures? For example, are pres-
sure, temperature, liquid level, and flow rate sensors
alarmed? Do these sensors actuate the closing of valves,
the shutdown of pumps, or a fire protection system? Are
there any special fail-safe procedures required, for insur-
ance regulations or by legal or other codes?
j)
(b) Are process areas curbed on a selective basis, i.e., with
respect to the volume and specific degree of hazard
involved in the material handled?
(c) How is the drainage from the plant and the process areas
handled? For example, are there separate sewer systems
from process pads going to special waste-water treatment
facilities? If curbed areas are unable to contain the
maximum credible spill, i.e., the maximum volume present
in the processing units located in the area, where would
110
-------
the overflow go, i.e., into storm sewers draining directly
to water courses, to holding basins, to municipal sewers,
and so on?
(d) Where holding basins (used for surge capacity) are in-
stalled so that runoff or overflows can be treated prior
to discharge to water courses, what is the design basis?
For example, the maximum 24, 48, etc., hour rainfall over
a 10, 20, 50 year or other period?
(e) Before a holding or catchment basin is emptied, what de-
cisions are made as to whether the contents are emptied
through treatment plants, or directly into receiving
waters? What analytical procedures are carried out?
(f) Are special handling equipment, or treating agents, e.g.,
lime for acid neutralization, located throughout the
plant for cleanup of spilled substances?
(g) Is there any special, non-process, detection instrumenta-
tion now installed that has a sole function of alarming
if spills occur? What type of detection equipment is
now installed for safety reasons and what is the nature
of any process controls actuated by this equipment?
(h) What degree of reliability is placed upon present de-
tection and alarm sensors, especially with respect to
experience and the backup or spare philosophies incor-
porated in design and operation.
(i) What has been the major attributable causes for past
in-plant spills regardless of size or whether these
111
-------
entered receiving waters, for example, process equipment
failure, operator error, control equipment failure and
so on.
112
-------
APPENDIX F
DETAILED RESULTS OF FIELD SURVEY
113
-------
DESIGN CRITERIA, EQUIPMENT. AND PROCEDURES IN CHEMICAL FACILITY - PLANT^A
ITEM
1. Drainage ditches surrounding acid tanks
lead to neutralization area
2. Spare acid tanks for rapid transfer in case
of leaks in primary tanks
3. Scheduled manual gauging of all storage tanks
once per shift
4. Tanks dikad to prevent spills from entering
waterway
TYPE
Design criteria,
equipment
Equipment
Procedure
Design criteria,
equipment
AREA_
Storage
Storage
Storage
Storage
5. Reduce number of flanges in piping systems
to reduce leaks
6. Pipelines located overhead (above grade) to
help locate leaks
7. Metal articulated swivel joint loading arms
for liquid transfer to rail and tank cars
8. Concrete gutters (curbing) along rail and
truck unloading areas to convey spills to
neutralization or treatment area
9. Gravel covered loading and unloading points
to prevent runoff
10. Concrete surfaced pad surrounded by curbing
and/or drainage ditch in process area
11. Large centrally located lime slurry tank for
neutralization
12. Common neutralization facility in addition
to principal waste treatment facility
13. Continuous pH monitoring to detect spills
or leaks in main waste treatment stream
14. Discharge to county waste treatment
facility on a fee basis
Design criteria
Design criteria
Equipment
Equipment,
design criteria
Design criteria
Design criteria,
equipment
Equipment
Equipment
Equipment and
procedures
Transfer
Transfer
Loading and
unloading
Loading and unload
ing, waste treat-
ment
Loading and
unloading
Process
Process, loading
and unloading
Waste disposal
Waste disposal
Waste disposal
Principal Hazardous Materials
Inorganic acids; chlorinated rubbers and waxes, ammonia, chlorine, alcohols, toluene, wax,
.114
chlorinated hydrocarbons
-------
PLANT A (Continued)
REQUIRED OR USED BACK-UP SYSTEMS
Neutralization area required
REMARKS
For acid tanks only
Sight tubes and float gauges used
also
Fail-safe system for dike
valves required
Continuous inspection required to
identify leaks
Acid tanks diked; alcohol
tanks diked to prevent loss
of costly fluid
Efforts made in all new lines to weld
joints because of leaky flanges
Experience indicates loading arms are
more reliable than flexible hoses
Adequate neutralization area required Mostly used for acid areas and spills
May actually be detrimental since acids can
enter ground water; curbing may be better
Adequate neutralization or holding
area required
Distribution method for slurry and
disposal of material required
Neutralization facility and
equipment required
Prevents overloading of waste treatment
facility in case of spills
This is a back-up system for waste treatment
facilities; is used when overloaded
115
-------
DKSICN CRITERIA, EQUIPMENT, AND PROCEDURES-IN CHEMICAL FACILITY - PLAHT__B
IT KM
i. Storage tanks of hazardous materials are
diked
2. Tanks containing hazardous materials have no
bottom connections; fluids pumped from top
3. Storage tanks have high level alarms and
"high-high" levels shutoff for pumps
4. Overflow lines from tanks run to process
area ditch
5. Major valves may be locked to prevent
unauthorized use i
6. Special toxic materials stored in underground
concrete tanks with impervious membrane layer
in tank walls
7. Flange bonnets used on mechanical pipe
connect ions
8. Closed sections of lines protected with relief
valves and burst disks
9. Written procedures for all operations from
transfer to processing; sign-off sheets
checked step by step by operator, filed
for record
10. Materials are sampled and analyzed for
compatability before transfer operations
11. Manual (stick level) gauging done periodically
to check instrumentation
12. Written permission of supervisor required to
override safety shut-off system
13. Different type (design) couplings for
different substances
14. Transfer areas sloped and graded toward
process drains
15. Rail transfer areas curbed, with sump for
spills; liquid must be pumped from sump
16. Process areas sloped toward process area
ditches and drains
17. Rainwater ditches separate from process drain;
used to drain swampy areas direct to river
T)TK
Design criteria,
equipment
Design criteria,
equipment
Equipment
Equipment
Procedure
Design criteria,
equipment
Kquipment
^quipment
Procedure
Procedure
Procedure
Procedure
Design criteria,
equipment
Design criteria
Design criteria,
equipment
Design criteria
Design criteria
ARFA
Storago
Storage, process
Storage, process
Storage, process
Storage, process
Process, storage
Transfer
Transfer
Storage, transfer
process
Storage, transfer
Storage, transfer
Storage, transfer
process
Transfer, loading
and unloading
Transfer, loading
and unloading
Loading and
unloading
Process
Process, other
116
-------
REQUIRED OR USED BACK-OP SYSTEMS
PLANT B (Continued)
REMARKS
Alarms and indicators are located in central
control room, manned continuously
System for collection or drainage of
any vented materials required
There are no penetrations in dikes; fluids
are pumped out if contained in diked area
Prevents leakage from valves by gravity
flow
This is a back-up system to convey overflows
to holding areas.
Has both advantages and disadvantages as a
fail-safe system
Prevents toxic material from entering ground
water
Prevents leaks in and damage to flange
joints
Supplements fail-safe equipment and design
criteria; helps operator reduce possibility
of accidents
Prevents chemical reactions—primarily a safety
procedure which can act as a pollution control measure
Check on fail-safe instrumentation
Prevents accidental flows of materials to
wrong lines or tanks—mainly a safety feature
Adequate process waste treatment required
Sumps must be large enough to handle
maximum spill
Process drain system required
Used only for most hazardous or toxic materials
Method to ensure that spills cannot get into
rainwater ditches required
117
-------
DESIGN CRITERIA, EQUIPMENT, AND PROCEDURES IN CHEMICAL FACILITY - PLANT B /Contj.nued)
ITEM
18. Process areas hard surfaced
19. Fire control deluge water flows into process
area ditch
20. Separate holding basins in each process area
21. Holding basin with 24-hour capacity
22. Double capacity emergency basin
23. pH monitors at inlets to each basin
24. pH instruments checked three times daily by
grab samples and lab analysis
25. Visual checks periodically for oil downstream
of skimmers
26. Heavy metal and other pollutants monitored
27. Settling basins have membrane liner to
prevent seepage
28. Well points surround settling basins sampled
to check for leakage
TYPE
Design criteria
Design criteria
Equipment, design
criteria
Equipment
Equipment, design
criteria
Equipment
Procedure
Procedure
Procedure
Equipment
Procedure
AREA
Process
Process
Process
Waste treatment
Waste treatment
Process, waste
treatment
Waste treatment
Waste treatment
Waste treatment
Waste treatment
Waste treatment
Principal Hazardous Materials
Chlorinated hydrocarbons, inorganic acids, caustic, oil, metal alkyls, acetone, kerosene
118
-------
PLANT B (Continued)
REQUIRED OR USED BACK-UP SYSTEMS
Fire control deluge water may contain
hazardous materials and requires treatment
REMARKS
Some process storage tanks with volatiles on gravel
Each process area has holding basin of capacity
equal to all tanks and equipment in area
This is a back-up for holding tanks in process areas
This is a back-up for large spills; fluids must
be diverted to basin
Used to activate caustic addition system to
neutralize waste streams
This is a back-up measure to ensure automated
equipment works well
Check on equipment -
Used to check if spill has occurred or as process control
Back-up system to detect faulty operation
119
-------
DESIGN CRITERIA. PROCEDURES AND EQUIPMENT IN OIL STORAGE AND TERMINAL PACILITY*_r_ PLANT C
ITEM
1. All storage tanks for oil and hydrocarbons
are diked
2. Process sewer system for drainage of fluids
in diked areas
TYPE
Design criteria,
equipment
Equipment
3. Leak detection system for pipelines—consisting Equipment
of flow meters and meter provers, with computer
system to check input and output
4. Separate sumps provided at blending, packaging, Design criteria,
and loading facilities equipment
5. Standard procedures for draining flexible hoses Procedure
after loading by gravity for barge operations
6. Standard procedures for pumping to drain
flexible hose lines on tanker operations
7. Temporary mounted high level alarms in barges
to provide visual and audio alarm on filling
8. All process units on hard surface pads
9- Standard procedure for flushing and draining
sample lines into process waste sewer
10. Once through cooling water visually inspected
and instrumented for measurement of total
organic carbon before discharge back to river
11. Waste water effluent from solvent recovery
and other process units monitored for
dissolved carbon
12. Impending area for rainwater to handle
24-hour drainage from worst storm in seven-
year period
13. Most of area served by two waste systems,
one for only water, the other clean
14. Chemical waste water kept separate from oily
waste water
15. Turbidity monitor for water leaving oil/water
separator
Procedure
Equipment
Design criteria
Procedure
Procedure,
equipment
Procedure,
equipment
Equipment
Equipment,
design criteria
Design criteria
Equipment
AREA
Storage, process
Storage
Transfer
Loading and
unloading
Loading and
unloading
Loading and
unloading
Loading and
unloading
Processing
Processing
Processing
Process, waste
treatment
Waste treatment
Waste treatment
Waste treatment
Waste treatment
Principal Hazardous Materials
Fuel and lubricating oils, asphalt, oil additives, inorganic acid and
caustic
*
Old refinery used as storage and distribution facility primarily
120
-------
REQUIRED OR USED BACK-UP SYSTEMS
Valving or pumping system required
to make this fail-safe
Disposal system required
Curbing and drainage system required
PLANT C (Continued)
REMARKS
Fire regulations require diked storage
Present system is inadequate and must be replaced.
Approach is thought to be valuable if system accuracy
can be improved. Probably detects large leaks.
