JULY 1997 Region III Oil Program Activities Volume 4, Issue 3 FEATURE CATASTROPHIC FAILURE OF STORAGE TANKS Catastrophic failures of aboveground, atmospheric storage tanks can occur when flammable vapors in the tank explode and break either the shell-to-bottom or side seam. These failures have caused the tanks to rip open and, in some cases, the explosions have caused the tanks to be hurled through the air. Tank design and inspection/maintenance practices are directly related to catastrophic tank failure. A properly designed and maintained storage tank will break along the shell-to-top seam. Consequently, any fire that would occur would be restricted by the damaged tank and the contents would not be spilled. Recent Accidents Several accidents have occurred within the last few years in which storage tanks have failed catastrophically when the flammable vapors inside an atmospheric tank exploded. The tank was either propelled upward from its base (shell-to- bottom seam failed) or split along the side seam. As a result, workers were killed or injured and the tank contents were released into the environment. Three specific incidents demonstrate the potential dangers posed to workers, the public, and the environment when these storage tanks fail catastrophically. In these incidents, the shell-to-bottom seam failed after an explosion and the tank was propelled upward. All occurred in older, atmospheric steel storage tanks. Often workers were performing tank maintenance or other activities that introduced an ignition source. The vapors were ignited either inside the tank or outside and then flashed back into the tank. In a 1995 incident, during a welding operation on the outside of a tank, the combustible vapor inside two large 30 foot diameter by 30 foot high storage tanks exploded and propelled the tanks upward-one landing more than 50 feet away. The flammable liquid inside was instantly released and ignited, resulting in a massive fire that caused five deaths and serious injuries. In a 1992 incident, while workers were welding the outside of a tank empty of liquid, the residual vapor in the storage tank exploded and propelled the tank upward and into an adjacent river. Three workers were killed and one was injured. In a 1994 incident, during a grinding operation on a tank holding petroleum-based sludge, the tank was propelled upward injuring 17 workers and spilling its contents over a containment berm into a nearby river. Tank Design Accidents where the shell-to-bottom seam fails are more common among older storage tanks. Steel storage tanks built before 1950 generally do not conform to current industry standards for explosion and fire venting. Atmospheric tanks used for storage of flammable and combustible liquids should be designed to fail along the shell-to-roof seam when an explosion occurs in the tank. This prevents the tank from propelling upward or splitting along the side. Several organizations, including the American Petroleum Institute, have developed standards and specifications for storage tank design. Poor Inspection, Maintenance, and Repair Practices Tanks that are poorly maintained, rarely inspected, or repaired without attention to design, risk catastrophic failure in the event of a vapor explosion. Either weakening of the shell-to-bottom seam through corrosion or strengthening the shell-to-roof seam relative to the shell-to-bottom seam will increase the vulnerability of the tank to failure along the shell-to-bottom seam. The practice of placing gravel and spill absorbents around the base of the tank, may increase the likelihood of bottom corrosion. Given years of this practice, Karen Melvin, Chief, Removal Enforcement and Oil Section 841 Chestnut Building, Philadelphia, PA 19107 Phone: (215)566-3275 Paula Curtin, Editor, Spill Enforcement Coordinator 303 Methodist Building, Wheeling, WV 26003 Phone: (304)234-0256 ------- the bottom of some tanks, especially older ones, may be below ground level, thereby trapping moisture along the tank bottom. This can weaken the bottom and the shell-to-bottom seam. Alternatively, changes to the roof seam such as modifications to or replacement of the roof, or attachments to the roof, could make the shell-to-roof seam stronger relative to the shell-to-bottom seam. Other hazards that can contribute to a tank explosion and possible consequences are: Combustible Vapors Generation of combustible vapors is a hazard not only for the storage of pure flammable liquids but also for the storage of any sludge or mixture where a combustible component is present or can be produced by reaction. Sludge (slop tanks) and mixture (e.g., oil/water) tanks may be particularly vulnerable because they are sometimes open to the air; explosive atmospheres may form inside and outside the tank. Facilities may not always recognize this hazard. In addition, even tanks appearing to