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KALTAG SCHOOL
OIL STORAGE
KALTAG, ALASKA
PREPARED TO SATISFY:
AUGUST 2016
2016 AMENDED
PAGE #’s
Title page Record of Revision included, documentation of 5 year review & evaluation inserted
I-4, 1-5, II-5, II-6 Contractor information updated
The above amendments do not constitute technical changes to the facility, therefore
recertification of this SPCC Plan by a Professional Engineer (PE) is not necessary.
YUKON KOYUKUK SCHOOL DISTRICT
EPA REGULATIONS (40 CFR §112.5(B)) REQUIRE A DOCUMENTED REVIEW AND EVALUATION
OF THE SPCC PLAN AT LEAST ONCE EVERY FIVE YEARS. THE SPCC PLAN IS TO BE
UPDATED WHENEVER THERE IS A CHANGE IN FACILITY DESIGN, CONSTRUCTION,
OPERATION, OR MAINTENANCE THAT COULD MATERIALLY AFFECT THE POTENTIAL FOR
DISCHARGE TO NAVIGABLE WATER. TECHNICAL AMENDMENTS TO THE PLAN ARE TO BE
CERTIFIED BY A PROFESSIONAL ENGINEER.
I have completed the five year management review and evaluation of the SPCC Plans for the
oil storage at the following YKSD schools.
Allakaket Allakaket Airport Hughes Huslia Kaltag
Koyukuk Manley Minto Nulato Ruby
There have been no changes in facility design, construction, operations, or maintenance that
could materially affect the potential for discharge to navigable water. It is my understanding
no technical changes have occurred, therefore, recertification of the SPCC Plans by a
Professional Engineer is not necessary.
Administrative amendments, including updated names, phone numbers, and contractor
information have been completed. Revised pages have been inserted into the SPCC Plans
and labelled with a footer date of08/16 (August 2016).
Signature:
Name:
Title:
Date:
08/16
CERTIFICATION
SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN
KALTAG SCHOOL OIL STORAGE
Facility Location
Kaltag is on the west bank of the Yukon River, 75 miles west of Galena and 335 miles west of
Fairbanks. Geographic coordinates of Kaltag are 64° 20' N, 158° 43' W. The community tank
farm is on Eighth Avenue at “A” Street. It is about 800 feet west of the Yukon River. The
School is located about 2,000 feet southwest of the community tank farm on a bluff above the
Yukon River.
Mailing Address
Yukon Koyukuk School District
4762 Old Airport Way
Fairbanks, Alaska 99709
Facility Responsible Person
Kerry Boyd
Superintendent of Schools
(907) 374-9400 - phone
(907) 374-9440 - fax
Management Approval
This SPCC Plan for the Kaltag School oil storage will be implemented as described herein.
Yukon Koyukuk School District
_________________________
Kerry Boyd, Superintendent of Schools
Date: ____________________
____________________________ 8/29/14
Date: _________
Steve Stassel, P.E. Registration No.: ME 8601, Alaska
i 08/14
TABLE OF CONTENTS
SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN
KALTAG SCHOOL OIL STORAGE
Section Page
CERTIFICATION .......................................................................................... i
TABLE OF CONTENTS ............................................................................... ii
FIGURES
Figure Page
1. Location Map ................................................................................................ I - 6
2. Area Plan / Community Tank Farm .............................................................. I - 7
3. Community Tank Farm Piping Plan .............................................................. I - 8
4. School Site Plan ........................................................................................... I - 9
APPENDIX
Appendix Page
A. Engineer’s Observations .............................................................................. A - 1
B. Self-Inspection Logs / Documentation .......................................................... B - 1
C. IT Tank Fill Procedure, TT Sequence of Operations .................................... C - 1
ii 08/14
I. INTRODUCTION
40 CFR Part 112.7 (a)
A. Regulatory Compliance
The Environmental Protection Agency (EPA) adopted 40 CFR, Part 112 in 1974, and
substantially amended it in August 2002. Subsequent amendments were adopted through 2011.
These oil pollution prevention regulations require the preparation of a Spill Prevention Control
and Countermeasure Plan (SPCC) for facilities with aboveground oil storage in excess of 1,320
gallons, and which due to their location could reasonably be expected to discharge oil in harmful
quantities into or upon the navigable waters of the United States or adjoining shorelines. The
SPCC regulations apply to all tanks (containers) 55-gallons and larger, to each “non-
transportation” fuel transfer system, and to mobile/portable containers when positioned at
regulated facilities in a “non-transportation” mode.
The EPA regulated portion of the School fuel system consists of four bulk storage tanks in the
community tank farm which provide total storage capacity of 34,100 gallons, and five tanks at
the School which provide total capacity of 10,675 gallons. The tank farm is approximately 800
feet west of the Yukon River. The School is on a bluff above the Yukon River.