Is fail-safe only to extent used by operators.
In experimental stage, believed to give tanker personnel
false sense of security^-not connected to shut-off system
Prevents release of product to waterway
Detects leaks in heat exchangers; requires diversion
system and catch basins in event of accident
Detects leaks but not fail-safe
Not fail-safe, but prevents most accidents in
plant discharge from reaching waterway
Allow two levels of treatment and different
separation and treatment techniques
Detects overloading of separator and prevents direct
release of oil into clean waste treatment facility
121
-------
DESIGN CRITERIA. EQUIPMENT. AND PROCEDURES USIil) IN PLASTICS AND RUBBER FACILITY - PLANT
ITEM
I. Dikes Around Individual tanks or groups oi tanks
2. Separator pits for draining tanks
TYI'K
Design crltorlu, Process, slor«K«'
equipment
Design criteria, Process
equipment
3. First half hour of heavy rain runoff flows into
trade waste system for processing in water
treatment area
Procedure
Process, storage
4. Lagoon for diversion of one day's trade waste
for further processing
5. Other lagoons for diversion and storage of
2-3 days' wastf.
6. Sight glasses on tanks
7. Written handling procedures for loading and
unloading tanks
8. Level or pressure alarms on critical tanks
Design criteria Waste treatment
Design criteria Waste treatment
Equipment
Procedure
Equipment
Process
Storage, process
loading and unload-
ing
Transfer, process
9. Piping above ground with concrete ditches
underneath
Design criteria, Transfer
equipment
10. Operator on duty in waste treatment area
24 hours a day
11. Concrete ditches surrounding tank car unloading
area
12. Hard surfaced areas near loading and facilities
Procedure
Design criteria,
Design criteria
13. Gravity overflow lines on tanks'
Principal Hazardous Materials: Butadiene, Styrene, Latex, Rubber Formulations.
Design criteria,
equipment
Waste treatment
Loading and
unloading
Loading and
unloading
Loading and -unload-
ing, process
122
-------
PLANT D (Continued)
REQUIRED OR USED BACK-UP SYSTEMS
Requires control of valves and lines
going through dikes
Requires system for disposal of
material collected in pits
Requires separate storm and process
waste system
REMARKS
Used whenever tanks are being
cleaned ;or as an overflow
protection measure
Used to collect any oil or wastes
that would be washed off in heavy
rain; one half hour may be
insufficient
This is a back-up for waste treat-
ment system
Requires operator's use
Requires appropriate maintenance
and checking
Used when load on waste processing
is heavy or failure in system
Not fail safe, but may help to
prevent spills
Ditches empty into trade waste,
and are used to collect any
spills from pipes
Operator is able to divert flows
or spills
Requires adequate waste treatment
or disposal system
Requires collection system as
described above
Requires sumps or holding vessels
for overflow
Overfilled tanks release
material by gravity flow to sump
or tank instead of spillage
123
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DESIGN CRITERIA. EQUIPMENT AND PROCEDURES USED IN PETROCHEMICAL AND CHEMICAL f^f!TLTTY - PLANT,E
ITEM
1. Dikes around most storage tanks
2. Sui.ips or traps with eductors inside diked area
3. Excess flow valves on critical lines used during
transfer
4. At least one catch basin or holding tank in each
process waste stream
5. Skimmers in storm sewer runoff stream
TYPE
Design criteria,
equipment
Design criteria,
equipment
Equipment
Design criteria,
equipment
Equipment
AREA
Process,
storage
Storage
Loading and unload-
ing
Process, waste
treatment
Waste treatment
6. Concrete barrier around hazardous materials tanks Design criteria, Process, storage
equipment
7. Sumps with eductors in concrete barrier tanks
Equipment
Process, storage
8, Level alarms on selected tanks
Equipment
Process
9. Operator in control room 24 hours per day Procedure
10. Feed line pumps of critical materials can be shutoff Equipment
by scales under tank cards or process vessels
Design criteria,
11. Separators, sumps, and process sewers used to collect equipment
spills in loading areas
12. Return lines on loading of cars goes to separate tank Design criteria,
equipment
13. Planned inspection of hoses and piping
Procedure
Process
Process, loading
and unloading
Process, loading
and unloading
Loading and
unloading
Storage, transfer
14. Rigid connections on materials of high hazard
Equipment
Loading and
unloading
124
-------
PLANT E (Continued)
REQUIRED OR USED BACK-UP SYSTEMS
Sumps or valves in lines passing
through dikes required
This is a back-up system for dikes
Requires operators to observe use of
system
REMARKS
Spills in diked areas cannot flow
out under gravity
If flow is too large due to tank
or line failure, flow is shutoff
A safety measure to prevent heavy
loading of waste treatment system
Planned to remove any hydrocarbons
from runoff water
Used primarily as a safety measure
around very flammable and hazardous
materials
Is a back-up system to prevent gravity
flow of spilled materials
Used mostly for flammable or hazard-
ous materials
Back-up for alarm system
Is a back-up system for transfer of
fluids
Is a back-up system during filling
operat ions
Used primarily in transfer of very
hazardous materials to prevent over-
filling
Gravity flcv "•••' •• '
tanks
Normal plant practice with extra
attention given to hazardous materials
lines
Eliminates problems of flexible lines
125
-------
DESIGN CRITERIA, EQUIPMENT AND PROCEDURES USED IN PETROCHEMICAL AND CHEMICAL FACILITY
PLANT E (Continued)
ITEM
15. Use of atmospheric pressure and vacuum systems to
convey materials rather than pumps
16. Curbing around selected process areas
TYPE
Design criteria,
equipment
AREA
Loading and
unloading
Design criteria Process
Principal Hazardous Materials: Chlorine, Alcohols, Olefins, Sodium, Flammable Materials.
126
-------
PLANT K (Contitiued)
REQUIRED OR USED BACK-UP SYSTEMS REMARKS
Believed to reduce potential for
spills during transfer operations
Is a back-up system for small spills
in process area
127
-------
DESIGN CRITERIA. EQUIPMENT AND PROCEDURES USED IN REFINERYAND STORAGE AND DISTRIBUTION FACILITY
PLANT F
ITEM
I. Separate storm water and process water systems
2. Four large guard basins to retain storm water
3. Dikes around selected tanks
Separate drainage system for diked tanks
5 Emphasis on placing responsibility for spills on
operator
TYPE
Design criteria,
equipment
Design criteria,
equipment
Design criteria,
equipment
Design criteria,
equipment
Procedure
AREA
Process
Waste treatment
Storage
Storage
6. Cathodic protection of pipelines, frequent corrosion Design criteria, Transfer
inspection procedure
7. Testing and certification of hoses at loading dock Procedure Loading and
on regular basis unloading
8. Use of articulated swivel joint steel loading arms Equipment Loading and
on increasing level unloading
9. Gravity flow of oil for first half hour to check Procedure Loading and
connections before applying pump pressure unloading
10. Low pressure shutoff on selected lines Equipment Transfer
11. Drip pans at appropriate loading points Equipment
12. Securing of normally closed lines (valves) by seals Procedure
Loading and
unloading
Process, loading
and unloading,
storage
13. Small local tanks of acid or caustic to help in
neutralization
Equipment, design Process, waste
criteria treatment
128
-------
PLANT F (Continued)
REQUIRED OR USED BACK-UP SYSTEMS
Must have method to divert flow into
these basins
This is a back-up system to separate
material released in diked areas
REMARKS
Design to separate oily wastes
from water runoff
Designed for holding storm water
or spills for further treatment
Dikes used depending upon
flammability of material
This is an attempt to make
employees more aware of the con-
trol and consequences of spills
Requires manual check for leaks, drip
pans, etc.
Plant staff believe these are safer
than flexible hoses
Used to help spot leaks when under
low pressure and prevent large leaks
Used to detect if there is a leak in
pipeline
Need curbs or dikes around tanks
This is planned to eliminate
accidental opening of drain lines,
dike feed throughs, etc. which could
result in spills
Used to help neutralize on site small
spills
129
-------
DESIGN CRITERIA. EQUIPMENT AND PROCEDURES USED IN REFINERY AND STORAGE AMD DISTRIBUTION FACILITY
PLANT F (Continued^
ITEM
TYPE
14. Continuous monitoring of waste water system for pH Equipment
at several points
15. Hard surfaces in process areas
16V Above grade product lines over drainage ditches
17. Gauging manifolds on tanks
Principal Hazardous Materials; Oil, Hydrocarbons.
Design criteria
Design criteria
Equipment
AREA
Waste treatment
Process
Process, transfer
Storage, loading
and unloading
130
-------
PLANT F (Continued)
REQUIRED OR USED BACK-UP SYSTEMS
Requires system for monitoring of
other substances as well
REMARKS
Drainage goes to waste treatment
system
Permits rapid measurement of tank
levels during transfer operations
131
-------
CRTTERL
PROCEDURES AND EQUIPMENT IN PETROCHEMICAL AND CHEMTCAT. FACILITY -_
ITEMS
1. Separate chemical sewer and clean water storm Design criteria
sewer drainage systems.
2. Rainwater collection and holding pond to contain Design criteria,
first fifteen minutes of runoff; the remainder procedure
being diverted directly into waterway.
3 Practically all piping is above ground. Design criteria
4. Regular periodic inspectirn using standard pro- Procedure
cedures for all piping including hydrostatic
testing and visual inspection.
5. Normal activities of plant operation requires Procedure
operators to observe or at least walk along some
of the exposed pipelines during their daily
activities.
6. .Long interfacility liquid transfer pipelines Design criteria,
supplied with check valves, and emergency liquid equipment
storage tanks at both ends.
7. Standard procedures established for communicating Procedure
via telephone between both ends of long major inter-
facility pipelines.
132
-------
PLANT G (Continued)
AREA
Process, other
Process, other
REQUIRED OR USED
BACK-UP SYSTEMS
REMARKS
Backup system to insure chemical
spills do not get into the rainwater
discharge from the facilities.
Requires means for
detection of chemicals
or contaminants in rain-
water runoff diverted
directly to waterway.
Collects the potentially
dirty initial rainwater run-
off which has washed old
spills of chemicals from
processing areas, etc.
Process, other
Transfer, other
Transfer, others
Transfer
Transfer
This is a backup
system for the
preceding item.
Permits immediate visual de-
tection of leaks or spills
associated with transfer pipe-
lines.
Primary purpose is to prevent
accidents--built-in spill
prevention and detection
aspects.
Certain sample points or data
taking points are stratically
located in plant, such that
operators must regularly visi:
these points--requiring their
visual observation of pipe-
lines arid other equipment
enroute.
In case of emergency, the en-
tire contents of the trans-
fer pipeline can be emptied
into a storage tank at either
end of the pipeline.
133
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.DESIGN CRTTi:j;_A. PVOi;:_M.i;.__.. .' iOj:O!:-'nM''NT IN PETROCHKMICA1. AND CHEMICAL FACILITY -
ITEMS
8. All moves of liquid through large major inter-
company transfer pipelines made in increments or
"batches", utilizing transfer tanks located at
both ends of pipeline.
9. Areas under transfer pipelines have concrete
surface.
10. Loading racks at loading terminal are mounted
over concrete surface.
TYPE
Proceduie,
equipment
Design criteria
Design criteria
11. Education program aimed at process unit op-
erators to make them aware that they have the
ultimate responsibility for spills.
Procedure
12. Sample lines purged into collection drums.
Procedure
LPG storage tanks equipped with high-pressure
alarms.