be empty may pose a hazard if they still contain combustible vapors. In the previously cited cases, the potential for combustible vapors was not clearly recognized and materials were stored in tanks that were not equipped with flame arresters to prevent external fire from reaching the vapor space inside the tank or with vapor control devices to limit vapor emissions from the tank. Ignition Sources When combustible vapors escape from their containment and mix with air in the presence of an ignition source, combustion may occur. To minimize this hazard, all possible ignition sources must be isolated from potential combustible vapors, e.g., welding equipment or other maintenance equipment that can spark or arc, sources of static electricity, lightning, "hot work" in adjacent areas, and any electrical equipment in the vicinity of tanks that does not conform to the National Fire Protection Association (NFPA)-70, "National Electric Code". Proximity to Workers and Environment The danger posed by these tanks is often increased when the location of the tank does not conform with current minimum spacing requirements. Sections 2-3.2 to 2-3.3 of NFPA-30 discuss minimum spacing. For mitigating consequences to workers, the environment, and other tanks, proper secondary containment (diking) should be considered for containment. Reference: EPA 550-F-97-002b (May 1997) PLANNING ACTIVITIES EPA REGION III - PLANNING & RESPONSE CD- ROM PHILADELPHIA... Imagine this worst-case scenario: a huge tank of oil spills into a river, moving downstream threatening drinking water for whole communities, impacting ecologically sensitive areas such as wetlands. The EPA Region III Inland Area Contingency Plan on CD- ROM makes computer-generated maps and diagrams of five eastern states and the District of Columbia immediately accessible, showing the relationship of the spill to areas at risk, including drinking water intake pipes, hospitals, public lands, ecological sensitive areas, and populated places. The program defines county, state, township, and even congressional boundaries, and provides emergency telephone numbers. The new program will track the flow of that river ~ to let planners know what sensitive areas lie in the path of the spreading plume. For the first time, planners can use high- tech visuals to develop more effective strategies for containment and response. The computer program is the brainchild of Superfund environmental scientist and Senior On-Scene Coordinator (OSC) Steve Jarvela who demonstrated the program to senior EPA managers in April. "It is the compilation of huge amounts of information from many sources, a Herculean task," according to Jarvela a biologist originally from Kodiak Island, Alaska, who now lives in Gloucester Township, NJ. "Until now, " Jarvela says, "this information was unavailable in one compact form. This allows planners to see the connection between regulated facilities and areas at risk ~ Economic, environmental, or public health." This program has tremendous value for emergency response teams and planners. It was developed for EPA Region III ~ Pennsylvania, Virginia, West Virginia, Maryland, Delaware and the District of Columbia, and is being distributed at no cost to each Local Emergency Planning Committee (LEPC) in each state. The program is available at a nominal fee to environmental groups, consultants, schools, and interest groups. "It's the first really user-friendly planning guide," said Thomas C. Voltaggio, Director of the Hazardous Waste Management Division for Region III, "You don't have to be a techie to understand it. It's the kind of tool that's going to allow a quick emergency response, meaning there will be less of a negative impact on people and the ecology. And in terms of planning and preparedness for future emergencies, the system is invaluable." To order the CD-ROM, fax your Page 2 ------- written request to Steve Jarvela at Fax# (215) 566-3254. HUNTINGTON / OHIO RIVER INLAND SUB- AREA CONTINGENCY PLANNING COMMITTEE A committee responsible for inland area contingency planning pursuant to the NCP - Subpart C to address spills/releases of oil or hazardous substances in EPA Region III Huntington/Ohio River inland sub-area is currently being formed. The Huntington/Ohio River sub-area encompasses Ohio River miles 121.6 to 317.0, Kanawha River, Big Sandy River, Little Kanawha River, and all West Virginia tributaries and includes the West Virginia counties of Wetzel, Tyler, Pleasants, Wood, Jackson, Mason, Putnam, Kanawha, Cabell, and Wayne. EPA Region III and USCG MSO-Huntington will be co-chairing the committee and are looking for participants from other federal, state, and local agencies or committees such as LEPCs, as well as industry/cooperative organizations. Representatives from adjoining EPA Regions IV and V and the states of Kentucky and Ohio are also being sought to