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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 […]
A Look at Common Ski Area SPCC Violations Having an SPCC Plan that was not fully implemented. 40 CFR Section 112.3, states, “The owner or operator or an onshore or offshore facility subject to this section must prepare in writing and implement a Spill Prevention, Control, and Countermeasure Plan … in accordance with 112.7 [General […]
Multiple Ski Areas Learn SPCC Compliance Lesson Over the past few years, the U.S. Environmental Protection Agency (EPA) has reached settlements with a number of ski areas in New England communities throughout Maine, New Hampshire, and Vermont. According to the EPA, the settlements “were reached under an expedited settlement program whereby EPA agreed to resolve […]
Tips for Assessing Applicability with the SPCC Rule Tip—Know the qualifying factors for coverage under the SPCC rule. The SPCC rule applies when the following are met at a facility*: The facility stores, transfers, uses, or consumes oil or oil products, such as diesel fuel, gasoline, lube oil, hydraulic oil, adjuvant oil, crop oil, […]
SPCC Inspection, Evaluation, and Testing—5 Specific Things Inspectors Are Looking For 1) Regular leak testing of tanks that are completely buried. Any completely buried tank that was installed on or after January 10, 1974, must be leak tested regularly “in accordance with industry standards or at a frequency sufficient to prevent leaks.” While there are […]
SPCC Inspection, Evaluation, and Testing—5 General Things Inspectors Are Looking For 1) A complete SPCC Plan that contains a description of “the scope and schedule of inspection, evaluation, and testing to be performed on bulk containers.” In its SPCC Guidance for Regional Inspectors, the EPA references the following sections of 40 CFR 112 that address […]
SPCC Plan Compliance FAQs for Production, Drilling and Workover Facilities Q: Are there SPCC Plan requirements that apply to all covered oil production, drilling and workover facilities? A: Yes. 40 CFR part 112.7 provides the general requirements for SPCC Plans at all facilities covered by the regulations. Although these requirements are extensive, there are a […]
SPCC Applicability FAQs for Production, Drilling and Workover Facilities Q: What different types of activities at non-transportation, onshore oil production, drilling and workover facilities are covered under the SPCC rule? A: The SPCC rule defines “facilities” as “any mobile or fixed, onshore or offshore building, property, parcel, lease, structure, installation, equipment, pipe, or pipeline (other […]
SPCC Secondary Containment Impracticability FAQs Q: How does the Environmental Protection Agency (EPA) define “impracticability” in regard to secondary containment? A: According to the EPA, the meaning of “impracticability” relative to SPCC secondary containment requirements is the determination that a “facility owner/operator cannot install secondary containment by any reasonable method.” Q: What considerations are acceptable […]
SPCC Secondary Containment FAQs Q: What are the differences between general and specific secondary containment requirements in the SPCC rule? A: The general requirements address the potential for oil discharges from all regulated parts of a facility. Using good engineering practices, the containment method, design, and capacity should be determined to contain the most likely […]