Equipment,
design criteria
14. LPG pumps equipped with high-flow cutoff.
15. Many storage tanks are surrounded by dikes.
Design criteria,
equipment
Design criteria,
equipment
134
-------
PLANT G (Continued)
Transfer,
processing
Loading and
unloading.
Process, others
Process
REQUIRED OR USED
BACK-UP SYSTEMS
Requires gauging of liquid
levels in receiving tanks
and transfer tanks.
Grade, curbing, and
drainage system required.
Curbing, grade, and
drainage system required.
Records maintained by
company for each employee,
showing record of spills
caused by each employee;
poor record can result in
official reprimand, time
off without pay, or loss of
job.
Collections and disposal of
liquids from purged waste
liquid collection drums.
REMARKS
Close control provided over
quantities moved, with in-
ventory control providing
direct indication of spills.
Any liquids lost in this
area of high-spill potential
and frequency are directed
to containment rather than
being allowed to escape.
This philosophy gives promise
of being an ultimate "fail-
safe" procedure for prevent^n
spills.
This replaces the old system
of purging sample lines
simply onto the ground or
processing pad.
Storage
Storage,
transfer
Storage
Requires attention of
operator, and subsequent
appropriate corrective action.
Requires proper dike drain-
age system operation to in-
sure impounding of spills,
and the proper transfer to
waste disposal of the con-
tained spill.
Dikes are required by fire
regulations, but also serve
as an effective "fail-safe"
spill prevention measure.
135
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c;iiu:u].\. PROCKIH'RKS AND EQUIPMENT IN PF.TKOCHHMTCAL AND.CHKMICAI,, FACILITY
PLANT G (Continued)
ITEMS TYPE
16. Some storage tanks are equipped with high- Design criteria,
level alarms. equipment
17. Manual tank gauging occurs regularly. Procedure
18. A log is maintained which indicates the con- Procedure
ditijn (open or closed) of each valve on the
drain lines from dikes surrounding storage tanks.
19. Large impounding area provided for tvbltting- of -''^r
any large spills of chemicals which would drain Design criteria
from the plant at a rate higher than the maxi-
mum which the waste treatetnent facilities could
handle.
20. Process areas handling the most hazardous ma- Design criteria
terials from a pollution viewpoint are completely
surrounded by dikes, drainage ditches, etc. and
are provided with specific waste treatment
facilities designed specifically for those
materials being handled.
21. Loading arms are washed with a minimum quantity Procedure,
of solvent wnicfi is collected in containers equipment
oC: i'-:ic.tea for used solvent for collection
and >: i ?posa 1 ,
136
-------
.PLANT G (Continued^
REQUIRED OR USED
BACK-UP SYSTEMS
REMARKS
Storage
Storage
Waste treatment
Process
Loading and
unloading
Manual gauging provides
a back-up for the tanks
with continuously
monitored liquid
level indicators
This is a backup
system for the main waste
treatment facilities
The main waste treatment
facilities of the plant
provide backup for the
specialized waste treat-
ment facilities serving
the hazardous process area
Regular collection of waste sol-
vent and transportation to waste
disposal facilities required
This procedure was developed
to provide better control
over the position of drain
valves from dikes which should
be in the normally closed
position such that any spill
will be impounded' behind the
dike, and can later be
drained under control to waste-
treatment or product recovery
areas.
After a large spill was col-
lected and impounded, it could
be fed back to the waste trea-
ment facility at a rate that
would not exceed the waste
treatment facility's capacity
during normal plant operation
An example of such a system
is one in which phenol is
processed.
137
-------
DKST.CN CRITERIA. PROCEDURES AND EQUIPMENT IN PETROCHEMICAL AND CHEMICAL FACILITY -
PLANT G(Continued)
ITEMS TYPE
22. All sewers sampled at least onre a day. Procedure
Chromotography used to identify each specific
chemical in the sewer system.
23. Suction trucks are used to remove waste chemicals Procedure,
collected in sumps during equipment "turn-around". equipment
Principal Hazardous Materials; Chlorine, Organic Solvents, Phenol
138
-------
PLANT G (Continued)
REQUIRED OR USED
AREA BACK-UP SYSTEMS REMARKS
Process, This is a backup system for The presence of any organic
other the various monitoring and products in excess of the
detection procedures and acceptable limits set by the
systems used to identify company is traced to the
spills in processing specific operator responsible
storage and other areas.
Processing, Regular chemical sewer Waste materials from equip-
other system and waste treat- ment cleaning operations are
ment facilities. removed in a concentrated
form, thereby facilitating
disposal.
139
-------
DESIGN CRITERIA! EQUIPMENT AND PROCEDURES IN REFINERY I OIL STORAGE j AND DISTRIBUTION FACILITY
PLANT H
ITEM
1. Drainage Ditches or Dikes around
entire plant site
TYPE
Design Criteria,
Equipment
AREA
all
2. Storage tank diked—diked to
1257, of capacity
3. Drainage from diked areas, process,
and plant go to retention basins
4. Wastewater treatment plant for all
water streams leaving plant
5 Retention basins
(a) Normal
(b) Excess
Design Criteria
Design Criteria,
Procedure
Design Criteria,
Equipment,
Procedure
Design Criteria,
Procedure
Storage
all
Waste
Disposal
all
all
6. Loading areas drain to wastewater
treatment plant
Design Criteria, Loading
Procedure
7 Company owned boom for barge! '-
loading area
8. Curbed process areas
Procedure
Design Criteria
Loading
Process
9. Articulated Loading Arms
Equipment
Loading
10. Process piping on racks
11. Standby Wastewater Transfer
Pumps
Design Criteria Process,
Transfer,Loading
Design Criteria, Waste Disposal
Equipment
12. Development of plant water
recycle system
Procedure
all
Principal Hazardous Materials:
Petroleum Products from Crude Through Refined Acids, Phenols, Heavy Metals
140
-------
PLANT H (Continued)
REQUIRED OR USED
BACK-UP SYSTEMS
All drainage leads to
holding basins
REMARKS
Serves to insure that internal plant
spillages are not removed beyond
property line
Holding basins and plant per- Dikeage required for safety reasons
imeter dikes & ditches used
Plant perimeter dikes and
ditches used
Retention basins required
Requires all water to go through
wastewater treatment plant
Plant employs physical and chemical
separation processes for removal
of pollutants
Excess basins & perimeter
dikes and ditches used
Perimeter dikes & ditches
used
Retention basins required
Drains to wastewater
treatment plant required
Drainage to wastewater
treatment plant required
Drainage systems
Holds normal run-rff and surges
Diked area around two tanks is used
to, receive excess storm drainage via
pumping
Meets plant operational philosophy of
^treating all water emissions regardless
of source
Part of industry-government group
under National Contingency Plan
Normal design criteria to prevent spread-
ing and to direct flow to treatment facility
Ease of leak detection, repair,
renovation
Since all water streams leaving plant
area must be pumped, good operational
practices dictates spares
To minimize overall water usage and
improve efficiency of usage
141
-------
ITEM
1. Elimination of drains in areas
handling highly toxic chemicals
2. Batch collection and treatment
cf all water streams
TYPE
Design Criteria,
Procedure
Design Criteria,
Procedure
AREA
Process
All
3 In old plants, sealing of all
area drainage sewers
4. Diking of tanks
Procedure
Design Criteria
All
Storage
5. Discharge of treated wastewater
to municipal sewers
Procedure
Waste
Disposal
6- Designation of specific employees
to discharge treated waters
Procedure
Waste
Disposal
7. Roofing of'areas where spills
might occur
Design Criteria
Transfer,
Loading &
Unloading
8. Waste sludge disposal by regula-
tory agency approved contractors
Procedure
Waste
Disposal
9. Company program for education of
operating personnel
Procedure
General
Principal Hazardous Materials: Paints, Solvents, Cyanides, Heavy Meals, Oils
142
-------
PLANT I (Continued)
REQUIRED OR USED
BACK-UP SYSTEMS
Manual removal and
disposal required
Wastewater treatment
system required
Wastewater treatment
system required
Wastewater treatment
system required
Regulatory agency
approval
REMARKS
Most positive method for containment
and treatment
Small volume of wastewater streams per-
mits collection & treatment to degree
required for emission
Only practical method to insure
col lection
Done on a selective basis—prefer to
depend upon drainage & collection to
central water treatment system
Company policy to treat to level accept-
able to municipal sewage system in order
to insure that additional treatment is
given before emission
Assigns responsibility for insuring that
quality of treated wastewaters meets
established standards
. i
Objective is to insure that storm water
drainage does not remove spilled sub-
stances since it is more economical to
provide roofing than large wastewater treat-
ment plant capable of handling storm water
flows
Company will not contract with unlicensed
disposers because of contingency liability
possibilities
Company believes that operating personnel
must be made aware of the consequences
of leaks and spills
143
-------
DESIGN CRITERIA, EQUIPMENT AND PROCEDURES IN CH8MICAL FACILITY - PLANT J
ITEM
1. Large number of separated
process units
2. Prohibition of certain pro-
cessing operations at plant
TYPE
Design Criteria,
Procedure
Procedure
AREA
3. Extensive sewer system equipped
with automatic recording instru-
mentation
Design Criteria,
Procedure
all
4. Diked tanks
Design Criteria
Storage
5. Holding basins and lagoons
Design Criteria,
Procedure
Waste
Disposal
Primary and secondary waste-
water treatment plant
Design Criteria,
Procedure
Waste
Disposal
Random program of monitoring
the effluents from individual
process areas
Procedure
All
8. Curbed process areas
Design Criteria
Process
144
-------
PLANT J (Continued)
REQUIRED OR USED
BACK-UP SYSTEM
REMARKS
Segregation permits greater attention to problems
peculiar to a particular process.
The hazardousness of certain products is regarded
as so great that incorporation of adequate safe-
guards at this location is infeasible.
Selected points in process sewer system are ana-
lyzed on short-time repetitive schedule for car-
bon containing or oxygen demanding substances.
Results are electronically recorded in central
control. System provides alarms and causes actions
to be initiated'
Collection system Dikes are provided on a selective basis. However,
and wastewater treat- because of plant experience wherein a tank rupture
ment plants required washed out a dike, plant relies on area ditches,
& peripheral dikes to prevent spread beyond plant
borders.
Wastewater
treatment
plant required.
Wastewater treat-
ment plant
Wastewater treatment
plant required
Large volume basins are maintained into which
"slugs" of spilled substances can be routed for
purposes of dilution and for protection of bio-
logical wastewater treatment plant.
Plant can be operated in many different modes, is
equipped with monitoring & control instrumentation,
operated by trained personnel, & protected against
upsets by the use of holding basins & lagoons to
which slugs of hazardous polluting substances can
be sent.
A highly visual sampling station installed on a
random schedule on sewers from processing areas
results in encouraging operating personnel to
improve housekeeping, reduce leaks, and decrease
load to wastewater treatment plant since they
know that record is being obtained.
Good operating procedures to confine leaks and
spills to desired channels.
145
-------
r.RTTKRTA,' EQUIPMENT AND PROCEDURES TN CHEMTCAL FACTLTTY - PLANT J (Continued)
ITEM
9. Plant wide spill reporting
system
TYPE
Procedure
AREA
All
10. Independent Pollution
Control Group
Procedure
General
11. Plant safety—Pollution
Control Educational Program
Procedure
General
Principal Hazardous Materials: Large Variety of Reactive Organic and Inorganic Chemicals
146
-------
PLANT J (Continued)
REQUIRED OR USE1)
BACK-UP SYSTEM
Flexible waste-
water treatment
system required.