The content of the SPCC Plan is to follow the sequence outlined in 40 CFR, Parts 112.7-12. The
Plan is to be prepared in accordance with good engineering practices to prevent and mitigate
damage to the environment from oil spills. The Plan must be certified by a licensed Professional
Engineer and must have the full approval of management at a level with authority to commit the
necessary resources.
The Plan must be available to facility operators and agency inspectors. Facility management is
to review and evaluate the Plan at least once every five years, and update it within six months
whenever there is a change in facility design, construction, operation, or maintenance that could
materially affect the potential for discharge to navigable water. The review is to be documented.
Technical amendments to the Plan are to be certified by a Professional Engineer.
EPA regulations further stipulate, in 40 CFR, Part 112.4, that a written report must be submitted
to the EPA Regional Administrator, and appropriate state agency, when a facility has discharged
more than 1,000 gallons in a single discharge, or discharged more than 42 gallons in each of two
discharges within any 12 month period that enter navigable waters or adjoining shorelines. The
report must include:
1. Name of facility;
2. Your name;
3. Location of the facility;
4. Maximum storage or handling capacity of the facility and normal daily throughput;
5. Corrective action and countermeasures you have taken, including a description of
equipment repairs and replacements;
6. An adequate description of the facility, including maps, flow diagrams, and
topographical maps, as necessary;
7. The cause of the discharge, including a failure analysis of the system or subsystem in
which the failure occurred;
8. Additional preventive measures you have taken or contemplated to minimize the
possibility of recurrence; and
9. Such other information as the EPA Regional Administrator may reasonably require
pertinent to the Plan or discharge.
EPA regulations also require preparation and submittal of an oil spill response plan from
facilities that can cause "substantial harm" due to potential oil spills. Each operator is to review
the EPA applicability of substantial harm criteria and, if necessary, prepare a Facility Response
Plan (“FRP”) in accordance with 40 CFR, Part 112.20. The Kaltag School meets EPA
substantial harm criteria, and a FRP has been prepared and submitted to the EPA and Coast
Guard.
I-1 08/14
B. Facility Description
• Figure 1 is a location map.
• Figure 2 is an area plan with community tank farm detail.
• Figure 3 is a community tank farm piping plan.
• Figure 4 is a school site plan.
The Yukon Koyukuk School District (“YKSD”) operates the Kaltag School (“School”) and its
related oil storage tanks and piping (“Facility”) which supply fuel for School heat and backup
power generation. Diesel fuel is the only oil stored in bulk. Total annual fuel throughput is
about 18,000 gallons.
The EPA regulated portion of the School fuel system consists of four bulk storage tanks in the
community tank farm which provide total storage capacity of 34,100 gallons, and five tanks at
the School which provide total capacity of 10,675 gallons. The community tank farm also
contains fuel storage tanks that are separately owned, operated, and maintained by the City of
Kaltag and Kaltag Cooperative. Fuel is delivered to the community tank farm by barge via a
1,000 foot marine pipeline which is individually operated by the three tank farm operators when
fuel is being delivered to their respective tanks.
Fuel is transferred from the community tank farm via a 2,500 foot pipeline to a 6,600 gallon
intermediate tank at the School. From the intermediate tank fuel is transferred to a 75 gallon day
tank in the boiler building and to a 1,000 gallon transfer tank which is used to fill nearby heating
fuel tanks and a backup generator day tank.
The community tank farm, marine pipeline, School pipeline, and intermediate tank were installed
in 1998/9 as part of a State of Alaska bulk fuel upgrade project. The upgrade project included
preparation of an SPCC Plan for the community tank farm as a single, co-located, cooperatively
operated entity. The 1999 SPCC Plan was in place until 2014, at which time YKSD elected to
prepare this SPCC Plan which specifically covers the School fuel system components and
regulatory requirements for which YKSD is responsible. YKSD is responsible for the operation
of the School fuel system which includes its four tanks in the community tank farm, the transfer
pipeline to the School, and all tanks at the School. In addition, YKSD is responsible to ensure its
portion of tank farm impound complies with SPCC requirements.
The School receives fuel by marine delivery normally once a year. There is no dock, therefore
the barge beaches or anchors near shore and extends its hose to the marine pipeline fill point
connection (header). All fuel is transferred by pipeline to the intermediate tank at the School.
Pipeline transfers to the intermediate tank at the School generally occur once a month.
