Facility Oil Transfer Rule

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Facility Oil Transfer Rule
Washington State Department of EcologySpill
Prevention, Preparedness and Response Program
(SPPR)
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2004 Legislature - Set a Zero Spills Goalfor
WashingtonPurpose of the proposed rules is to
establish minimum prevention and response
standards for safe oil transfers in Washington
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Purpose of Oil Transfer Rules

• Risk based, scaled approach required by 2004/2006
  legislation to
• Prevent oil spills from oil transfer operations
  (prevention measures)
• Protect the environment by minimizing spill
  impacts from oil transfers (spill containment and
  recovery standards)
• Applies to oil transfers to non-recreational
  vessels of any size
• Applies to the deliverer, not the receiving
  vessel

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Facility Classifications

• Class 1
• Large Refineries, oil terminals, pipelines
• Class 2
• Tank trucks, railcars
• Class 3
• Small tank farms and terminals (transfers to
  vessels with a capacity of gt10,500 gallons)
• Class 4
• Marine Fueling Outlets, Marinas (transfers to
  vessels with a capacity lt10, 500 gallons).
  Includes boatyards servicing vessels lt 300 GT

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Marinas/Fuel Outlets -Spill Response Equipment

• Must have following onsite equipment and
  materials to clean up minimum 25 gallon spill
• 200 feet of boom ready for deployment
• Oil spill sorbent materials
• Shovels, buckets, containers, protective clothing

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Marinas/Fuel Outlets - Personnel Training

• Provide annual training for employees covering
• Safe oil transfer operating practices
• Safe use of spill response equipment
• Spill notification procedures
• Record keeping at the facility available for
  inspection

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Marinas/Fuel Outlets - Spill Notification

• Facility operator must provide spill notification
  information for employees or post at dock
  including
• State notification requirements ( RCW 90.56.280)
• Spill cleanup contractor phone number
• If facility unmanned, 24 hr. contact number

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Marinas/Fuel Outlets - Other Requirements

• Facility operator must ensure that oil transfer
  equipment is properly operated, maintained and
  tested according to manufacturers recommendation
  or industry standards to avoid spill risks
• Semi-annual reporting of type and volume of oil
  transferred

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Marinas/Fuel Outlets - Compliance Schedule

• Response equipment and personnel training to be
  completed within 120 days of effective date of
  rules (February 25, 2007)
• All other requirements October 26, 2006

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Class 3 Facilities - Oil Transfer Requirements

• Pre-load plans from receiving vessel that
  include
• Location and capacity of oil tanks
• Level and oil type in each tank prior to loading
• Final planned ullage or innage, volume of tank to
  be filled
• Sequence of tanks to be filled
• Vessels procedures for monitoring oil transfer

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Class 3 Facilities - Oil Transfer Requirements
(contd)

• Pre-Transfer Conference (also required by USCG)
  by Person(s) in Charge (PICs) that covers
• Pre-load plan
• Declaration of Inspection (DOI)
• Communications
• Emergency shutdown procedures
• Environmental conditions affecting safe transfer

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Class 3 Facilities - Oil Transfer Procedures

• Oil transfers must follow (USCG) approved
  operations manual
• Method to control spills from connections in oil
  transfer system
• Ensure sufficient capacity in receiving tanks
• Readily available means to immediately activate
  emergency shutdown system
• Maintain, test oil transfer equipment

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Advance Notification of a Transfer

• Class 1, 2 and 3 facilities
• 24 hours in advance of a transfer
• If scheduled in less than 24 hours notice must
  come ASAP.
• Will meet the Coast Guard advance notice
  requirement through a shared web based system

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QUESTIONS?
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(No Transcript)
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Tank Truck and Small Oil Terminals (Class 2 3)
- Facility Containment and Recovery Standards

• Requirements apply to all light products (e.g.
  diesel) except gasoline/aviation gas
• Facilities must choose to
• Pre-boom or
• Conduct alternative measures