REMARKS
Special telephone and alarm system is available
for reporting spills and leaks. Employees are
trained in its use & are subject to disciplinary
action for failure to report unless protection
of life & property takes precedence.
Through the establishment of a pollution control
group reporting to top management, area manage-
ment can be judged on the effectiveness of pol-
lution control efforts. Group has authority to
require periodic reviews of water usage & reviews
all changes & additions in processing sites.
Plant management has established a direct correla-
tion between safety record and pollution control
record for operational areas. Consequently, edu-
cation and training of plant personnel in both
areas is carried on continuously. Furthermore,
records show that wastewater plant pollution load
is decreasing even though overall plant production
is increasing.
147
-------
DESIGN CRITERIA. EQUIPMENT AND PROCEDURES USED IN REFINERY. STORAGE AND DISTRIBUTION FACILITY! PLANT J<
ITEM
1, Plant graded toward drain system
TYPE
AREA
Design criteria process
2. Waste process system separate from water runoff system Design criteria
3. Overflow and emergency basins for holding heavy rain
and emergency spills
4. Scheduled startup, maintenance and shutdown of storage
and process areas done with area drains blocked
Procedure
Process, storage,
loading and
unloading
Design criteria Waste treatment
Storage, process
5. Planned inspection and replacement of pipelines, equip- Procedure
ruent, etc.
Storage, process
transfer
6. Specific trainee programs with oral and written exams
for operator status
7. Check sheets used for many transfer and process
operations
8. Daily check of pipelines from wharf to plant
9. Selected storage within concrete diked area
Procedure
Procedure
Procedure
Design criteria
Process, loading
and unloading
Process, loading
and unloading
Transfer
Storage"
10. Oil spill booms available on dock
11. Low dikes used in storage areas when more than one tank
within a common dike
12. Rainwater accumulated and drained sequentially from
diked areas using manually actuated valves
Equipment
Design criteria,
procedure
Loading and
unloading
Design criteria Storage
Storage
13. Automatic level measurement systems widely used
Equipment
Process, storage
14. Trailer loading facility graded toward hold tank
148
Design criteria Loading and
unloading
-------
PLANT K (Continued)
REQUIRED OR USED BACK-UP SYSTEMS
Adequate waste treatment system
required
REMARKS
This is a back-up system for all
spills
Requires checklist to insure drains
unblocked at end
Separate treatment of selected
streams before combining process
wastes
Five-day total retention based on
worst 30-year rainfall is provided
Plant experience indicates spills
occur during startup, maintenance
and shutdown. This helps contain
spills during these times
Specified replacement dates and
X-ray, dye technique inspection
provided
Requires controlled use of check
sheets
This is an attempt to get operators
more responsible for spills
Requires proper use of booms
Tanks very near water course are
diked by concrete barriers
Not fail safe but a control measure
Used to contain limited spills and
rainwater
Prevents overloading water treat-
ment system; manual valves normally
closed
Central control stations with
operators can monitor tank levels
regularly
149
-------
DESIGN CRITERIA. EQUIPMENT AND PROCEDURES USED IN REFINERY. STORAGE AND DISTRIBUTION FACILITY
PLANT K (Continued)
ITEM
15. "Meter Loading" of trucks with calibrated meters
Principal Hazardous Materials: Oil, Hydrocarbons.
TYPE
Procedure
AREA
Loading and
unloading
150
-------
PLANT K (Continued)
REQUIRED OR USED BACK-UP SYSTEMS
REMARKS
Helps to prevent spill by transferring
limited amounts
151
-------
DESIGN CRITERIA. EQUIPMENT AND PROCEDURES USED IN CHEMICAL FACILITY -
ITEM
1. Acid and caustic tanks and loading areas have
individual catch basins to hold stored capacity
2. All oil process areas have sewer system leading to
trap and skimmer
3. Double capacity trap for oil operations
4. Cooling towers replacing once through process water
TYPE AREA
Design criteria, Storage
equipment
Design criteria, Process
equipment
Design criteria, Process
equipment
Design criteria, Process
equipment
5, Paved process areas to control runoff
Design criteria •- Process
6. Hourly visual inspection of oil collection trap
Procedure
Waste treatment
7. High level alarms on indoor tanks
8. Overflow lines on outdoor storage tanks
9. Oil tanks within common dike; acid and caustic tanks
have separate dikes
10. Dikes drained by pump out rather than gravity
Equipment
Design criteria,
equipment
Design criteria
Design criteria
Process, storage
Process, storage
Storage, process
Storage, process
11. Rail tracks and truck loading areas sloped toward
drain system
Design criteria
12. Tank car valves routinely checked before and after Procedure
loading and unloading
13. Specific procedures for transfer operations with check Procedure
lists
Loading and
unloading
Loading and
unloading
Process loading
and unloading
Principal Hazardous Materials; oil Detergents, Soaps.
152
-------
PLANT L (Continued)
REQUIRED OR USED BACK-UP SYSTEM ft
REMARKS
Requires some separation and treat-
ment of process water
Waste water collection and treatment
required
Requires drainage system for overflow
This is a back-up system for spills
into dikes
Adequate drain sys tern required
Frequent spills occurred from leaks
into process water and into water
course
Inspection performed so that diver-
sion can be accomplished
Primarily a safety measure
Primarily due to plant siting
requirements
plant staff feels that this is
most important in preventing
spills
153
-------
DESIGNCRITERIA, EQUIPMENT AND PROCEDURES USED IN METAL PRODUCTS FACILITY - PLANT M
ITEM
1. Separate sewer system for waste acid
TYPE
Design criteria
2. Neutralization or removal (by hauling) for acid streams Design criteria,
procedure
3. Oily waste separated in API separators and trucked away Equipment,
procedure
4. Oil skimmers on all main plant water ditches
Equipment
5. Acid tanks placed in concrete dammed area with drain Design criteria
to acid sewer
6. Gravity loading of acid trucks
7. Hard surface truck loading acid area
Design criteria,
procedure
Design criteria
8. High level alarm in sump used in acid storage area Equipment
AREA
Process, waste
treatment
Process, waste
treatment
Process
Waste treatment
Process, waste
treatment
Process, storage
Process, loading and
unloading
Process, storage
9. Automatic pH control of effluent
Equipment
Waste treatment
Principal Hazardous Materials; Acid, Caustic, Oil and Oily Waste.
154
-------
PLANT M (Continued)
REQUIRED OR USED BACK-UP SYSTEMS
REMARKS
Requires adequate waste oil separation
system
Same as above
This is a back-up measure to detect
unusual acid leaks
Metal acid wastes are trucked away;
relatively clean acids are neutralized
Designed to prevent spills during
pumping operations
Required because of acid content of
waste streams
155
-------
DESIGN CRITERIA PROCEDURES AND EQUIPMENT USED IN STORAGE AND DISTRIBUTION FACILITY
PLANT N
ITEM
. All tanks within common dike
2. Shutcff valves up and downstream of pumps
3. Sampling of all cargoes prior to unloading
4. Blow back of flexible hoses to ship
5. Hard surface transfer areas
TYPE
Design criteria,
equipment
Design criteria,
equipment
Procedure
Procedure
Design criteria
AREA
Storage
Storage, loading
and unloading
Loading and
unloading
Loading and
unloading
Transfer, loading
and unloading
6. Blending and canning operations inside diked area Design criteria Process
7. Dip stick gauging is standard
8. Drainage valves on dikes
Procedure
Storage, loading
and unloading
Design criteria Storage
Principal Hazardous Materials; Xylene, Toluene, Glycol, Agricultural and Organic Chemicals.
156
-------
PLANT N (Continued)
REQUIRED OR USED BACK-UP SYSTEMS
REMARKS
This is a back-up system to
prevent accidents.
Small facility with tanks next to
each other
Helps prevent spills at pumps--
a frequent occurrence
Also used to maintain product
quality
Prevent spills during disconnect-
ing lines
Spills are common in blending
operations but are small
Poor experience with level gauges
suggests this approach is better
15"
-------
JRES AND EQUIPMENT USED IN REFINERY. STORAGE. AND PETROCHE>"^At. FACILITY
PLANT 0
ITEM
1. Process areas are sloped toward plant ditch system
2. Separate collection system for phenols, sulfidep,
ammonia, etc.
TYPE
Design criteria
Design criteria,
equipment
AREA
Process
Process, waste
treatment
3. Oily waste streams flow into closed drain system to
central oil-water separator
4. Clean process water and treated water go to large
holding basins
5, Petroleum tanks diked with concrete dikes in process
area and earthen dikes elsewhere
6. Water drains in dikes open only during rain periods
and checked every two hours
7. Elevated transfer piping with regular inspection
procedures
8. Overpressure relief valves on transfer lines
Design criteria,
equipment
Process, waste
treatment
Design criteria Waste treatment
Design criteria
Design criteria,
procedure
Design criteria,
procedure
Equipment
Storage and
process
Storage
Transfer
Transfer
9. Automatic shutoff valve system with liquid level
gauges
10. Transfer areas for truck and rail loading sloped
toward drains
11. Tank car wash water goes through oil separator
12. Scupper plugs on tankers and barges
13. Flexible hoses being replaced by metal loading arms
14. Catch basins used on ships under connections
15. Lines either drained back to ship or pumped out before
disconnect
15R
Design criteria,
equipment
Design criteria
Equipment
Equipment
Equipment
Equipment
Procedure
Transfer, storage,
loading and unload-
ing
Loading and
unloading
Loading and
unloading
Loading and
unloading
Loading and
unloading
Loading and
unloading
Loading and
unloading
-------
PLANT 0 (Continued)
REQUIRED OR USED BACK-UP SYSTEMS
REMARKS
This is a reclamation system which
acts to prevent discharge of these
materials
This is a back-up system for all
spilled materials.
Three to five week holdup times in
large basins
Diking due to local fire codes
Careful checking required to make
fail safe.
Requires method of collection of
vented substances.
System now being installed based
upon good experience at other
locations
Better experience obtained with
metal system
Procedure depends upon elevation of
ship and wharf
159
-------
DESIGN CRITERIA. PROCEDURES. AND EQUIPMENT USED IN REFINERY. STORAGE. AND PETROCHEMICAL FACILITY -
PLANT 0 (Continued)
ITEM
TYPE
16. Written instruction to ship personnel before unloading Procedure
17. Written procedures and check sheets used for all
transfer operations
18. Cleanup truck on standby during repair operations
19. Employee motivation program aimed at reducing spills
and keeping oil from water
Procedure
Procedure,
equipment
Procedure
AREA
Loading and
unloading
Loading and
unloading
Process, loading
and unloading
Principal Hazardous Materials; Oil, Phenol, Acid, Caustic, Petroleum Products and Derivatives.
160
-------
PLANT 0 (Continued)
REQUIRED OR USED BACK-UP SYSTEMS
REMARKS
Language problems have resulted in
past spills
Not fail safe, but a backup for
other equipment
Believe that employee training and
motivation is essential to prevention
program
161
-------
DESIGN CRITERIA, PROCEDURES AND EQUIPMENT IN METAL PRODUCTS. FACILITY -_
ITEMS TYPE
1. Many storage tanks surrounded by dikes Design criteria,
equipment
2, Manual tank gauging occurs regularly Procedure
3. All underground fuel storage tanks are Design criteria,
equipped with mechanical-type internal equipment
liquid level sensing devices with above-
ground visual indicators
4. The ground covering all of the buried Design criteria
storage tanks is graded s-ich than any spills
above ground will be directed into the
waste water treating system.