Community Tank Farm – School Storage Tanks, Secondary Containment, Piping
The School bulk storage consists of the following tanks:
TANK DIAMETER VERTICAL / REHAB OR CAPACITY
LOCATION X PRODUCT INITIAL
NO. HORIZONTAL (GALS)
HGT-LENGTH SERVICE DATE
ST-11 TANK FARM 9.5’ x 13’ 10” V DIESEL 1998/9 7,300
ST-12 “ 10’ x 13’ 10” “ “ “ 8,100
ST-13 “ 11’ x 13’ 10” “ “ “ 9,800
ST-14 “ 10.5’ x 13’10” “ “ “ 8,900
School Total: 34,100
The original dates of purchase and/or service of the storage tanks are unknown. In 1998 they
were relocated from existing local service and entirely refurbished. Each tank was drained,
cleaned, and visually inspected, internally and externally, for evidence of corrosion and for weld
integrity. Necessary repairs were made and new appurtenances installed. The tanks were
sandblasted and painted. The tanks are vertical “BIA” type tanks equipped with normal and
I-2 08/14
emergency vents, water draw valves, three-inch fill connections, and liquid level gauges. They
are positioned on treated timbers on grade.
The tanks are within the community tank farm which is a diked and lined impound
approximately 85’x 65’. It is surrounded by an earthen dike approximately two-feet high. The
impound floor and dike walls are covered with a fuel resistant liner that is covered with gravel.
Net capacity of the impound is approximately 65,000 gallons, which provides containment for
the contents of the largest tank plus more than 12 inches of freeboard for precipitation. Drainage
within the impound is to a collection sump in the southeast corner of the tank farm.
Accumulated stormwater is removed from the sump with a hand or portable pump.
Fuel is delivered to the tank farm via a three-inch marine pipeline that runs about 1,000 feet from
the tank farm to a marine fill point header located about 75 feet from the river. The pipe is
buried, schedule 80, welded steel that is coated and cathodically protected with magnesium
anodes. The marine header is a capped camlock fitting with three-inch check and ball valves. A
steel, two-barrel drip pan (spill box) is positioned beneath the header. The header is protected by
steel bollards.
Within the tank farm the fill and distribution pipelines pass through ball valves located where the
piping enters/exists the impound. The valves are used to isolate each pipeline that is not in
service. Tank farm piping is two and three-inch schedule 40, black steel. Joints are welded,
except for flanged and threaded joints that connect to valves and pumps. The tank farm piping is
equipped with steel flex connectors, pressure relief valves, check valves, and strainers. The
storage tank fill/withdrawal connections are three-inch ball valves. Piping is secured with pipe
straps to steel and timber supports.
The transfer pipe from the tank farm to the School intermediate tank is welded two inch diameter
steel about 2,500 feet in length. The pipe parallels the washeteria pipeline. It is above ground
except where it passes subsurface under roadways, where it is protected within culvert pipe.
Fuel is transferred to the intermediate tank by manually starting the transfer pump using controls
mounted on the intermediate tank. The pipe is located away from vehicle driving areas except
for the road crossings where it is subsurface in a carrier pipe.
School Tanks
The intermediate tank (#IT-1) at the School is a 6,600 gallon, 95”’Ø x 18’, horizontal, double
wall, skid mounted, UL 142 tank. It is equipped with normal and emergency vents, liquid level
gauge and high level shut off switch that controls the transfer pump in the tank farm. The 1998
SPCC Plan states the tank is equipped with a float actuated fill limiting valve. The electrical
control panel for the pump is mounted on the end of the tank. Fuel oil supply and return pipes
extend from the top of tank to a 75 gallon day tank (#DT-1) in the boiler building adjacent to the
intermediate tank. The day tank is a Simplex SRS75 package tank with auto-fill controls,
redundant overfill protection, alarms, and rupture basin. A submersible pump in IT-1 also
transfers fuel to a 1,000 gallon transfer tank via a 1½ inch welded steel pipe that runs on grade
about 365 feet and is equipped with two normally closed solenoid valves. The transfer tank
(#TT-1) is a horizontal, 5’6”Ø x 7’4”’, double wall, skid mounted, UL 142 tank. The tank was
installed new in 2012. It is equipped with normal vent with whistle alarm, emergency vents,
liquid level gauge, overfill protection valve, and pump and alarm float controls. The electrical
control panel for pump, float controls, alarms, and emergency shutdown pushbutton is mounted
on the end of the tank. A pump next to the tank with hose and hand-held nozzle is used to
transfer fuel from the tank to seven nearby heating fuel tanks and a backup generator day tank.
All heating fuel tanks are 500 gallon, horizontal, 46”x73”, single wall tanks on steel stands with
fuel lines into adjacent buildings. Five of the seven heating fuel tanks supply single family
I-3 08/14
teacher housing units, therefore are exempt from SPCC requirements. One heating fuel tank
(#HFT-1) supplies the vocational education building and a second (#HFT-2) supplies a teacher
housing duplex, therefore are subject to SPCC requirements. The backup generator day tank
reportedly has capacity less than 55 gallons, therefore is not subject to SPCC requirements.
Security
The School may receive, or transfer seven days a week. Transfers from the tank farm to the
intermediate tank normally occur once a month. School personnel normally observe the
intermediate tank, transfer tank, heating fuel tanks and exposed pipe during daily routine duties.
