1. Everything You Wanted to Know About Tanks But Were Afraid to Ask
This section of the workshop discusses aboveground storage tanks (ASTs). It includes discussions on:
Spill Prevention Control and Countermeasure (SPCC) plans,
Facility Response Plans (FRPs),
Stormwater Pollution Prevention Plans (SWP3),
Industry standards for ASTs,
Operations and maintenance on ASTs,
Key concepts in preventing spills or overfills at ASTs, and
An overview of air regulations applicable to ASTs.
Aboveground Storage Tank Systems

2. Outline
Introduction
Spill Prevention Control and Countermeasure (SPCC) Plans
Facility Response Plans (OPA-90)
Stormwater Pollution Prevention Plans (SWP3)
The Clean Water Act – Oil Pollution Prevention regulations are designed to protect surface water.
An SPCC plan must be prepared by all facilities subject to regulation.. The main thrust of the SPCC regulations is prevention as opposed to after-the-fact reactive measures.
The FRP program is designed to ensure that certain facilities have adequate oil spill response capabilities.
The SWP3 program is designed to keep contaminants out of stormwater runoff.

3. Oil Pollution Prevention Regulatory History
Promulgated by EPA in 1973
Revisions proposed in 1991, 1993, 1997
Final rule effective on August 16, 2002
Two amendments December 12, 2005
Streamlining
Extends Compliance Dates
One amendment effective December 26, 2006
December 11, 1973 Original SPCC Rule
July 17, 2002 Final Revised SPCC Rule
August 11, 2004 Final Rule to Extend Deadlines under the SPCC Rule
December 12, 2005 Two amendments to streamline regulations and extend compliance dates
February 17, 2006 Final Rule to Extend Deadlines under the SPCC Rule
December 26, 2006 Finalized Amendments to the SPCC Rule
Provides option for owners and operators of facilities that store 10,000 gallons of oil or less and meet other qualifying criteria to self-certify their SPCC Plans in lieu of review and certification by a Professional Engineer
An alternative to the general secondary containment requirement without requiring a determination of impracticability for facilities that have particular types of oil-filled equipment
Defines and exempts particular vehicle fuel tanks and other on-board bulk oil storage containers used for motive power. For Region 2, Chris Jimenez will provide additional discussion on the requirements for vehicle fuel tanks.
Exempts mobile refuelers from the sized secondary containment requirements for bulk storage containers.

4. 2002 Rule Changes
Exempts only completely buried storage tanks subject to all of the technical requirements of the UST regulations (40 CFR Parts 280 or 281)
Exempts portions of certain facilities or any facility used exclusively for wastewater treatment
Establishes a de minimis container size of 55 gallons
Establishes an aboveground storage capacity threshold of greater than 1,320 gallons and removes the 660 gallon threshold
Revises the trigger for submitting information on spills at SPCC regulated facilities to EPA
Allows deviations from most rule provisions when equivalent environmental protection is provided
Flexible plan format, but requires a cross-reference
Clarifies rule applicability to the storage and operational use of oil
New AST regulations are designed to prevent duplicate or redundant regulation by removing USTs regulated under 40 CFR 280 and 281 from Part 112.
Part 112 exempts only completely buried tanks complying with 40 CFR 280 and 281 and does not follow the 40 CFR 280 definition, e.g., USTs are defined as any one or a combination of tanks that have 10% or more of their volume below the surface of the ground in which they are installed. This definition includes the tank, connected underground piping, underground ancillary equipment, and containment system.
Part 112 applies to all oils – vegetable, animal, petroleum, synthetic.
Revises the trigger for submitting information on spills at SPCC regulated facilities to EPA. Facilities are now required to submit information after having 2 discharges (over 42 gallons) in any 12-month period or a single discharge of more than 1,000 gallons.
Allows deviations from most rule provisions (with the exception of secondary containment requirements) when equivalent environmental protection is provided. Equivalent environmental protection is explained in further detail in another slide.
Incorporates the use of plain language.
"Should to shall to must." Clarification that the rule's requirements are mandatory.