5. A single sewer system handles all rain- Design criteria,
water runoff as well as any spills of liquids equipment
from the processing, manufacturing operations,
or storage tank farm areas.
6. All areas in which solvents, cutting oils, and Design criteria
acids are used are provided with appropriately
sloping hard surfaced floors, and curbing,
which will direct any spill to a sump from which
it is pumped either into a storage tank for re-
processing, or disposal.
Principal Hazardous Material^: Oil, Acid Washes, Metal Treatment Chemicals.
162
-------
PLANT P (Continued)
Storage
REQUIRED OR USED
BACK-UP SYSTEMS
Requires proper dike drain-
age system operation to in-
sure impounding of spills,
and the proper transfer to
waste disposal of the con-
tained spill
Manual gauging provides a
back-up for the tanks with
continuously monitored
liquid level indicators
REMARKS
Dikes are required by fire
regulations
Storage
Operator must take
effective action
Storage
Appropriate sewer system
and waste water treating
system required
Only those leaks which occur
above ground can be handled
by this approach.
Processing,
transfer, others
Process, other
Although such a system
maximizes the waste treatment
facilities necessary, it in-
sures treatment of all liquids
leaving the plant facilities.
Regular collection of waste
solvent, acid, etc. and
transportation to waste
disposal facilities required
163
-------
DESIGN CRITERIA. PROCEDURES AND EQUIPMENT IN OIL TERMINAL AND OIL REFINERY
STORAGE AND DISTRIBUTION FACTLTTY - PLANT Q
ITEMS TYPE
1. Each tank of any barge operating within the Equipment
metropolitan district near this facility requires
the use of a high-level alarm.
2. Standard procedures regularly used to pressure Procedure
test each flexible hose against a blind flange
bolted on the hose end.
3. Flexible loading hoses preferred over swivel- Equipment
jointed, articulated loading arms.
4. After a loading or unloading operation has been Procedure
completed at a marine terminal, the hoses are
drained by gravity either into the vessel or
back into the shore-mounted storage tank (de-
pending upon relative elevations).
4. All storage tanks are equipped with level Equipment
indicators which register on a tank-side gauge.
5. Manual tank gauging occurs regularly. Procedure
164
-------
PLANT Q (Continued)
REQUIRED OR USED
BACK-UP SYSTEMS
Appropriate action on the
part of a licensed tanker
man present on the barge
during loading operations
Loading
Loading
REMARKS
A high-level alarm in the
strict sense is not a fail-
safe device, and proper
functioning of such a device
tends to make operating per-
sonnel put absolute reliance
on the continued perfect
functioning of the equipment,
which in itself can be re-
sponsible for major spills in
the event of equipment failure
Leaks from flexible pressure
hoses due to damage incurred
during handling, or deterio-
ration resulting from their
normally exposed locations
dictates strict testing pro-
cedures .
Each swivel-joint viewed as a
point of vulnerability with
regard to leaks. Experience
has shown that flexible hoses
give better, and more leak-fre
service than swivel-jointed ar
at marine terminals.
Loading and
unloading
Storage
Storage
Gauging of liquid levels
in all tanks by manual means,
Manual gauging provides
a backup for the tanks
with continuously monitored
liquid level indicators.
165
-------
DESICH CRJ
rc EQUIPMENT OIL TERMINAL AND OIL REFINERY.
.STGR-jylT AX
:-
ITEM
6. A single sewer treatment conveys all rain-
water runoff and any oil spills to the
waste water treatment system.
Design criteria
7. All marine terminals are equipped with an oil-
water separator.
Design criteria,
equipment
8. Practically all piping is above ground.
Design criteria
9- Regular periodic inspection using standard pro- Procedure
cedures for all piping including hydrostatic
testing and visual inspection.
10. Normal activities of plant operation requires Procedure
operators to observe or at least walk along some
of the exposed pipelines during their daily
activities.
principal Hazardous Materials; Oils, Hydrocarbons, Organic Products.
166
-------
PLANT Q (Continued)
AREA
Storage, others
REQUIRED OR USED
BACK-UP SYSTEMS
Storage, others
Waste water treatment
system following oil-
water separator used
Process, other
Transfer, other
Transfer, other
REMARKS
Although this approach mini-
mizes the risk of untreated
spills leaving the facility
proper (if designed well) it
maximizes the size of waste
water treatment facilities
required.
An oil-water separator serves
the dual purpose of recovering
valuable petroleum products
which are spilled and carried
from the facilities with rain-
water or deluged flushing
systems required by various
insurance and fire codes, and
also serves to minimize the
treatment load placed on the
waste water treatment facili-
ties by a large spill of oil
or other petroleum products.
Permits immediate visual de-
tection of leaks or spills
associated with transfer pipe-
lines .
Primary purpose is to prevent
accidents—built-in spill pre-
vention and detection aspects.
Certain sample points or data
taking points are stratically
located in plant, such that
operators must regularly visit
these points--requiring their
visual observation of pipeline
and other equipment enroute.
167
-------
ITEM
1. Separate chemical sewer and clean water storm
sewer drainage systems.
TYPE
Design criteria
2. Practically all piping is above ground
Design criteria
3. Regular periodic inspection using standard pro-
cedures for all piping, including hydrostatic
testing and visual inspection.
Procedure
4. Areas under transfer pipelines have concrete
surface.
5. Suction trucks are used to remove waste chemicals
collected in sumps during equipment "turn-around".
Design criteria
Procedure,
equipment
6. During loading or unloading operations between a
tanker and the terminal, the scupper plugs must
be closed in order to contain any oil spill to
the deck of the vessel.
7. Some storage tanks are equipped with high-level
alarms.
&. Many storage tanks are surrounded by dikes.
Procedure
Design criteria,
equipment
Design criteria,
equipment
9. Manual tank gauging occurs regularly.
168
Procedure
-------
PLANT R (Continued)
AREA
Process, other
Process, other
Transfer, other
Transfer,
processing
Processing,
other
Loading and
Unloading
REQUIRED OR USED
BACK-UP SYSTEMS
Grade, curbing, and
drainage system required.
Regular chemical sewer
system and waste treat-
ment facilities used.
Means for removing oil-
contained on deck required.
REMARKS
Insures chemical spills do
not get into the rainwater
discharge from the facilities
Permits immediate visual de-
tection of leaks or spills
associated with transfer pipe-
lines.
Primary purpose is to prevent
accidents—built-in spill
prevention and detection
aspects.
Waste materials from equip-
ment cleaning operations are
removed in a concentrated
form, thereby facilitating
disposal.
Storage
Storage
Storage
Operator required to
take effective action
Requires proper dike drain-
age system operation to in-
sure impounding of spills,
and the proper, transfer to
waste disposal of the con-
tained spill.
Manual gauging provides a
backup for the tanks with
continuously monitored
liquid level indicators.
Dikes are required by fire
regulations, but also serve
as an effective "fail-safe"
spill prevention measure.
169
-------
PLANT R (Continued)
ITEMS
10. Computer control capability for monitoring
and controlling all of the liquid moves
associated with the storage tanks terminals,
and pipelines.
TYPE
Design criteria
11. The sludge which is removed from the bottom
rf storage tanks during their periodic cleaning
is performed on a contract basis and is removed
by the waste disposal contractor.
12. Samples of waste water moving through the sewer
systems and the waste disposal facilities are
regularly monitored for pH, Toe, and oil
content.
13. All surge tanks are located at the offsites
with the final product storage tanks.
Procedure
Procedure
Design criteria
14. Standard procedures established for communi-
cating between ship and shore during loading
and unloading operations at the marine terminal
Procedure
Principal Hazardous Materials- Oils, Hydrocarbons, Organic Products.
170
-------
PLANT R (Continued)
AREA
Storage,
other
REQUIRED OR USED
BACK-UP SYSTEMS
Storage
Process,
Other
Diversion or other
facilities to hold
fluids outside normal
tolerances required
REMARKS
This system is presently in
the early stages of evolution,
but the intent is clearly to
provide a computerized system
to handle the logistics of the
movement and storage of liquid
in a complex refinery/terminal
operation, from which close
inventory control and leak
detection should be resulting
by-products.
Industry appears to be turning
to this solution for the dis-
posal of materials which are
difficult to treat.
Storage,
Other
Loading and
unloading
171
Any'over filling of surge
tanks due to problems or error?
in operation in the processing
areas will result in spills
which can contained and handle
by the facilities which exist
for this purpose at the storag
areas.
Communications between ship an.
shore during unloading of largv
oceangoing tankers at marine
terminals can be a significant
problem with the relatively
small crews extant on todays
large supertankers, and the
language barriers which often
exist when large tankers are
manned by non-English speaking
crews.
-------
DESIGN CRITERIA. PROCEDURES AND EQUIPMENT IN CHEMICAL FACILITY - PLANT S
ITEMS TYPE
1. Only storage tanks containing flammable liquids Design criteria,
are surrounded by dikes. equipment
2. A single sewer handles all rainwater and chemical Design criteria
spills.
3. A holding and neutralization pond is used to in- Design criteria,
crease pH to approximately 6 - 7 by the use of procedure
lime additions to neutralize normally acidic
chemical waste materials.
4. Process areas built on proper grade to direct any Design criteria
spills to sewer system.
5. Process areas and other areas where strong acids Design criteria
are used are surrounded b y curbing to direct
the flow of any spilled liquids to the sewer
system.
6. Process areas handling the most hazardous materials Design criteria,
from a pollution viewpoint are completely sur- equipment
rounded by dikes drainage ditches, etc. and are
provided with specific waste treatment facilities
designed specifically for those materials being
handled.
Principal Hazardous Materials; Acids, Inorganics.
172
-------
P1.ANT S (Continued)
REQUIRED OR USED
BACK-UP SYSTEMS REMARKS
Process,
others
Process,
other
Process
Process,
other
Requires proper dike
drainage system opera-
tion to insure impounding
of spills, and the proper
transfer of waste dis-
posal of the contained
spill
Appropriate impounding
and waste disposal treat-
ment facilities required
Continuous pH measurement
by submerged electrodes,
with periodic check and
calibration of instrumen-
tation by plant personnel used
Adequate sewer system to
Convey spills to waste
treatment facilities required
Appropriate sewer system
to convey spills to waste
treatment facilities required
Dikes are required by fire
regulations, but also serve
as an effective "fail-safe"
spill prevention measure.
Process
The main waste treatment
facilities of the plant
provide backup for the
specialized waste treat-
ment facilities serving
the hazardous process area
173
-------
DESIGN CRITERIA. PROCEDURES AND EQUIPMENT IN CHEMICAL FACII-TTV - PLANT T
ITEMS TYPE
1. All of the processing units are located on concrete Design criteria
surface areas.
2. All concrete surface areas under processing Design criteria
units are constructed with a sloping grade
toward drainage ditches.
3. Concrete lined ditches surround the concrete Design criteria
surfaced areas on which all processing units
are located. :
4. All piping above ground on overhead Design criteria
pipe racks.
5. The plant affluent stream is continuously Design criteria,
monitored for BOD and TOD. equipment
6. The activated sludge plant is equipped with Design criteria,
a continuous TOD analyzer and recorder and equipment
alarm system.
7. The first one-half inch of rainfall goes Design criteria
through the neutralizing and treating
ponds, while the remainder of each rain-
fall is discharged directly into the nearby
watercourse.
