Storage Tank Systems for Petroleum Products and Allied Petroleum Products Regulations

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Storage Tank Systems for Petroleum Products and
Allied Petroleum Products Regulations

• Waste Programs
• Environment Canada
• Ontario Tribal Council, Large Unaffiliated
  First Nations Meeting
• October 24, 2013
• Sault Ste Marie, ON

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Purpose of Regulations

• To reduce leaks and spills from fuel storage
  tanks
• Leaks and spills from fuel storage is single
  greatest cause of contamination on bands lands
• Most common cause of problems is poor
  installation
• Second most common cause is poor practices when
  fuel is delivered

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What is wrong with this installation?

• Proper tank design and installation prevents
  problems

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What is wrong with these installations?

• Poor tank installation may put your community at
  risk

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Application of the Regulations

• Video pilot project Looking for your help
• Survey

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Snapshot of Obligations

• Obligations were phased in over 4 years
• On June 2012, Regulations were fully in force
• Prohibited practices
• Leaking storage tank systems cannot be operated
• Unidentified storage tank systems cannot be
  operated, i.e. filled
• Installation, withdrawal from service, and
  removal of a storage tank system must only be
  performed by certified persons
• Minimum technical standards for design and
  installation based on national standards and
  codes of practice

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Snapshot of Obligations (continued)

• Register and label STS
• Emergency plan
• Keep records for five years or longer
• Report leaks to Minister
• Regularly inspect for leaks
• Systems installed by specified entities
• Design plans, drawings and specifications that
  bear stamp and signature of professional engineer
  
• Replace high-risk tanks (2012)
• Product transfer area designed to contain spills
  (2012)

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What are the most common problems?

• Incomplete emergency plan
• Improper installation
• Lack of leak detection testing and maintenance
• High-risk tanks in service
• Poor design and set-up product transfer areas to
  contain spills during fuel transfer
• Poor record keeping
• Lack of identification

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High risk tanks

• Only 3 FSTS still in service in Ontario located
  on First Nation Lands identified in FIRSTS
• Are they really still in service?
• Is it an identificaiton mistake?

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Emergency Plans

• Emergency plan tells response team what to do if
  something goes wrong such as a leak or spill
• Includes location of spill equipment, contact
  numbers, training
• Often emergency plans are missing name, phone
  number or responding procedures and communication
  plan
• 50 of identification in FIRSTS do not specify
  the location of plan

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Leak Detection

• When a leak starts leak detection helps to
  minimize harm
• For an aboveground tank, leak detection could be
  as straightforward as regularly walking around
  the tank and piping looking for leaks
• Many tanks now come with leak detection installed

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What is a Product Transfer Area?
CURB
The area around the connection points between a
delivery vehicle and STS
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Product Transfer Areas (PTAs)

• Prevent problems by helping to contain spills
  that occur during tank filling
• A good PTA should be designed to contain
  sufficient volume to contain most spills

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Product Transfer Areas

• There are several systems that have not indicated
  they have a design in place

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Identification On-line - To Obtain System ID
On-line www.ec.gc.ca
FIRSTS
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Identification - Paper Form
Remember Fuel deliverer could be in violation if
they fill tank without an ID
(Page 1 of 6)
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Spill reporting

• 5 incidents reported in Ontario in 2012
• No Enforcement inspection where non-compliance
  found
• UseSpill Reporting Lines Across Canada
• In Ontario Spills Action Centre
• 1-800-268-6060

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Keep Secondary Containment Empty

• Poorly maintained secondary containment can be
  problematic
• Keep secondary containment free of water, and do
  not use it for storage

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What happens if an EC Enforcment Officer (EO)
inspects your system?

• Will identify themselves and ask questions about
  your tank system and other requirements of the
  regulations
• Will look for ID number and may ask to see some
  documentation (e.g. emergency plan, maintenance
  records, leak detection records, etc.)
• If a problem is found, EO will typically let you
  know what it is and may give you a timeframe to
  address it
• Most 2 common types of tools used to address a
  violation
• Warning Letter
• Environmental Protection Compliance Order (EPCO)

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Available resources

• Useful websites
• ECs Storage Tank website for Petroleum and
  Allied Petroleum Products http//www.ec.gc.ca/st
  -rs/. Contains link to Regulations.
• CCME Environmental Code of Practice for
  Aboveground and Underground Storage Tank Systems
  Containing Petroleum and Allied Petroleum
  Products http//www.ec.gc.ca/ceparegistry/docume
  nts/regs/CCME/toc.cfm
• Compliance and Enforcement Policy for the
  Canadian Environmental Protection Act, 1999
  -http//www.ec.gc.ca/CEPARegistry/documents/polici
  es/candepolicy/toc.cfm
• National Fire Code of Canada http//www.nationalco
  des.ca/nfc/index_e.shtml

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Available Resources (continued)
Lisa McClemens, Environment Canada Ontario
Region lisa.mcclemens_at_ec.gc.ca (613)
949-8278 Aaron Dornan, Environment Canada
Headquarters Gatineau aaron.dornan_at_ec.gc.ca
[phone] Marie-Michelle Modéry,
Environment Canada Headquarters
Gatineau marie-michelle.modery_at_ec.gc.ca (819
) 953-0459 General inquiries TankRegistry_at_ec.gc.
ca
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Thank You
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Appendix A- Leak detection overview