5. Regulatory Overview 40 CFR 112.7 requires
Facility Diagram CFR 112.7(a)(3)
Trajectory Analysis CFR 112.7(b)
Secondary Containment CFR 112.7(c)
Contingency Plans CFR 112.7(d)
Inspection, Tests, and Records CFR 112.7(e)
Personnel Training and Discharge Prevention Procedures CFR 112.7(f)
Security (excluding production facilities) CFR 112.7(g)
Facility Tank Car and Tank Truck Loading/Unloading Racks (excluding offshore facilities) CFR 112.7(h)
Field-constructed Aboveground Containers - Brittle Fracture Evaluation CFR 112.7(i)
40 CFR requires spill prevention and control measures specific to the different types of oil facilities or operations, including:
Onshore Facility Drainage (excluding production facilities) CFR 112.8(b)
Facility Transfer Operations, Pumping, and Facility Process (excluding production facilities) CFR 112.8(d)
Onshore Bulk Storage Containers (excluding production facilities) CFR 112.8(e)
All SPCC Plans must comply with a set of general requirements listed on the slide under 40 CFR
In addition to general requirements, the SPCC regulations provide spill prevention and control measures specific to the different types of oil facilities or operations under 40 CFR
A SPCC Plan should address the following three areas:
Operating procedures that prevent oil spills;
Control measures installed to prevent a spill from reaching navigable waters; and
Countermeasures to contain, clean up, and mitigate the effects of an oil spill that reaches navigable waters

6. 40 C.F.R. § 112 Spill Prevention Requirements
Spill Prevention Control and Countermeasure (SPCC) Plans
Spill Response Requirements
Facility Response Plans (FRP or OPA-90)
40 CFR §
Key Dates for SPCC Compliance Facilities
Before 8/16/02 Maintain the facility's existing Plan. Amend and implement the Plan no later than 7/1/09 (anticipated).
Between 8/16/02 – 7/1/09 Prepare and implement Plan no later than 7/1/09 (anticipated).
After 7/1/09 (anticipated) Prepare and implement Plan before starting operations

7. 40 C.F.R. §
Spill Prevention Control and Countermeasure (SPCC) Plan
Facility Diagram
Inventory
Discharge Prevention Measures
Discharge or Drainage Controls
Countermeasures
Disposal for Recovered Material
Contact Numbers
Each SPCC Plan must be unique to the facility.
This and the next slide lists the elements of an SPCC. Basic information required in an SPCC Plan includes:
A description of the physical layout and a facility diagram.
A description of containment and/or diversionary structures or equipment to prevent discharged oil from reaching navigable waters.
A complete discussion of the spill prevention and control measures applicable to the facility and/or its operations.
Contact list and phone numbers for the facility response coordinator, National Response Center, cleanup contractors, and all appropriate federal, state, and local agencies who must be contacted in case of a discharge.

8. 40 C.F.R. § 112.7-112.12 SPCC Plan - Continued PE Certification
Secondary Containment
Integrity testing
Inspections
Training
Plan Updates
Continued - Basic information required in an SPCC Plan includes:
A description of containment and/or diversionary structures or equipment to prevent discharged oil from reaching navigable waters.
The SPCC Plan must include a demonstration of management's approval and must be certified by a licensed professional engineer, if applicable

9. 40CFR § 112.7-112.12 Covers SPCC Plans
Any owner/operator of a non-transportation onshore or offshore facility engaged in the following activities with oil which due to location could discharge to waters:
Storing
Processing
Transferring
Distributing
Using
Consuming oil/oil products
This slide discusses what type of federal facility would generally require a SPCC plan.
Further information is available in the EPA publication Spill Prevention, Control and Countermeasure Regulation 40 CFR 112. .

10. 40CFR § 112.2 Covers Facility: Small as one tank
Large as a military base
Boundaries of facility depend on:
Ownership
Activities on site
Responsibility for response
This slide provides a definition of a facility.
A facility is any place mobile or fixed where the handling, use, or processing of oil could potentially cause a spill into a water way.
The facility can be as small as one tank as long as it is greater than 1,320 gallons or as large as a military base.
Boundaries of the facility depend on where ownership of the land ends or on where the oil handling is taking place. They can also depend on whose responsibility it is to report a spill and where that person is located.