8. Flexible loading hoses are blown clean with "Procedure
nitrogen into the vessel being loaded after
the filling operation has been completed.
174
-------
PLANT T (Continued)
REQUIRED OR USED
BACK-UP SYSTEMS
Process
process
Appropriate sewer system
to remove spills required.
REMARKS
Prevents penetration of any
spilled liquids into the soil.
Spills are controlled by being
directed away from their
source toward the disposal
facilities provided.
transfer
Waste treatment,
other
Waste treatment
Process, other
This is a backup
system for the
main waste treat-
ment facilities.
This is a backup system
for the main waste
treatment facilities.
Loading and
unloading
Permits visual detec-
tion of leaks or spills
associated with transfer
pipelines.
The potentially dirty
initial rainwater run-
off is treated, while
the typically clean
rainwater runoff from
the latter part of each
storm is diverted directly
into the watercourse.
This procedure minimizes
the liquid to be drained and
collected from the loading
hose after each loading opera-
tion has been completed.
175
-------
DESIGN CRITERIA.' PROCEDURES AND EQUIPMENT IN CHEMICAL FACILITY - PUNT T (Continued)
ITEMS
9. When not used, loading hoses are capped to prevent
drips.
10. Tank cars and trucks are filled entirely by manual
operations.
11. The product tanks from which liquids are moved to
the terminal location are mounted on load-cells
which continuously weigh the total tank plus
contents.
TYPE
Procedure
Procedure
Design criteria,
equipment
12. Specific storage tanks are surrounded by con-
crete fire walls (dikes)
Design criteria
Principal Hazardous Materials; Isocyanates, Amimes Caustic, Inorganic Acids.
176
-------
. PLANT T (Continued)
AREA
Loading and
unloading
Loading and
unloading
Storage,
loading and
unloading
REQUIRED OR USED
BACK-UP SYSTEMS
Requires continuous
operator attention
Data transmission
and operator action
required
REMARKS
Storage
Appropriate fire wall
drainage and sewer
systems required.
This provides a direct and
continuous monitoring of the
total liquids moved from the
storage tanks to the rail
cars or tank trucks. It is don
primarily for safety reasons,
and because of the very high
value of the products moved at
this plant. However, this
system also provides a means
for quickly determining spills
of liquids associated with
the storage facilities.
Dikes surround only the tanks
containing flammable liquids.
as dictated by fire regulation
however, these dikes also serv
as an effective "fail-safe"
spill prevention measure.
177
-------
DESIGN CRITERIA
PROCEDURES AND EQUIPMENT IN THE PETROCHEMICAL, CHEMICAL AND PLASTICS FACILITY -
PLANT U
ITEMS
TYPE
1. Most of the production units are located on concrete Design criteria
pads.
2. Concrete pad areas are built on a grade to direct
chemical spills.
3. Curbing and/or ditches surround process unit
concrete pad areas.
4. Many production units are equipped with a
separate chemical sewer system-
Design criteria
Design criteria
Design criteria
5. All other process concrete pad areas are serviced Design criteria
by a single sewer system.
6. Certain production units are equipped with unit
oil separators and/or other waste treatment
facilities.
Design criteria,
equipment
7. All of the loading and unloading terminal fa-
cilities which service carriers other than
barges or vessels are built over concrete
surfaced areas.
/
8. Concrete surfaced loading and unloading areas are
graded toward drains connecting with the general
sewer system.
Design criteria
Design criteria
178
-------
PLANT U (Continued)
Process
Process
REQUIRED OR USED
BACK-UP SYSTEMS
REMARKS
Suitable means for directing Insures that chemical spills
spills of liquids to col- are simply not absorbed into
lection and disposal the soil.
facilities required
Suitable collection and
handling means required
Suitable sewer system
required
Process
Process
Process
Suitable waste disposal
facilities required
A suitable single waste
water treatment facility
required
Main waste treatment
facilities required
This is provided for the
production units which handle
or produce water soluble
organic materials.
Processing areas which produce
organic chemical liquids
which are not soluble in
water are serviced by the same
sewer system which handles
rainwater runnoff.
This not only reduces the
total load on the central
waste treatment facilities
serving this plant, but also
permit more specific tailoring
of the kind of waste treatment
facilities used for each new
unit.
Loading and
unloading
Suitable sewer
system required
Loading and
unloading
Suitable waste disposal
facilities required
179
-------
DESIGN CRITERIA. PROCEDURES AND EQUIPMENT IN THE PETROCHEMICAL. CHEMICAL AND PLASTIC^ FACILITY -
PLANT U (Continued)
ITEMS TYPE
9. Rail car and tank truck washing facilities are Design criteria
built on concrete surfaced areas which are con-
nected to a unit oil separator and then to the
sewer system.
10. The first one-half inch to one inch of rainfall Design criteria
over the entire plant area which is served by
storm sewers drains into and is held by a large
holding lagoon.
11. Suction trucks are used to remove waste sludge Procedure,
from the bottom of storage tanks. equipment
12. Vacuum trucks are used for removing large spills Procedure,
which are confined in specific areas such as equipment
behind dikes or curbing.
13. A continuous TOD monitoring system is being Equipment.
developed. design criteria
14. Gas chromotography is being used to identify Procedure
specific organic compounds contained in the
waste water system.
180
-------
Plant U Continued)
AREA
Loading and
unloading
REQUIRED OR USED
BACK-UP SYSTEMS
Suitable waste disposal
facilities required.
REMARKS
Waste treatment
Storage
Storage, other
This is a backup
system for the
main waste treat-
ment facilities to even
out the load imposed on
it by rainstorms.
After the first one-half inch
to one inch of rainfall, it has-
been found that the entire plant
area will have been cleaned of
chemical and oil spills. After
this quantity of rainfall has
run off and has been collected
by the large storage lagoon,
the remainder of the rainfall
is discharged directly to the
watercourse since it is es-
sentially clean. After the
rain has stopped, the oily
water stored in the large
lagoon can be slowly fed into
the water treatment system.
The remainder of the sludge
is washed from the -bottom
of the tank with water and
drained to the sewer system.
Specific waste disposal
facilities required.
The use of vacuum trucks for
such purposes is increasing.
Process, waste
treatment, others
Waste treatment,
others.
This is a backup
system for processing
operations.
The presence of any organic
products in excess of the
acceptable limits set by the
company is traced to the speci-
fic operator responsible. This
is perhaps the essence of spill
prevention.
181
-------
DESIGN CRITERIA. PROCEDURES AND EQUIPMENT IN THE PETROCHEMICAL. CHEMICAL ANn PTA
-------
PLANT U (Continued)
REQUIRED OR USED
AREA BACK-UP SYSTEMS REMARKS
Process, Appropriate operator This decreases the lag time
other action,required. between a spill of specific
products, reactants, or inter-
mediates at their source, and
the detection of these chemica
This approach to spill detec-
tion is highly favored, and
is'.Increasing in its use.
183
-------
DESIGN CRITERIA, PROCEDURES AND EQUIPMENT IN CHEMICAL AND PETROCHEMICAL FACILITY - PLANT V
ITEMS
1. All of the process units are built on concrete
pads .
TYPE
Design criteria
2. All storage tanks are diked.
3 The first inch of rain which runs off the
entire plant area goes to a storm water holding
pond.
Design criteria
Design criteria
Separate chemical sewer and clean water storm
sewer drainage systems.
Design criteria
6. A separate chemical sewer takes spills from
specially curbed areas such as around pumps and
certain process units which produce either a
continuous discharge or have a high risk of
chemical spills.
7. All storage tanks are surrounded by dikes.
Design criteria
Design criteria
8. The rail car loading area is graded to drain to
a concrete lined trough paralleling the rail
tracks and located on each side of the tracks.
9 The troughs which handle spills at the rail car
loading and unloading facilities empty into a
special catchment basin with a capacity equiva-
lent to one inch of rainfall on the entire track
loading terminal area
Design criteria
Design criteria
184
-------
PLANT V (Continued)
Storage, other
Process, other
Process, other
Process, other
REQUIRED OR USED
BACK-UP SYSTEM
REMARKS
Suitable means for col-
lecting and treating
waste chemical spills.required.
Suitable waste treatment
facilities required.
Suitable waste disposal
facilities used.
After the first inch of rain
runs off the plant area, it
is clean, thereby permitting
the remaining rainwater to
run off directly to the nearby
watercourse.
Insures chemical spills do not
get into the rainwater dis-
charge from the facilities.
Storage, other
loading and
unloading
T i-;s proper
diainage system operation
to insure Impounding of
spills, and the proper
transfer to waste disposal
of the contained spill.
Suitable sewer system to
handle spills required.
Dikes are required by fire
regulations, but also serve as
an effective "fail-safe" spill
prevention measure.
Loading and
unloading
Suitable waste disposal
facilities required.
185
-------
DESIGN CRITERIA. PROCEDURES AND EQUIPMENT IN CHEMICAL AND PETROCHEMICAL FACILITY
PLANT V (Continued)
ITEMS TYPE AREA
10. The entire marine terminal dock is constructed Design criteria Loading and
of concrete, is curbed, and has its surface unloading
slrped toward stainless steel drains.
11 At the conclusion of loading operations, the on- Design criteria, Loading and
shore valve is closed, and the hose between the procedure unloading
valve and the barge is blown out using pressurized
nitrogen.
12. Remote shutdown for loading transfer pumps. Design criteria. Loading and
equipment unloading
Principal Hazardous Materials; Ethylene, Acetic Acid, Cyclohexane, Organlcs.
186
-------
PLANT V (Continued)
REQUIRED OR USED
BACK-UP SYSTEM REMARKS
Stainless steel waste
storage tank located
below dock area used.
This is a backup This remote control for the
system for the loading pump is a safety re-
directly controlled quirement, but also functions
loading operation under as an environmental protection
the supervision of a , feature.
registered tanker man.
187
-------
DFSIGN CRITERIA, PROCEDURES AND EQUIPMENT IN CHEMICAL FACILITY - PLANT W
ITEMS " TYPE
1. Some storage tanks are diked. Design criteria
2. Regular periodic inspection using standard Procedure
procedures for all piping including hydro-
static testing and visual inspection.
Principal Hazardous Materials; Inorganic Solids
188
-------
PLANT W (Continued)
REQUIRED OR USED
AREA BACK-UP SYSTEMS REMARKS
Storage Suitable means for trans- Dikes are required by fire
porting and handling waste regulations, and therefore
chemical spills required. surround tanks containing
flammable materials only;
dikes however also serve as
an effective "fail-safe" spill
prevention measure.
Transfer, other Primary purpose is to prevent
accidents--built-in spill
prevention and detection as-
pects.
189
-------
DESIGN CRITERIA. EQUIPMENT AND PROCEDURES USED BY ARCHITECT-ENGINEERING FIRMS
ITEM TYPE AREA
1. Location by area function, Design all
i.e., process, storage, Criteria
loading utility, etc.