coordinate area contingency planning in the Ohio River Valley area. A kick-off meeting for late August or early September is expected. Please contact OSC Jeffrey Dodd, EPA Region III at 304-234-0254, or Lt. Shawn Moon, MSO- Huntington at 304-529-5524 for additional information. REGULATIONS 1998 DEADLINE FIRM FOR UPGRADING STORAGE TANKS EPA will not extend the December 1998 deadline for upgrading, replacing, or closing underground storage tanks, according to a May 14 memorandum from EPA Administrator Carol M. Browner. Under regulations that EPA issued in 1988, owners and operators of underground storage tanks (USTs) storing petroleum and hazardous substances have until Dec. 22, 1998, to upgrade their tanks that do not meet federal requirements for protection against spills, overfills, and corrosion. These requirements are a key element in the ongoing state-EPA effort to prevent groundwater contamination. Browner has asked EPA and states to continue working with UST owners and operators to encourage compliance in advance of the 1998 deadline. LEGISLATION INTRODUCED Representatives Jim Moran (D-Va.) and Tom Davis (R-Va.), and Senators Charles Robb (D-Va.), Thomas Daschle (D-S.D.), and Alan Simpson (R-Wyo.) introduced the Aboveground Storage Tank Consolidation and Regulatory Improvement Act. This bill requires EPA to issue a regulation that consolidates all environmental laws and health and safety laws applicable to the construction, maintenance, and operation of aboveground storage tanks, and for other purposes to the Committee on the Environment and Public Works. REGIONAL TRAINING SPCC, FRP & ICP OUTREACH EPA Region III provided outreach in five cities during the month of May to over 300 people. The presentations were held in Roanoke, Richmond, and Norfolk, Virginia; Wheeling, West Virginia; and, Pittsburgh, Pennsylvania. The presentations covered Spill Prevention Control & Countermeasures (SPCC), Facility Response Plans (FRP), and Integrated Contingency Planning (ICP). The Virginia locations were chosen to geographically cover the State and were sponsored by Virginia Department of Environmental Quality (DEQ). The purpose of the outreach was to provide not only general awareness of the regulations, but also to provide EPA's insight and interpretation of the regulations. Attendees agreed that they were better able to return to their facilities and focus their spill prevention and response resources. Future presentations will be advertised in this publication. UPCOMING EVENTS INTEGRATED CONTINGENCY PLAN WORKSHOP EPA Region III and Fort Eustis are teaming up to provide a one day Integrated Contingency Plan (ICP) workshop. The workshop will be on Thursday, August 14, 1997 at Fort Eustis (Norfolk, Virginia Area). Both private industry and federal facilities are invited to attend this workshop. There will be a minor workshop fee of $5.00 to cover coffee and donuts. The ICP guidance or "one plan" concept was issued in June 1996 (see 61 FR 109, pg 28642). Many facilities are hoping to reduce their number of plans with this guidance. The goal of the workshop is to give the participants an understanding Page 3 ------- of the process and elements that go into the development of an effective ICP for their facility. Presenters from EPA Region III will provide their experience as to what makes a good ICP. In addition, the keynote speaker will be Anne Hay ward-Walker of SEA Incorporated. Ms. Hayward-Walker is a nationally known consultant on ICP development. Attendees will receive a training certificate from EPA Region III after completion of the workshop. For more information contact Ft. Eustis Tim Christensen at (757)878-1998 or Susan Kang at (757)878-2537. Registration: Due to limited seating there will be mandatory pre-registration by August 4, 1997. To pre-register fax (757)878-4589 or e-mail "tchristense@eustis.army.mil" your registration request along with: Name, Company, Address, Phone Number to Fort Eustis ICP Workshop. An information packet (IE, direction, etc) will be mailed to you. Payment will be collected at the workshop. API STORAGE TANK CONFERENCE The American Petroleum Institute (API) will sponsor a program this Fall on aboveground and underground storage tanks for tank owners, operators, designers, and inspectors. The second annual Underground and Aboveground Storage Tank Management Conference will be held September 9-11, 1997 at Bally's Hotel and Casino in Las Vegas. The Fall Conference is designed for professionals in storage tank management, will provide in-depth sessions on soil and groundwater cleanup, storage tank standards, and EPA regulatory guidelines for storage tank emissions. There will also be panel discussions, presentations and question and answer sessions on specific topics, including tank design and maintenance, and fire and safety considerations. For additional information, contact