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ASTs are storage tanks that are aboveground, regardless of whether they are used to store petroleum products, hazardous waste, or other hazardous material. There are a variety of overlapping federal laws and regulations that govern ASTs, and most are highly regulated on the state and local level. There are specific inspection requirements for hazardous waste […]
Penalty—$3,650; Cost to Come into Compliance—$30,000 An onshore oil production company in Illinois racked up a rather small penalty of $3,650 for SPCC violations. However, its cost to come into compliance was a substantial $30,000. Their violations can be divided into seven main categories: Problems with the Plan itself: The facility diagram was inadequate. The […]
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 […]
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 […]
UST O&M—Changes in the Works Historically, the Environmental Protection Agency’s (EPA) UST regulations were focused on improved equipment, with not a lot of attention given to O&M practices. However, based on more than 20 years of regulatory experience, the EPA acknowledges that a higher level of O&M, in addition to better equipment, is required to […]
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 […]
To attempt to collect data systematically and have each state fit their data into several categories To request the number of occurrences for each violation To request the number of inspections on which the data was based The data was based on approximately 100,000 inspections with a significant operational compliance (SOC) rate of approximately 72%. […]