11. 40CFR§112.1-112.3 Doesn’t Cover SPCC Plans
Facilities with USTs that contain 42,000 gallons or less of oil
Facilities with aggregate AST storage capacity of 1,320 gallons or less of oil.
Any container with a storage capacity of less than 55 gallons
Underground storage tanks (USTs) subject to part 40 CFR 280 and 281
Any facility which is used exclusively for wastewater treatment
Facilities with USTs that contain greater than 42,000 gallons in the aggregate must prepare a SPCC plan. This means that, if you have several USTs, and together all the USTs contain greater than 42,000 gallons of petroleum products, then you must prepare a SPCC plan.
USTs refers to completely buried tanks only.
Oil filled equipment is covered and falls under 40 CFR (c). As long as the operator of a facility meets the discharge criteria, they may implement an inspection and monitoring program, develop an oil spill contingency plan, and provide a written commitment of resources to control and remove oil discharged, for qualified equipment in lieu of secondary containment for the oil-filled operational equipment.
The facility does not need to make an impracticability determination for each piece of equipment.

12. SPCC Flow Chart
The intent of this flowchart is to show the general principles of applicability.
Completely buried tank: Any container completely below grade and covered with earth, sand, gravel, asphalt, or other material. Containers in vaults, bunkered tanks, or partially buried tanks are considered aboveground storage containers for purposes of this part.
Complex: A facility possessing a combination of transportation-related and non-transportation-related components that is subject to the jurisdiction of more than one Federal agency under section 311(j) of the CWA.
Facility: Any mobile or fixed, onshore or offshore building, structure, installation, equipment, pipe or pipeline oil storage, oil gathering, oil processing, oil transfer, oil distribution, and waste treatment, or in which oil is used.
Permanently closed: Any container or facility for which: (1) All liquid and sludge has been removed from each container and connecting line; and (2) All connecting lines and piping have been disconnected from the container and blanked off, all valves (except for ventilation valves) have been closed and locked, and conspicuous signs have been posted on each container stating that it is a permanently closed container and noting the date of closure.
Storage capacity: Shell capacity of the container.

13. Noncompliance Issues OVERALL Plan not developed
Inspections not conducted
Spill response equipment not maintained
No training
FEDERAL FACILITIES
Tenants not covered
Maintenance & housekeeping
No assigned responsibility for inspections and testing
No controls on drain valves
Use of mobile/portable tanks
Lack of spill reporting procedures
This slide shows general SPCC noncompliance issues and noncompliance issues commonly found at federal facilities.

14. SPCC Violations – H&M Oil Site, 2001
The H & M Oil, Inc., Triangle site located in Pocatello, Idaho.
Three vertical above ground storage tanks (ASTs), drums, and a portable storage container containing waste oil, water, and sludge. The AST capacity ranges from 8,000 to 12,000 gallons.
Located 200 yards from Portneuf River. Feeds directly to a reservoir.
Drinking water intakes approximately 1 mile from site.
No AST maintenance and inspection.
Soil staining
Unrestricted access
No secondary containment
Spills to gravel and dirt
The H & M Oil, Inc., Triangle site is an oil storage facility located in Pocatello, Idaho. The facility is composed of three vertical above ground storage tanks (ASTs), drums, and a portable storage container. The ASTs contain waste oil, water, & sludge. The capacity of the ASTs range from 8,000 to 12,000 gallons. Idaho Department of Environmental Quality referred the site to EPA as a potential major inland spill.
This site is located 200 yards from Portneuf River. Portneuf River feeds directly into the American Falls Reservoir and is a tributary of the Snake River.
Drinking water intakes are located approximately 1 mile from Site.
Owner lives in another state and was unaware of activities at the site.
ASTs at site are not undergoing routine maintenance and inspection. Operations have resulted in spills as evidenced by soil staining.
Site access is not restricted.
Secondary containment at the site is inadequate given that there is no paved area directly under the tanks or drums to control a spill. Spills go directly into gravel and dirt.
An opening in the secondary containment wall would allow a major spill to leave the containment area and it is likely that such a spill would enter the Portneuf River.
Results: 20,000 gallons removed. $80,000 in cleanup and removal costs.