The tank farm is normally observed daily by the other tank farm operators who conduct
dispensing operations from the tank farm. At least once a month, the School Site Principal /
Head Teacher, or designated alternate, is to conduct and document a thorough visual inspection
of the entire School fuel system. Any fuel system discrepancies, leaks or potential discharge, or
items which are in need of maintenance are to be reported to the YKSD Director of Facilities and
Maintenance or the Maintenance Mechanic in Fairbanks.
Leak detection is by visual monitoring or inventory discrepancy. There are no automated leak
detection systems in the School fuel system.
The community tank farm is enclosed by an eight-foot high chain-link fence, topped with barbed
wire. All entrance gates to the tank farm are to be closed and locked when the area is
unattended. Bottom-penetration valves on storage tanks and transfer pipeline isolation valves at
the entry/exit to the tank farm are to be closed and locked when transfers are not being
conducted. Two pole mounted area lights illuminate the tank farm.
The School intermediate and transfer tanks are double wall construction with top-mounted
penetrations. The pump control panels are energized from breakers in the tank farm and in the
backup generator shed, both of which are to remain locked when unattended. The boiler day
tank is within the boiler building which is to remain locked when unattended. School personnel
observe the tanks during normal duties and are instructed to be alert to notice security issues and
to report leaks to the School Site Principal / Head Teacher. Area lighting at the School provides
some illumination of the tanks. Portable, hand-held lighting is available for inspections
conducted during hours of darkness.
Labels are to be maintained on the storage, intermediate, and transfer tanks to identify product
stored, tank capacity, and tank number. No smoking and emergency notification placards are to
be posted. Fire extinguishers are to be maintained near the entrance gates to the community tank
farm and near the intermediate and transfer tanks.
C. Operating Procedures
All fuel transfers are manually initiated and visually monitored, with the exception of the boiler
day tank which is auto fill.
Written procedures that address routine fuel handling and transfer procedures are to be
maintained at the School, reviewed with fuel handling personnel, and updated as necessary. It is
recommended basic procedures be posted near primary transfer locations.
Marine delivery procedures are addressed in the Facility Coast Guard Operations Manual.
Appendix C of this SPCC Plan contains the intermediate tank fill procedure that was prepared as
part of the installation in 1999, as well as the transfer tank sequence of operations prepared by
the tank manufacturer.
YKSD has contracted Frontier Fuel Service (FSS) to provide spill prevention, response, and
compliance assistance at all of its schools. FSS services include on-site maintenance, required
I-4 08/16
inspections and tests, discharge prevention training, and spill response including Qualified
Individual responsibilities and authority. FSS is a Wasilla based corporation organized to
contract for the operation and maintenance of rural Alaskan bulk fuel storage facilities.
I-5 08/16
COMMUNITY TANK FARM
SCHOOL
I-6
'Nulato B-6 63K; AK'; Scale: 1" = 0.789Mi 1,270Mt 4,167Ft, 1 Mi = 1.267" , 1 cm = 500Mt
THE AREA SUBJECT TO COAST GUARD JURISDICTION IS THE MARINE TRANSFER AREA (PIPELINE AND HOSE) BETWEEN
FUEL BARGE THE VESSEL, OR WHERE THE VESSEL MOORS, AND THE FIRST MANIFOLD OR SHUTOFF VALVE ON THE PIPELINE
COMMNITY MOORNIG AREA ENCOUNTERED AFTER THE PIPELINE ENTERS THE SECONDARY CONTAINMENT AREA AROUND THE BULK STORAGE
TANK FARM TANKS. EPA JURISDICTION EXTENDS “INLAND” FROM THE FIRST VALVE IN THE TANK FARM TO ALL TANKS AND TRANSFER
LOCATIONS. SEE FIGURE 3.
MARINE HEADER
& PIPELINE
MARINE PIPELINE
WASHETERIA
SCHOOL TANKS
SEE FIG. 3
SCHOOL PIPELINE
SCHOOL
FIGURE 2.
SCHOOL SPILL RESPONSE AREA PLAN
EQUIPMENT STORED IN
GENERATOR BLDG.
SCHOOL
INTERMEDIATE TANK I-7
SCHOOL
TANKS #'S 11-14
FIGURE 3.
PIPING PLAN
I-8
TEACHER HOUSING - DUPLEX
HEATING FUEL TANK (#HDT-2)
500 GALS.
SCHOOL
YUKON RIVER
INTERMEDIATE TANK (#IT-1)
6,600 GALS..
POWERHOUSE
BACKUP GENERATOR
MECHANICAL / BOILER BLDG.