2. Dual Sewers in loading & Design Loading &
unloading area, one for Criteria Unloading
spills, one for rain runoff
3. Hard surfacing of loading Design Loading &
and unloading area Criteria Unloading
BACK-UP SYSTEMS
not applicable
Curbed area &
hard surfacing
Curbs and
separate sewers
Curbing
(a) Process
(b) Loading
(c) Unloading
(d) Transfer
Gravel or shell covering
of loading
Design
Criteria
Design
Criteria
Process
Loading
Unloading
Transfer
Loading &
Unloading
Sloping surface
to appropriate
sewer
Grade to sewer
Flame Arresters in
Sewer Systems
Loading arms and "dead
man" controls
8. Drip pans under selected
joints, etc., in loading
and unloading area
9. Dikes around storage tanks
(a) Flammable Liquids
(b) Non-Flammable Liquids
10. Process Wastewater
Treatment Plant
Design
Criteria
Design
Criteria,
Equipment
all
Loading
Design Loading &
Criteria Unloading
Equipment
Design
Criteria,
Design
Criteria,
Storage
all
Hard surfaced,
sewered areas
Plant Collection
system
Fail-safe valve
system in diked
area for drainage
Catchment basins
or holding lagoons
11. Holding Lagoon
Design
Criteria
all
Diversionary Sewers,
etc.
190
-------
DESIGN CRITERIA, EQUIPMENT AND PROCEDURES USED BY ARCHITECT-ENGINEERING FIRMS
(Continued)
Company Recommended or Industry Standard If Required by Client
REMARKS / Companies Companies
AA AB AC AD AJE AA AB AC AD AE
Systematizes Designs and X X X X X
Spill Control Problem
Permits special handling
of most hazardous concen-
trations
Permits special handling
of most hazardous concen-
trations
X X X X
X X X X
Controlling spread of liquids X X
11 " "XX
Essentially for personnel
convenience. Requires all
rainwater treatment
To prevent spread of flames
via sewer system
Reduce dependency on
operator attention
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X X X X X
X
X X
Low cost, selective
control system
X X X X X
Passive Barrier,
Primary Defense
X X X X X
X X X X X
Permits removal of spilled
materials on controlled
basis
Permits segregation for con-
trolled treatment or release
X X X X X
XXX
191
-------
DESIGN CRITERIA, EQUIPMENT AND PROCEDURES USED BY ARCHITECT-ENGINEERING FIRMS (continued^
ITEM
TYPE
AREA
BACK-UP SYSTEMS
12. Selective Segregation
of Storm Water
Design
Criteria,
Procedure
all
Diversinary
mechanism
13. Separate Process sewers
from process area drainage
Design Process Wastewater Treat-
Criteria, ment plant &
Procedure holding lagoon
14. High&low liquid level alarms
on storage & process tanks
15. Above ground piping on
racks
Design
Criteria
Design
Criteria
Process &
Storage
Process
Transfer
Monitors and
alarms
Drainage collec-
tion under rack
16. Fixed Boom loading arms in- Design Transfer
stead of hoses on marine
facilities
17. Tank Hydrostatic Testing Procedure Storage,
Program Process
18. Manual Pump out connections
for tank emptying
Design
Criteria,
Procedure
Storage
Curbed areas
Spare Tankage
19. Automatic Controls on pH at
wastewater treatment plant
20. Liquid knockout drums on
gas relief system
21. Installation of fin-
fan coolers
22. Detection Instrumentation in
wastewater lines-especially
oil
23. All welded transfer piping
systems
Design
Criteria,
Equipment
Design
Criteria,
Equipment
Design,
Criteria
Design,
Criteria
Equipment
Design
Criteria
Waste
Treatment
Process
Process
Process
Process
Transfer
Process Drainage
192
-------
DESIGN CRITERIA, EQUIPMENT AND PROCEDURES USED BY ARCHITECT-ENGINEERING FIRMS
(Continued)
Company Recommended or Industry Standard If Required by Client
REMARKS Companies Companies
AAAIBACADAE £A £B £C ££ M.
Permits holdup of initial X X X X X
storm runoff for subsequent
treatment
Permits most effective
treatments
X X
X
Active detection
X
Prevents uncontrolled spread X
of liquids from pipe breaks
Pipelines should be periodi-
cally tested
Recommendation to client—no
responsibility for program
Removal to permit repairs
X
X
X X
X X
X X
Rapid response to control
X
X X
Prevents liquids from being
blown onto uncontrolled areas
Replace water cooling system
X X
Active alarm
XXX
X
Reduces potential of leaks X ' X XX X
from flanges
193
-------
APPENDIX G
TYPICAL PROCEDURE (JOB STANDARD)
FOR TRANSFER OPERATION IN CHEMICAL INDUSTRY
TYPICAL OPERATING STANDARD AND
CHECK LIST FOR LOADING AND DISCHARGING OF SHIPS
195
-------
JOB STANDARD
JUtS oiAINUAKU
37"::\ rz-:i SCALE TAT; TO •.*. FIF.U STO.V.G:, V^T nc:
.::, VALV.-.S, F-'T, AH 5/312!, FLO..' ir.UM, J.U, TAG
Li:rr r:ivi5io:>
Ptant Svtt. No Rf
L 4>;> ra 15^;
UX-AT1CN
MACHIt.
IOUIPW
TOOL*
FIELD & CLD3. J25
MACHINE .~J
IOUIPWENT OAT*
PA.'.t . OF -
SUPERSEDES ACE
PdLJJWB_
Nt \S( )v. I OK
W ' H5I liLHL
fAJlTICIPANTS
1
No,
.1 U M 0
CHART
WORK FRODUCHD SHOULD BE VERIFIED BY
REPORT
Foto No.
ACTUAL
OBSERVATION
Opi-r.ition Studied
No.
NORMAL FREUUtNCY
T (' _ ' t'_^_ ;
ELEMEKTS IN FULL DETAIL
Wot* EUmcnl, MUM B. PctfonntJ A. Dcxribcd Wo*
REF FILE No
Occ P«
\. JrO P STOCK r^OM 3C.\1.?. T.^K i?120 TO U'L'-T FIL1D T.V«C V.ILN :
sv^L" is :;I:.O;-.D (Els. 1-7, 9, 11-13, 13, 13, 20-22)
. A;;ITIC-:\L ALLO:A:;CL ro:i TA'a;;a FLO..' n.u*:t s-Vi-LC ra:
Ar?:io:a."Axri.Y 9/10 rr:?i:;o3 (1:1-.. 3, 10, 1-'*, l'->. 17, 19)
c. TJ-TAL ALLCr.'.'.rrc TO rivj? 37oc:; r?.a:t ;;C,VLE TA:H; tn20
FILLT r\-::: '..ir:i FLOT-; rrc*t S.VTLE i^ m;visno (Us.
3a-"3ple
...-.Ik to"ocalo Cai^ (if* av;;.)(.0012). Set scalca aaJ check
vci-'r.t of stock in t.mk (.0014). Hecoril In pocl:ct notcboo!;
(.0024).
:.*r. Ain_o:!.U'^;
.ir.o is not uicli air to be aura that line ia set to carrcct t.nk
ilk to air vilvc;i £i\)iip at
> ij.ib u^ »»i i. v i^vw;^ ^..w.^/ .jh. i..-....* \3^ tiV^. } \»'-"-"_ .I/ . C»3^Q UXO
naJ open t-.-o 3/V v.ilvc-.; to ti;m 0:1 air (.0042). Return to fr
of scxilo t;j;ii (33' avj.)(.C024). ,
ij-C---^./'••: .^-*, •'.-'• •^*, ' -• • "" < • 5t-i'-,- ^; j^«..-:
lull cl: :ia cutc-iuiana to open ono 2!y v.ilve nnj close ono 2%"
vilvo a'jovc n.iin aisle (.0030). Go to area acir pi^-?, pull
c'.:.iln e:;tc;isVo-.i3 to open one 2'."' vjlvo o:iJ clo^o 2V v:ilvo
(.0033). CD to ?:6 tci:s.->aina level (53' av-. * 21 su)(.0037).
Check 2 - 3'1 v.-jlvas on:! open or close or.o 3'' valvo (.0353).
Step to £. slUe of ^es.-:.5nlno (5'). Chen!: r-n av^. of ono 4"
viive. Open or clo-o 3 - 4" v.lvos (.0104). Walk to arc.wny
south of s:=3 bsut. (00* * 21 s-J + 4 5u)(.00')7). Open o.n4 clos(
an QV3. of 4 - 4" valves to set lino (.0165).
:I:T LT:njTOFi.M.o TA::^. c;.".:c:c AI:I Ti;tr/;.";i
-Jcr
nt
W:\lk frou vnlvc.T near S'^i bjst..:crit cjor to vnlvo groi») at end
(vent) of nrcaway by storeroom (216') (.0126). Open one 4" v.il'
Close ono 4" v.ilvo (.0110). W-.l'.; to valvo group outside west
j**tp house (193* + 14 su). Observe 3 valves on line to be sure
tfa«y are s«t properly (.0144). Open one 4" valve, close 2-4"
valves (.0165). Step to weet tank Cant (57* + 3 su). Open and
closo an ovs. of 3 valves to set lino to tank. Walk on. av«.
of 154' + 2 sd while setting lino (.0775). Clor.o tone 4" vnlvc
on line. Open rls«r valve on tank slowly to feel rush of air
Into tank (.0072).
STD HRS.
J .5732
.0522
.0050
.COJO
.0745
1302
l/yr. ai
STUDIED BY S.7
CHANCES BY
TOTALSTO. HRS PER CCO SU^TUJtV
IT. » O-ERJC .
l-P!«nl
) L F- Div. .
4. D^L Mgr. .
I. Croup Mgr
D«Pt Mgr.
GroiTpMgr
EfTEC
196
Ind. Enn.
pUnt M
Dt
Audi""
"
D«
Auditor
M.
1.1
-------
r
*
. -OO'-'CT tnj
LOCATION
JOB STANDARD
L /.OO Pd
PUT STOCK F7.0?! SCALE TX. TO ',.'. FILLD
T, W. flLL) 4 25U>G« £26
No.
10
li
12
13
14
:l
IN FULL DETAIL
8 is obtalncjd.
Open \" valvo In line to flov droa (.0014). i^lk to flow dru
(151 avj.). Step up to flow druz3. Inspect anJ adjust flow lnt>
flo:v druni. Step clav.'n fro.-j drta (.0-^9).
_
Walk to storage tank i» W. tank farm to which oil is being
puaped (688' + 21 a« + 2 sd -»• od)(.C427). Note flow of oil
Into tank by placing car againat riser pipe line (.0010).
Return to S&S b«rt. (674' + 21 au + 2 su + od)(.0468)
V.'::i,n at o.KC.ifor's Uo-'.:, G-'-^ -<-V-:plc t:'-J fro.i --raver in dc^U
Till la ace. infoivution on s.;::pic t^ (.CD70). Get e-v^lc
k frou Jc.'--; an-1 pencil £I-D:- po;l:ct. fill out tho ncceaj
iori in tlie 3a;,plo 'jo:/.; relativo to na., co^'c, stack,
etc. (.OOS3). '..'aIk frs i other v;ork l;j area ta cxjplo jr.r atora
at t.jn'c 110 (j1). Get liner, place liner in cap an«l s_ro"?.t:r=t> o?
(.0029)
Uaii: iron other vorU to acala (10' ovj.). Balance scalo for
opprox. wc-l^ht to noto prosross o; pulping (40,000^ avs. pvc--plnk).
ATT;:: mo:: TO LAST o?_yi? ffUjc
Walk rro.3*othor worU to scale (10' nv
Watch anJ soove scale
boa.-a v'lllo pippins -last of stock frt^ scale tan!«,
"to rear oi Vealo"tank (35' av3.)(.0025). Close vaivo in
lino unJ«r tanU (.0355). Open two 1;' valves, close bleeder to
air blov lino fros scale tanU to vest fara tank (.0033).
o:: .'.GIT.MC:I i:? FT.O.J. orx:i
'iTTlo^ (jrua ~ust ajltato for at lea-st 2-3 alnutoj before
takln-r oacsplo. Tills i« done to l:uuro well nintd sa^?lo.