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Pre-booming Requirements

• Deploy boom to contain transfer area
• Response equipment
• Trained personnel
• Within 1 hour of a spill, deploy additional 500
  feet of boom

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Alternative Measures

• Enough boom to completely surround vessel and
  transfer area
• Recovery equipment
• Trained personnel
• After 1 hour of a spill, 500 feet must be
  deployed
• After 2 hours of a spill, another 500 feet
  available for deployment

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Class 2 Facilities

• Oil Transfer and Response Requirements same as
  Class 3 (small oil terminals)
• Operations Manuals
• Training and Certification Program
• Oil Transfer Response Plans
• Drill Requirements

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Legal Issues with Vessel Rule

• Potential federal preemption concerns under Title
  I and II of the Ports and Waterways Safety Act
  and other federal statutes.
• Vessel equipment, operations, personnel
  qualifications, manning, lightering are primary
  issues of concern.
• Current vessel oil transfer rule does not address
  lightering, work hours, manning, automatic
  shutoff alarms, and high level alarms.
• Ecology can regulate the facility without federal
  preemption concerns

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Where to go from here?Coast Guard Ecology MOA

• USCG and Ecology sharing of advance notice of oil
  transfer data through joint use of web based
  system.
• Opportunities for both agencies to coordinate and
  target inspections of high risk vessels and oil
  transfer operations in Puget Sound, Columbia
  River and other areas.
• Build efficiencies into both agencies inspection
  activities given limited resources and competing
  workload priorities.
• Take advantage of staff expertise in both
  agencies.
• Great partnership towards spill prevention.

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Facilities and Vessel Rule

• Old Standards
• Facilities
• Four chapters
• Applies only to large facilities
• Vessels
• Covered vessels that conduct bunkering

• New Standards
• Facilities
• One chapter applies to class 1,2,3, and 4
  facilities
• Vessels
• Covered vessels that conduct bunkering and cargo
  oil transfer

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Class 1 Facilities

• Oil transfer and response requirements
• Design Standards for facilities
• Operations Manuals
• Training and Certification Program
• Prevention Plans
• Class 1 facilities must comply with the
  Contingency Planning Rule (Chapter 173-182 WAC)

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Vessel Oil Transfer Rule

• Oil transfer requirements for all covered vessel
  oil transfer operations
• Specific requirements for
• Bunker (fuel and lubricants) oil transfers
• Keep requirements in existing rule
• Add number of prevention requirements including
  oil transfer restrictions
• Cargo Oil transfers
• Cargo transfer plan
• Oil transfer restrictions when environmental
  conditions threaten safe oil transfer operations

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Containment and Recovery Standards

• Apply to Class 1, 2, and 3 facilities and all
  covered vessels
• Standards are broken into two categories
• Rate A transfers gt 500 gpm
• Rate B transfers - lt 500 gpm

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Containment and Recovery Standards Rate A

• Deliverers transferring at Rate A (over 500 gpm)
  must
• Meet the pre-booming requirements when safe and
  effective
• Use alternative measures when pre-booming is not
  possible.
• Note The deliverer makes the decision when it is
  safe and effective

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Rate A Pre-booming Requirements

• Access to boom 4x length of largest vessel
• Deploy enough boom to provide transfer
  containment
• Recovery equipment
• Trained personnel
• Within 1 hour of a spill, deploy remaining boom

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Rate A Alternative Measures

• Access to boom 4x length of largest vessel
• Recovery equipment
• Within 30 minutes be able to track and respond
  safely at night and low visibility situations
• Within 1 hour of a spill, deploy remaining boom
• Within 2 hours, have a Skimming system and
  additional boom 4x length of largest vessel
  onsite

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Pre-boom Standards

• Pre-booming is a standard practice in several
  coastal States
• No state addressed the very complicated issue of
  determining the safety of personnel and the
  effectiveness of boom in all the situations at
  transfer areas

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Pre-boom Standards

• Standards are based on oil transfer rates
• Same standards applies to facilities and vessels
• Rate A MUST pre-boom unless not safe and
  effective.
• Rate B Option to pre-boom or boom after a spill.