DAY TANK (#DT-1)
75 GALS.
VOC. ED BUILDING
HEATING FUEL TANK (#HFT-1)
500 GALS.
TEACHER HOUSING -
SINGLE FAMILY UNITS
HEATING FUEL TANKS
5 EA. - 500 GALS. EA.
I-9
II. GENERAL INFORMATION
40 CFR Part 112.4 (a)
40 CFR Part 112.7 (b)-(k)
A. Written Spill Reports - 40 CFR Part 112.4 (a)
This section of the regulations requires a written report be submitted to the EPA Regional
Administrator, and appropriate state agencies, when a facility has discharged more than 1,000
gallons of oil into navigable waters, or adjoining shorelines, or if it has discharged more than 42
gallons in two separate instances within a 12 month period into navigable waters, or adjoining
shorelines. The content of the report is listed in Section I.A of this Plan.
Federal and state spill reporting requirements are listed in the Facility Response Plan.
II - 1 08/14
C. Containment Structures - 40 CFR Part 112.7 (c)
“Specific” secondary containment requirements in 40 CFR 112.8(c) apply to all storage
tanks/containers 55 gallons and larger, and require “sized” secondary containment capacity for
the volume of the single largest tank/container in the storage area plus freeboard for
precipitation. The containment must be sufficiently impervious to prevent discharged oil from
impacting navigable water or adjoining shorelines. The volume of freeboard is to be determined
in accordance with good engineering practice, and should be adequate to contain the
precipitation from a 25-year, 24-hour storm event; or where sufficient precipitation information
is not available the net dike volume should be sufficient to contain 110% of the capacity of the
largest storage tank within the dike. Double wall and self-diked tanks satisfy specific
requirements provided they have redundant overfill protection and comply with good
engineering practice.
“General” secondary containment requirements in 40 CFR 112.7(c) apply to all other facility
components regulated by the EPA including piping, transfer areas, and oil-filled operational
equipment. General containment may be achieved by a variety of means including (“non-sized”)
berms, drainage, or “active” containment (spill response), provided it is adequate to prevent the
most likely discharge volume from impacting navigable water.
Facility tanks/containers subject to “specific” secondary containment are as follows:
Tank / Container Means of Specific Secondary Containment Comments
Community Tank Tanks are within a diked and lined impound approximately Meets intent of 40
Farm 85’x 65’ surrounded by an earthen dike approximately two- CFR 112.8
Storage Tanks feet high. Net capacity of the impound is approximately
#ST-11 - 7,300 gals. 65,000 gallons which provides containment for the volume of
#ST-12 - 8,100 gals. the largest tank plus more than 12” of freeboard for
#ST-13 - 9,800 gals. precipitation. The extreme 24 hour precipitation recorded in
#ST-14 - 8,900 gals. Galena (60 miles NE of Kaltag) is 2”. (Western Region
Climate Center).
School The tanks are double wall, U.L. 142 construction equipped Meets intent of 40
Intermediate Tank with liquid level gauge and high level pump shutoff controls. CFR 112.8
#IT-1 - 6,600 gals. The transfer tank is equipped with an overfill protection valve
Transfer Tank and high level alarm. The intermediate tank is reportedly
#TT-1 – 1,000 gals equipped with a fill limiting valve. Tank filling is manually
initiated and visually monitored by an operator who has direct
access to pump shutdown controls.
Boiler Bldg. Day Tank The boiler building day tank is equipped with auto fill Meets intent of 40
#DT-1 – 75 gals controls, redundant overfill protection devices, alarms, and is CFR 112.8
located within a rupture basin with containment capacity in
excess of the tank capacity.
Heating Fuel Tanks Single wall tanks with no secondary containment. Secondary
Voc. Ed. Building containment must be
#HFT-1 – 500 gals. provided to comply
Teacher Housing with 40 CFR
Duplex 112.7(Appendix A)
#HFT-2 – 500 gals.
Facility piping and transfer areas subject to “general” secondary containment are:
Means of General Secondary Containment Comments
Pipe in Undiked Areas Active secondary containment measures are considered Meets intent of 40
Transfer Piping from adequate to prevent the most likely discharge from impacting CFR 112.7
Tank Farm to navigable water. The determination is based on transfer
Intermediate Tank and to procedures, location and potential discharge volume and the
Transfer Tank. availability of response equipment and personnel described in
the FRP.
Transfer Areas Same as above. Meets intent of 40
Heating Fuel Tank Fill CFR 112.7
from Transfer Tank.
II - 2 08/14
D. Demonstration of Impracticability - 40 CFR Part 112.7 (d)
This section of the regulations states that if it is determined impracticable to provide secondary
containment, then additional prevention/response measures are to be implemented.
It is not impracticable to install secondary containment measures at this location.
II - 3 08/14
• Tanks with capacity of 5,001 gallons or more (School storage tank #’s ST-11, 12, 13, 14
and intermediate tank #IT-1) are subject to a Formal Inspection every 20 years, or as
determined by previous inspections. The inspection shall be conducted by a qualified
tank inspector. Tanks without secondary containment and/or from which a release cannot
be detected by direct visual observation, and double wall tanks without overfill protection
are subject to additional and more frequent certified inspections and leak tests.