15. SPCC Plan Elements Part 1
Facility Diagram
Inventory of Oil Types and Capacity
Discharge Prevention Measures
Discharge or Drainage Controls
Spill Countermeasures
Disposal of Recovered Material
Contact Numbers
Diagram would consist of the facility layout showing the location and contents of each container. The diagram must include underground storage tanks, transfer stations, and connecting pipes.
The plan must also include a list of the types of oil stored on site and the storage capacity of each.
The plan must include the measures your facility will take to prevent discharges through procedures for routine handling of products (loading and unloading etc.)
Drainage controls include controls such as secondary containment around containers and other structures, equipment, and procedures for the control of discharge.
Countermeasures for Discharge discovery include procedures for response to spill, and cleanup (both at the facility and from the use of a contractor)
The plan must include the method by which materials used to clean up a spill will be disposed of.
Finally a list of phone numbers for the facility response coordinator, National Response Center, Clean up contractors whom you have an agreement with, and all appropriate agencies including Federal, State, and Local Agencies who must be contacted in the event of a discharge as described.

16. Facility Diagram
If the facility is subject to a SPCC, the location of all completely buried tanks complying with 40 CFR 280 and 281 needs to be added to the facility diagram.

17. Inventory
Include all oil storage at facility in storage containers of 55 gallons and greater
Record the amount stored, the storage capacity, and its location
Update the inventory as changes occur and have a PE recertify the plan
This slide describes what storage containers are included in the oil inventory.
Inventory reported in the SPCC plan should be updated as the facility alters, removes, or adds storage containers or ASTs. Recertification by a PE for non-administrative changes will be required.

18. Discharge Prevention Measures
Not a recommended spill prevention measure
Provide Employee Training! #1
Describe spill prevention equipment (i.e., leak detection systems, secondary containment)
Describe plans for inspection and maintenance
The #1 way to prevent a discharge of oil is by training. It is essential that staff who will work with oil or oil containing equipment are trained in the proper procedures to prevent spills. They must also be aware and perform best management practices as well as good housekeeping.
If any of the tanks on site have a leak detection system, employees must know and understand how to operate this system and how it is maintained. Leak detection systems need to be serviced periodically and inspected regularly. In addition integrity testing for the ASTs may be required by industry standards.

19. Discharge or Drainage Controls
Includes:
Oil water separators
Ditches
Levies
Berms
Retention Ponds
Curbs
Discharge or Drainage Controls are those physical structures which are built to contain a spill once it has started. If your facility has any of these structures they should be included in the plan. There are location, size, and other physical properties of the discharge or drainage controls that should be detailed in the plan.
If your facility does not have these structures, a environmental equivalence and impracticability determination may be required. It allows your facility to implement alternate measures based on site-specific considerations. Alternate measures must provide equivalent environmental protection, in accordance with good engineering practice and as determined by a Professional Engineer.

20. Spill Countermeasures
Describe the equipment at your facility such as:
Industrial absorbent
Pigs
Oil booms
Plugs
Pans
Describe the steps in the spill response procedure
The SPCC must describe what equipment you need at your facility to contain spills. It should list the materials you store on site. The SPCC should outline what types of equipment are available, how much, and where is it located.
The plan must include the procedure that everyone will follow during a spill event. It should be clearly outlined who is responsible for what and what regulatory agencies should be contacted during a spill and what steps are needed to contain the spill.

21. Disposal/Contact Numbers
Outline the plan for disposal of used absorbent material in the Plan
Identify the contractor (s) who will be disposing of material
Determine Federal, State, and local requirements for disposal (if any)
Federal, State, and Local emergency numbers (National Response Center )
Ambulance and hospital numbers
Spill cleanup contractors
This slide provides information on disposal of contaminated absorbents or other waste materials generated during spill cleanup as well as the contact numbers that should be included in a SPCC plan.

22. SPCC Plan Elements Part 2
PE Certification
Secondary Containment
Integrity testing
Inspections
Training
Security
Plan Updates
This slide describes the remaining elements of a SPCC plan.
Even those facilities who do not require a SPCC should consider reviewing and implementing secondary containment, integrity testing, inspections, training and security for smaller ASTs or collections of drums. This will minimize risk to the environment.