Jtep to aov drua (12' + 2 su r.vj.). Open I" valve to turn on
nir to contents of flow drua (.0029).
2 OF 3
STO HRS
.0063
.0118
.0305
.01GC
.0115
.0300
.0133
.0025
COPT: 1. T.B. CLERI
2. PL»»T I.C.
3. I.S. DIV.
Bgr.
. Group Mgr.
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«-•<» I
_L
JOB STANDARD
L 600 Pd 1T-'.C pu"' **
LX.6 ELDG« ?2j
q
t
15
16
;MtN'1S IrJ fV'l-L DETAIL
i .v u»i P^ P.-T 111 i-.*\J A * CV*rTib"«J Mow
17
20
21
22
.
V.ilk to pu p cvltch (1G* avj.), p-:sb button to stop pmp(.C020)j.
Ualk to ot'.K-r worl: (30'), vMlo flo^ CHJ.I njltctcs (.0022).
..'alii to sc.ilo"ta;'_: (11'), 2C^ s^..:?le bcttle, valk to flov Urur.
(25' -»• 2 cu)(.C035). "c_ow c^p on:', place In pocl;c-t» u>o Ulppdr
t^ Clp ca--plc fr:/n flow drvc to t^plo Lottie or jar» cap bottlp
(.O062). C1030 V:" valvo to turn off olr (.0014).
.
.-.tn 2!1 wotto.a v;-.vo to
cJr.2.; (.0023). Valk (4» nv~.), pus
starting j>uv.p (.0012). ?.ctum en*;1, c'.icci p-^.pln^ fro'.i
fl-j Ci-uu! (.01CO). Step uavn anJ close 2" bottom valx-c of
flow tlruu (.003-4).
:;;;^C ;ri , AI ^_T o J'I/A:^ to?) ^.^y 71 J:_LT: u:
w'^li: to ,:ir valv:.-j (20* avj,.), clo.oo bleeder and open two valve
to tura on air to blo-j lino (.0333). Walk to T»V.-»> (341
PAI .E
3 °F3
Occ. Per
set c.nplc (1C r-:iy) csiCo on sc.-le of t.^i'- (.OJ26). Open blccc
clicclc air tl:rou^li pu.-.,?, cloao blco^cr (.OC3i).
l'u-li li.ct'Ki to £1:^.-:) p?j .p (.CCC6). O-ion I," flo-j l!no valve.
Cloio 2-V' valve in lir.o froa i>'-'c I? co *'S tc> force air tl;r»ush
s.^rplc lino ta flov Oru:i. Dlow line. Open 2';" valve. Close
I" v.ilvc (.0073).
l,ic to W. field -.:Li.at be blov.i Cor at Ic :ct 20 uiivj^cs to clear
lino.
'il-ill: to air v.ilvcj (30* aV2.)(.0022). Cloijc 2 air valve .5, open
blccJcr (.0^2).
».ii: tu .rJ; ia vr.;c icl.J (603' * 21 GII *• 2 a I * oj){.0*>17).
C-.u^o tuiLC onj record In jvnli (.0030). Clouo f»" riccr v;:lvo on
tarl; (.COjS)- Ilcturii Co ccjlc tanl: In brr.at. (603' + 21 sd + 2
Sut ccr.lca ,i:ij c:-.cct: flail wclclst (.CC42). Subtract Cinnl uei;
froj st-u-Clnj uc..-:.t Co calculalre not uoljht pu'.r^cd (.0340).
::.-.i:o r.ecccsary cn'cric-3 on pujp ol.cot. Show tanl: noa., a'jount
pu-rpcJ, etc. C.CC33).
5/1C/GG bS
198
COPT: 1. T.B. CITRI
3. I.S. DIV.
.0111
.0174
.0113
.0079
.OCS4
.C925
.0175
4. D»pt. »gr.
5. Croup »gr.
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STANDARD OIL COMPANY OF CALIFORNIA
WESTERN OPERATIONS, INC.
RICHMOND, CALIFORNIA
VESSEL'S NAME
Our Operating Standard RE-3110 "Loading and Discharging Ships at Manufacturing Department
Terminals" describes the rules and regulation governing the operation of this Wharf. A
complete copy la available for you to read upon request. The following is an abstract of
these rules and regulations:
I. "Class A" products include all oils under 115*? closed cup flash or all oils handled
at or above their closed cup flash temperature or all oils loaded into a tank con-
tainir? Class A products and not subsequently gas freed.
2. "Claps B" products include all oils of 115*P and higher closed cup flash when
handled at temperatures below their flash temperature.
3. No smoking on the Wharf or in the Berth Offices.
4. No smoking on the weather decks of your Ship. Smoking peroitted aboard ship only in
locations designated by the Master. Portholes on the Wharf aide shall be kept
closed or screened while ship IB along side Wharf. Doors and portholes facing load-
ing decks shall be kept closed except for momentary passage.
5. In case of fire, stop cargo movements and handle oil lines as directed by Wharf.
Ship's fire fighting equipment must remain operative while at Wharf.
6. Potential sources of ignition, particularly small power craft, should not be allowed
to approach your Ship nearer than 100 feet.
7. Ship's Officer and Wharf Representative shall agree upon the method of comnunicating
during cargo movements. Cargo movements shall not begin until the vessel and the
Wharf inform each other that lines, valves and tanks are properly set.
8. Ver.sel is responsible for proper make-up of ship's hose connection, adequate hose
support. Avoid hose kinks. Maintain hose bends above 12 diameters.
9. Tank tops must be kept closed at all times. Ullage plugs are to be kept closed at
all times except when sampling, thieving or inspecting, at which time they can be
opened for the necessary time and then immediately closed. Tank tops may be open if
gas free.
* 10. No ballasting during cargo movements except when ballast handling Is in a separate
system from bulk cargo handling. 'Ballast discharge over side prohibited. Use shore
tank only.
11. Proper preparation of tanks ia Ship's responsibility. Consultation Is available.
12. Vessel is responsible for all on board cargo movements.
13. Stnrt loading slowly and by gravity when possible. Top off t«nk by gravity when
possible.
lit. Vessel shall report Ship's tank gages every 2 hours.
1^. ClRss A products shall not be displaced from cargo hoses with compressed air.
15. Scupper plugs shall be tightly fitted on the weather deck in way of tanks before
cargo or bunker movement can start.
17. Hose limits-. 150°F, 125 psig.
18. If contamination or a serious leak is discovered, discontinue the stock moveaent
until agreement is reached on the proper procedure to follow.
19. Your ship must be able to get underway while at Wharf. Bitter end of mooring lines
must not be secured. Fire wires must be out at bow and stern.
20. No other vessel is permitted to moor alongside or allow cargo movements across the
decks of a Class A vessel.
;•• Holler fires shall be adjusted so as to pre*vnt "Stack Burnouts".
'"> Wireless transmission is prohibited. Electrical repftlr work is prohibited.
23. Handling of ail ship stores will be the responsibility of the ship's Officer.
24 Abide by Federal, State and Local Air and Water Pollution Laws.
25. Vessel shall provide own gangway. Wharf gangway normally Is not available.
*Revised 3-31-70 199
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- 2 -
26. You must provide your own doctor or ambulance service. A local list can be obtained
from the Wharfmaster.
27. Keep both anchors housed.
28. Special situations, such as repair work, require Terminal Executive approval.
29. Pedestrians are not permitted on Long Wharf causeway. Ride the Company-provided bus.
30. Paying passengers cannot board and must stay aboard your vessel.
31. So that shore booster pumps and manifolds can be properly adjusted to eliminate
possible hazards to these facilities, a 15-mlnute notification shall be given to the
wharf men in charge of the berth prior to the:
(I) Stopping of any cargo movement.
(2) Stripping of any tanks during cargo discharge.
32. Cover ship's sewer outlet to deflect material into the water Instead of on the deck.
*33. Cleaning of ship's tanks and/or butterworthlng alongside wharves Is prohibited.
*34. Deck-watch required at all times while loading/discharging.
I will abide by the rules and regulations as set forth In Operating Standard RE-3110,
"Loading and Discharging Shipa at Manufacturing Terminals", as well as those prescribed by
Law.
SIGNED SIGNED
(BERTH OPERATOR) (MASTER OR AUTHORIZED REPRESENTATIVE)
(NAME OF VESSEL)
(DATE) (TIME)
The" ToTl owing" section of "this* TornTshould bVused Tor special situation's:
(NAME OF VESSEL) ' (DATE) (TIME)
Wh.-»rf approval is required before «hlp can steam, wash
",as fro* tanks. (TERMINAL EXECUTIVE OR
AUTHORIZED REPRESENTATIV
The freight holds and/or tanks of this, vessel have been .
inspected/tested and have been found safe for men Co enter (MASTER OR AUTHORIZED
and/or work. (Must be signed before Company personnel can REPRESENTATIVE)
enter a freight hold or ship's tank.)
Special situations should be listed here.
200
*ReviseJ 3-31-70
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STANDARD OIL COMPAQ OF CALIFORNIA VESSEL:
LOJ:C. VTrfAUF/POINT ORIENT WHARF BERTH-'"
RICHMEJD, CALIFORNIA DATE: ~"
Check Hat of Itens to be dlacussed betvaan the Captain,Chief Kate, Chief Englnocr end Vhcrf-
noster he fore atnrt of cargo operation. Oil tranafer nay not start until ell quooclcaa have
been checked off In the "Yes" circle and .attested below. Each oncoming Whorfaaater end Kate
must sign- ' ' ''•''' '* ^ '• - • - ' "••••• .
1. Written cargo and bunker orders have been reviewed end agreed upon as to:
«. Quantity & Type of Stock () ! e. Weua Tinpersturo ()
b. Initial Transfer Rate ( ) f. Anticipated Stoppacoo ( )
c. Maximum Transfer Rate ( ) g. Booster Pimps ()
a. Maximum Line Pressure ( )
?.. The method o£ communication (signaling practice) between ship and shore hao boon
established. / \
3. It lr, understood a IS minute standby notice to both ship and shore is required
for .-.hutting down any cargo transfer, except la an energency., ( )
/». Ho all agree vessel and gangway Is properly secured at WharfT ( )
5. All bolted connections between ship and shore are full bolted. ( )
f>. If a hold-out (displacement) la required, has the amount and procedure been
nt;reed-upon? . ^ ^
7. In there a clear understanding at the terminal and on board ship the steps to bo
taken for containment and clean-up in the event of an oil cplll? ( )
(-> ~ •. •• >
>\. Aro. c.ir^ii/bunker hoses In good condition? ( )
9. Sen r-.iictlon valven will be-. p:ccp*tiy la«hed and opened only If under the'direct
supervision of the Officer In charge. Wharfmaater to be notified when valves
opened. v ._, , ,, , • .. ( )
10. HA-J Anv Anticipated repair work been brought to the Wharfmaater1 s attention? ( )
11. Ship nn-1 nhore 2-hour gages will be exchanged. , ( )
12. Portholes on Wharf side are closed or properly icreened. ( )
WHARFMASTER SHIP'S OFFICER ' TITLE SIIIP'S OFFICER TITLE
2. 2.
3. 3. _ _ . 9.
5. __ _ 5.
6. 6.
201 ou.S. GOVERNMENT PRINTING OFFICE:1972 484-487/3571-3
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