API at (202) 682-8187. THE 9TH ANNUAL CEPP CONFERENCE Pittsburgh, PA will be the site of U.S. EPA Region Ill's 9th Annual Chemical Emergency Preparedness and Prevention (CEPP) Conference, December 2-5, 1997 at the downtown Hilton Hotel and Towers. The conference theme is "If Not Us, Who?", and will feature an award winning smorgasbord of preparedness and prevention topics. Key topics covered at this year's conference will include: Crisis Management; Integrated Contingency Planning; Clean Air Act; Risk Management Planning; Oil Pollution Act; Exercise Design and Evaluation; Media Communications and Public Affairs Issues; Case Studies in Response, Enforcement, and Planning; Federal Facilities' Compliance Initiatives; LEPC and SERC Round table's; EPA Region Ill's innovative Chemical Safety Audit Program; and Environmental Crimes and Terrorism. For further information, or registration via the Internet site: http://www.vtec2.com, or call 1-888-429-6289, fax: (215) 357-3613. For exhibitor information contact Ray DeMichiei at (412) 255-4720. REGION III RRT MEETING The next regularly scheduled Region III RRT meeting will be held on September 23-25, 1997. The meeting will take place in Philadelphia, PA. For further information, contact Linda Marzulli at (215) 566-3256. SPCC IN FORMA TION SPCC Plan Certification The SPCC Plan must be certified by a professional engineer registered in any state; he or she may also be from the facility that he or she is certifying. The engineer certifies that the facility has implemented all the spill requirements listed in 40 CFR 112 or has the facility provide a schedule of when all discrepancies will be corrected. These discrepancies must be corrected in a timely fashion. INTERNET INFORMA TION WEBSITES The task of keeping up with the latest regulations and updates in the petroleum industry can be a full time job in itself. The internet can give you access to a wealth of information ranging from press releases to state regulations, to the most recent updates to industry standards. Some useful sites for the petroleum industry are as follows: www.api.org American Petroleum Institute homepage law.house.gov/cfr.htm Searchable version of the CFR from the House Law Library www.epa.gov Environmental Protection Agency homepage, from which individual region's homepages can be accessed Page 4 ------- ttnftp. rtpnc. epa. gov Technology Transfer Network, information on the Clean Air Act can be accessed through drive E clu-in.com Bulletin board covering topics related to remediation and hazardous waste, one special interest group includes AST owners www.wpi.edu/~fpe/nfipa.html National Fire Protection Association homepage Information taken from the AC&P Petroleum Report. This publication is now available via the internet. Go to EPA Headquarters internet web site: HTTP://WWW.EPA.GOV/oilspill/index.HTM. If you'd like to submit an article, comments, suggestions, etc., or receive your copy of this newsletter, please contact: Paula Curtin at (304) 234-0256, or you may send the information via Internet to: CURTIN.PAVIA @ EPAMAIL.EPA.GOV RRC III QUARTERLY FIGURES The Region III Response Center recorded and processed approximately 323 oil spill notification reports during the third quarter of Fiscal Year 97. Of the 323 reports, 6 spills resulted in accessing the Oil Spill Liability Trust Fund for cleanup and/or monitoring purposes. A total of 1,044 spills have been recorded to date. EPA REGION III SPCC & FRP HOTLINE Have a question on Spill Prevention, Control & Countermeasures (SPCC) 40 CFR 112.1 or Facility Response Plans (FRP) 40 CFR 112.20? EPA Region III has in place a hotline to answer these and other oil related questions. The hotline is staffed by the very people that will inspect your facility and review your spill plans. The hotline number is (215) 566-3452. Region III Oil Program Contacts: Karen Melvin (215) 566-3275 -Chief, Removal Enforcement and Oil Section Cordy Stephens (215) 566-3276 -Secretary Steve Jarvela (215) 566-3259 -On-Scene Coordinator -Inland Area Committee, Chair Linda Ziegler (215) 566-3277 -Oil Program Coordinator -Facility Response Plan (FRP) Coordinator -Oil Pollution Act -RRT, Area Committees, Port Area Committee -Spill Response Countermeasure (Dispersants) -Outreach Jean Starkey (215) 566-3292 -SPCC Coordinator -OPA Spill Penalty Program -SPCC Enforcement -Multi-Media Enforcement -Outreach Paula Curtin (304) 234-0256 -Oil Enforcement Coordinator -OPA Spill Penalty Program -Spill Investigations -Oil Program Activities Newsletter -Outreach Mike Welsh (215) 566-3285 -SPCC/FRP Inspector & Plan Reviews -Outreach Rob Sanchez (215) 566-3451 -SPCC/FRP Inspector & Plan Reviews -Outreach liernie Stepanski (215) 566-3288 -Spill Investigations Frank Cosgrove (215) 566-3284 -SPCC/FRP Inspections and Plan Review -SPCC Enforcement Support -Outreach Page 5 ------- Page 6 ------- |