• In the event of severe weather (snow, ice, wind storms) or maintenance (such as painting)
that could affect the operation of critical components (normal and emergency vents,
valves), an inspection of these components is required immediately following the event.
• Tanks subjected to damage caused by the following conditions require evaluation by an
engineer experienced in tank design or a tank manufacturer who will jointly with the
owner determine if an immediate formal external or internal inspection is required:
FIRE
NATURAL DISASTER (flooding, winds, etc. that has lifted or damaged the tank)
EXCESSIVE SETTLEMENT
OVERPRESSURE (tank exposed to excessive internal pressure caused by overfill or
failure of venting device or other reason)
DAMAGE FROM CRACKING – evidence of cracking of welds or steel surface
• If a leak is discovered at any time, the tank must be repaired, replaced or closed and
removed from service in accordance with good engineering practice.
Liquid Level Sensing Devices Inspections, Tests
40 CFR 112.8(c)(8) requires at least one means of liquid level detection or sensing device be
provided for each tank. 40 CFR 112.8(c)(8)(iii) allows that if there is “direct audible or code
signal communication between the container gauger and the pumping station”, it meets the basic
requirement of this part. 40 CFR 112.8(c)(8)(v) requires where liquid level sensing devices are
installed they be tested regularly to ensure proper operation. 40 CFR 112.7(e) requires written
procedures for required tests and inspections.
To comply with Part 112.8(c)(8)(iv), the storage tanks, intermediate tank, and transfer tank are
equipped with a clock-type level gauge. The gauges shall be visually inspected prior to each
tank filling. The gauges shall be tested at least once per year to verify accuracy and proper
mechanical operation. Testing may be performed with a gauge stick or tank strapping tape to
confirm correct level indication. If the gauge does not indicate the correct level, it shall be
inspected for damage and calibrated in accordance with manufacturer’s instructions. The gauge
shall be monitored during tank fill operations to confirm correct level and mechanical operation.
If the gauge does not operate correctly, the transfer shall be stopped, the gauge shall be repaired
or replaced and calibrated in accordance with manufacturer’s instructions. If the gauge cannot
be repaired immediately, fueling shall only commence if the liquid level is continuously
manually monitored in a safe manner during tank filling.
In accordance with good engineering practice and to avoid overfill discharge, the tanks at the
School are also equipped with following liquid level sensing devices with setting information as
listed by the manufacture, installer, or design drawings.
Intermediate Tank
• High level switch de-energizes transfer pump, close valve at 95% tank capacity
• Float actuated fill limiting valve - setting unknown
Transfer Tank
• High level whistle vent set at 90% capacity
• High level switch de-energizes transfer pump, closes valves at 90% tank capacity
• Critical high level switch cuts power to transfer pump, sounds alarm at 95% tank capacity
II - 4 08/14
Boiler Day Tank
Electronic level gauge
Low level switch energizes pump, opens valves at 50% tank capacity
High level switch de-energizes pump, closes valves at 90% tank capacity
Critical high level switch cuts power to pump, sounds alarm at 95% tank capacity
These devices are not continuous level sensing devices, and only actuate at single set points. The
actuating devices are within the tank interior and are not readily accessible. These devices shall
be tested while in service by periodically monitoring tank fill cycles to confirm proper operation.
The devices shall be tested annually by controlling fill cycles or manually actuating the devices.
If proper operation of a level sensing device does not occur, it shall be removed from the tank for
further examination and testing. Inspection, testing, and calibration shall be in accordance with
manufacture’s recommendation and conducted by a qualified person.
Records
The following additional inspections and records are required by EPA and are applicable to the
Facility:
Stormwater is to be removed frequently from the community tank farm impound. A
written log is to be completed each time stormwater is discharged from the impound.
Stormwater discharge procedures are described in Section III.B of this Plan.
Oil handling personnel are to be trained in operations, maintenance and discharge
prevention procedures pertinent to their duties. Training is to be conducted, at minimum,
on an annual basis and is to be documented. Training requirements are addressed in
Section II.F of this Plan.
An oil spill notification and report form is to be completed and maintained for each oil
discharge resulting from Facility fuel operations. Spill reporting requirements are
addressed in Section I.C of this Plan.
EPA requires a documented review and evaluation of this SPCC Plan at least once every
five years. It is to be updated whenever there is a change in facility design, construction,
operation, or maintenance that could materially affect the potential for discharge to
navigable water.
The Steel Tank Institute (STI) Standard SP001 “Standard for the Inspection of
Aboveground Storage Tanks”, Section 11 – Recordkeeping, states an AST (Aboveground
Storage Tank) Record is to be completed and retained for the life of each regulated AST.
The purpose of an AST Record is to document basic information including owner,
facility and installer information, and tank specifics including design, manufacture,
contents, construction date, repairs, dimensions, capacity, construction data, and means of
secondary containment, method of release detection, and type of release prevention
barrier. Appendix B contains the STI-SP001 Aboveground Storage Tank (AST) Record
suitable for recording tank information.
