Category: Special Topics in Environmental Management

Who Owns This UST?

Although it may seem obvious that if you ever owned or operated an underground storage tank (UST) that you are responsible for compliance or cleanup in case of a leak, the fact is that many USTs have long and complicated histories, and identifying the responsible party when, for example, the tank had multiple owners is […]

Biofuel Considerations: Safe Handling of Ethanol—For Your Tank

Ethanol is a renewable, domestically produced fuel that can be made from grains, such as corn or wheat, or from cellulose sources, such as prairie grass or agricultural, forestry, or municipal wastes. In the United States, ethanol is primarily made from corn. EPA’s Office of Underground Storage Tanks regulates tanks storing petroleum and biofuels. Under […]

12 Changes in Store for EPA’s MSGP for Stormwater Associated with Industrial Activities

Twelve changes to the 2008 federal MSGP for stormwater discharges associated with industrial activity are included in EPA’s draft 2013 MSGP. Coverage under the 2008 MSGP, which expired September 29, 2013, is administratively extended until the 2013 permit is issued, provided facilities submit a Notice of Intent (NOI) to be covered by the new permit […]

11 Tips for Qualifying Under the “No Exposure” Exclusion for Stormwater Associated with Industrial Activities

Under the conditional no-exposure exclusion (found at 40 CFR 122.26(g)), operators of industrial facilities subject to stormwater regulations have the opportunity to certify to a condition of “no exposure” if their industrial materials and operations are not exposed to stormwater. Note: This no-exposure exclusion does not apply to construction activities, which are addressed under the […]

SPCC: What Are Your Security Requirements

Standard SPCC plans must describe security procedures for their operation (excluding oil production facilities). The security requirements are meant to prevent oil discharges that result from vandalism or other unauthorized access to oil containers or equipment. Security procedures must include provisions to: Secure and control access to each facility’s handling, processing, or storage areas. Secure […]

SPCC: Tips for Tank Inspections

The following Table outlines the inspection requirements for tanks and associated piping at onshore nonproduction facilities that store petroleum and nonpetroleum oils—except animal fats and vegetable oils, which have their own set of inspection requirements. Note: The SPCC rule also contains integrity testing provisions for tanks, which are not included in this table.  In addition, […]

Tips for Storing Used Oil in an AST

Used oil generators include all persons who produce used oil through commercial or industrial operations and vehicle services. The regulations exempt household “do-it-yourselfers,” farmers under certain conditions, vessels at sea or at port, and mixtures of used oil and diesel fuel under certain conditions. If used oil is mixed with hazardous waste, it must be managed […]

Go Beyond Compliance to Prevent AST Spills

The federal regulations you should consider when developing management practices for ASTs include: Clean Air Act (CAA) regulations for tank vapor control, air toxics, and pollution reduction The Emergency Planning and Community Right-to-Know Act (EPCRA) and Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) hazardous substance reporting requirements The Clean Water Act (CWA)-incorporated OPA that […]

Are You Leakproof? 12 Tips for Avoiding Equipment Leak Fines—Part 2

5 Additional Best Practices for LDAR Programs These best management practices for LDAR programs follow up on the 7 we discussed yesterday. Maintain a “Delay of Repair” list. Any component that cannot be repaired during the specified repair interval must be placed on a “Delay of Repair” list to be repaired during the next shutdown […]

Are You Leakproof? 12 Tips for Avoiding Equipment Leak Fines

The Agency has estimated that approximately 70,367 tons per year of VOCs and 9,357 tons per year of HAPs have been emitted from equipment leaks. Many federal regulations under New Source Performance Standards (NSPS) at 40 CFR 60 and National Emissions Standards for Hazardous Air Pollutants (NESHAPs) at 40 CFR 61 and 40 CFR 63 […]