The YKSD Maintenance Director in conjunction with the Site Principal and Frontier Fuel
Service to ensure required records are completed and maintained. Records should be maintained
for five years, except for AST Records and records of certified inspection reports which are to be
maintained for the life of the tank, and spill reports which are to be maintained permanently.
The following sample documentation forms are in Appendix B of this SPCC Plan:
Visual Inspection – Monthly Checklist
Community Tank Farm Impound / Diked Area- Stormwater Drain Log
Liquid Level Sensing Devices – Test Log
Training & Drills Self Certification Form
Oil Spill Report and Notification Form
SPCC Plan Review and Evaluation
STI-SP001 Aboveground Storage Tank (AST) Record
II - 5 08/16
F. Personnel, Training, and Spill Prevention Procedures - 40 CFR Part 112.7 (f)
The YKSD Superintendent of Schools has overall responsibility of compliance and operation of
the School. The YKSD Maintenance Director is accountable for Facility operations, oil spill
prevention, and personnel training. YKSD has contracted Frontier Fuel Service (FSS) to provide
spill prevention, response, and compliance assistance at all of its schools. FSS services include
on-site maintenance, required inspections and tests, discharge prevention training, and spill
response including Qualified Individual responsibilities and authority. FSS is a Wasilla based
corporation organized to contract for the operation and maintenance of rural Alaskan bulk fuel
storage facilities.
All oil handling personnel are to be instructed in operations, maintenance, and spill prevention
procedures pertinent to their duties. Training is to be provided at least once a year. Verification
of training is to be maintained. At minimum, the training should address the following topics.
A. Pollution control laws, rules, and regulations summary of 40 CFR Part 112 "Oil
Pollution Prevention".
B. Fuel Storage Systems:
1. Purpose and application
2. System elements:
a. Tanks
b. Pumps
c. Accessory equipment
3. Operation and maintenance of equipment
4. Fuel transfer procedures
5. Required inspections / inspection procedures
C. Spill Prevention and Control:
1. Potential spill sources
2. Procedures to prevent spills
3. Review of control measures:
a. Secondary containment
b. Safety valves
c. Pump shutoff switches
D. Emergency response procedures:
1. Initial spill response / notification procedures
2. Personnel safety – MSDS review
3. Location and use of emergency phone numbers
4. Location and use of fire extinguishers
5. Location and use of spill cleanup materials
6. Review of facility spill prevention and response plans
7. Local spill response resources
II - 6 08/16
G. Security - 40 CFR Part 112.7 (g)
Security measures are listed in Section I.B of this Plan.
II - 7 08/14
III. SPECIFIC REQUIREMENTS
40 CFR Part 112.8 (a) - (d)
III - 1 08/14
The filling of the storage tanks is manually initiated and visually monitored. Double wall
tanks are equipped with overfill protection devices. Check and isolation valves and
normally closed solenoid valves are installed to isolate piping when transfers are not in
progress.
Section II.E describes liquid gauges and level sensing devices in tanks, and test procedures
for the devices.
(9) No petroleum effluents are discharged into navigable waters.
(10) Visible oil leaks from tank seams, gaskets, piping, pumps valves, and bolts shall be
reported to the YKSD Maintenance Director and promptly corrected. Any accumulation of
oil within diked areas is to be promptly removed.
(11) No portable or mobile oil storage tanks are stored in a non-transportation mode at the
School.
D. Facility Transfer Operations - 40 CFR Part 112.8 (d)
(1) There is no EPA regulated buried pipe at the Facility. The pipe from the community tank
farm to the School is above ground except where it passes subsurface under roadways,
where it is protected within culvert pipe.
EPA regulations (40 CFR Part 112.8(d)(1)) require buried oil pipe installed after August
16, 2002 be provided with protective wrapping and coating, and be cathodically protected
in accordance with corrosion protection standards or an approved State program.
(2) EPA regulations state that piping terminal connections that are not in service or are in
standby service for an extended period of time are to be capped or blank-flanged at the
transfer point and marked as to origin.
(3) Exposed pipe appears to be adequately supported to minimize abrasion and corrosion, and
allow for expansion and contraction.
(4) School personnel normally observe the intermediate tank, transfer tank, and heating fuel
tanks during daily routine duties. The tank farm is normally observed daily by the other
tank farm operators who conduct dispensing operations from tank farm. At least once a
month, the School Site Principal / Head Teacher, or designated alternate, is to conduct and
document a thorough visual inspection of the entire School fuel system. The visual
inspection of piping is to assess the general condition of items such as flanged joints,
expansions joints, valve glands and bodies, catch pans, pipeline supports, locking valves,
and metal surfaces. Any fuel system discrepancies, leaks or potential discharge, or items
which are in need of maintenance shall be reported to the YKSD Director of Facilities and
Maintenance or the Maintenance Mechanic in Fairbanks.
(5) Vehicular access into the community is restricted by dikes and fencing. The pipe from the
community tank farm to the School is removed from vehicular traffic except where it
passes subsurface under roadways, where it is protected within culvert pipe. Tanks at the
School are without protection from vehicular traffic, which is limited.
III - 2 08/14
APPENDIX A
ENGINEER’S OBSERVATIONS
To comply with EPA spill prevention regulations listed in 40 CFR Part 112, and to ensure
reasonable measures are in place to prevent spilled oil from reaching navigable waters the
corrective actions listed below, or equivalent measures, must be implemented at the Kaltag School
oil storage facility.
1. In accordance with 40 CFR 112.8(c)(2), install secondary containment for the 500 gallon
heating fuel tanks at the vocational education building (#HFT-1) and at the teacher housing
duplex (#HFT-2). Secondary containment must provide for the volume of the tank plus at
least two inches of freeboard for precipitation. The heating fuel tanks that supply single family
teacher housing units are exempt from SPCC requirements; therefore secondary containment is
not required, albeit recommended.
2. In accordance with 40 CFR 112.8(c)(6) and Section II.E of this Plan, implement a tank
inspection schedule that complies with the Steel Tank Institute (STI), Standard for Inspection
of In-Service Shop Fabricated Aboveground Tanks For Storage of Combustible and
Flammable Liquids – SP001.
• Tanks that have been in service for less than 20 years shall be subject to an initial
formal, certified inspection in accordance with SP001 Table 5.5 Table of Inspection
Schedules.
• Tanks that have been in service for 20 years or more, and tanks of unknown age, shall
be subject to an initial formal, certified external inspection no later than November 10,
2015.
3. In accordance with 40 CFR 112.8(c)(8)(v) and Section II.E of this Plan, implement inspection
/ test program of liquid level sensing devices, including tank gauges, float control switches,
and fill limiting valves. Confirm settings of float control switches in intermediate, transfer and
day tanks, and document tests to confirm proper operation. Confirm installation of fill limiting
valve in intermediate tank, and install valve if not installed.
4. In accordance with 40 CFR 112.8(d)(5) and good engineering practice, install bollards or other
protective measures to protect the exposed tanks at the School from vehicular traffic.
5. The following items should be verified periodically to ensure compliance with the SPCC Plan.
• Confirm inspection and record-keeping forms are maintained as listed in Section II.E of
this Plan.
• Confirm fire extinguishers (Type 40 BC) are maintained near the entrance gates to the
community tank farm and near the intermediate and transfer tanks.
• Confirm labels are maintained at storage tanks to identify product stored and storage
capacity, and ensure no smoking and emergency notification placards are posted at
appropriate locations.
• Confirm the Facility Response Plan is maintained in accordance with EPA and Coast
Guard requirements.
APPENDIX A 08/14
APPENDIX B
APPENDIX B 08/14
KALTAG SCHOOL – OIL STORAGE
VISUAL INSPECTION - MONTHLY CHECKLIST*
DATE: __________
INSPECTED BY: __________________ INSPECTED / OK REQUIRES
() ATTENTION
(attach comments)
* In the event of severe weather (snow, ice, wind storms) or maintenance (such as painting) that could affect the operation
of critical components (normal and emergency vents, valves), an inspection of these components is required
immediately following the event.
This checklist (or similar documentation) to be retained for 36 months to comply with Steel Tank Institute tank
inspection standard, STI SP001.
KALTAG SCHOOL – OIL STORAGE
COMMUNITY TANK FARM IMPOUND - SCHOOL STORAGE TANK
STORMWATER DRAIN LOG
* Operator's signature confirms that no oil or sheen was discharged during draining.
*This information must be recorded for each drill, exercise, program - use additional pages, as necessary.
These exercises may be conducted concurrently.
This form (or similar documentation) required by 40 CFR, Part 120.20(h)(8), and 33 CFR, Part 154.1050(b)
KALTAG SCHOOL
OIL SPILL REPORT AND NOTIFICATION FORM
USE ADDITIONAL PAGES AS NEEDED
1) REPORTING PARTY: NAME __________________________________________
ADDRESS __________________________________________
TELEPHONE __________________________________________
_____________________________________________________________________________________
I have completed review and evaluation of SPCC Plan for the Kaltag School.
City, State, Zip Code City, State, Zip Code City, State, Zip Code
.
TANK ID
SPECIFICATION:
API Other
Unknown
SPECIFICATION:
API Other
Unknown
TANK ID
SPECIFICATION:
API
Unknown Other
TANK ID
APPENDIX C
APPENDIX C 08/14
INTERMEDIATE TANK - FILL PROCEDURE
TRANSFER TANK FILL - SEQUENCE OF OPERATION