23. PE Certification PE may use an agent PE must review the agent’s work
PE Certification statement more specific
PE not required for non-technical amendments
State laws may preclude a PE not registered in the state from certifying
Familiar with requirements of SPCC rule
He or his agent have visited and examined the facility.
The Plan has been prepared in accordance with good engineering practice including consideration of applicable industry standards.
Procedures for required inspections and testing have been established.
The Plan is adequate for the facility
This slide describes the requirements for PE certification of a SPCC plan.
With the December 2006 amendments, PE certification is no longer required for those facilities storing less than 10,000 gallons and that have not had (1) a single discharge of oil to navigable waters exceeding 1,000 U.S. gallons or (2) two discharges of oil to navigable waters each exceeding 42 U.S. gallons within any twelve-month period.
However, any SPCC Plan which includes environmentally equivalent measures or impracticability determinations will require PE certification for only the portions dealing with environmental equivalence and impracticability determinations. 

24. Secondary Containment
Secondary containment must hold contents of largest single container in containment unit plus allowance for accumulated precipitation, if applicable.
55 gallon drums must have secondary containment.
Double walled ASTs with interstitial monitoring systems are considered acceptable secondary containment.
This slide describes the basic requirements for secondary containment.
General Secondary Requirements
At a regulated facility, all areas with the potential for a discharge are subject to the general secondary containment provision. These areas must designed with appropriate containment and/or diversionary structures to prevent a discharge that may be harmful. “Appropriate containment” should be designed to address the most likely discharge from the primary containment system such that the discharge will not escape containment before cleanup occurs.
Specific Secondary Containment Requirements
Areas where certain types of containers, activities, or equipment are located may be subject to additional, more stringent containment requirements. The SPCC rule specifies a required minimum size for secondary containment for the following areas:
Bulk storage containers;
Loading/unloading racks; and
Mobile or portable bulk storage containers

25. Environmental Equivalence
Allows facilities to implement alternate measures based on site-specific considerations:
Security
Facility drainage
Corrosion protection and leak testing of completely buried metallic storage tanks
Overfill prevention
Piping
Evaluation, inspection, and testing
Measures must provide equivalent environmental protection, in accordance with good engineering practice and as determined by a Professional Engineer.
The environmental equivalence provision allows for deviations from specific requirements of the SPCC rule, as long as the alternative measures provide equivalent environmental protection. The environmental equivalence provision is a key mechanism of the performance-based SPCC rule. This flexibility enables facilities to achieve environmental protection in a manner that fits their unique circumstances. It also allows facilities to adopt more protective industry practices and technologies as they become available.
Equivalent environmental protection means an equal level of protection of navigable waters and adjoining shorelines from oil pollution. This can be achieved in various ways, but a facility may not rely solely on measures that are required by other sections of the rule (e.g., implementing secondary containment) to provide environmentally equivalent protection. The reason for deviating from a requirement of the SPCC rule, as well as a detailed description of how equivalent environmental protection will be achieved, must be stated in the SPCC Plan.

26. Impracticability Determinations
Documentation needed
Detail on impracticability determinations for certain areas:
Piping and flowlines
Transfer areas
Oil-filled Equipment
Loading/unloading racks
Onshore bulk storage containers
Mobile/portable containers
Meaning of “Impracticable”
The impracticability determination is intended to be used when a facility owner/operator is incapable of installing secondary containment by any reasonable method. Considerations include space and geographical limitations, local zoning ordinances, fire codes, safety, or other good engineering practice reasons that would not allow for secondary containment.
Only secondary containment requirements can be determined to be impracticable; for most other technical requirements, the rule provides flexibility to facility owners or operators to implement alternative measures that provide equivalent environmental protection.
The impracticability provision allows facility owners/operators to substitute a combination of other measures in place of secondary containment: (1) periodic integrity testing of bulk storage containers and periodic integrity testing and leak testing of the valves and piping associated with the containers; (2) an oil spill contingency plan; and (3) a written commitment of manpower, equipment, and materials required to control and remove any quantity of oil discharged that may be harmful.
If an impracticability determination is made, the SPCC Plan must clearly describe why secondary containment measures are impracticable and how the specified additional measures are implemented.

27. Tank Integrity Testing
ASTs require:
Integrity testing on a regular schedule
Integrity testing when material repairs are done
Visual inspection must be combined with another testing technique such as: ultrasonic, radiographic, acoustic emissions, hydrostatic, or other nondestructive testing method.
Integrity testing may include leak testing
Type of integrity testing and inspections must consider applicable industry standards.
Integrity testing is any means to measure the strength of the container shell, bottom, and/or floor to contain oil and may include leak testing to determine whether the container will discharge oil.
Integrity testing requirements are distinct from and are in addition to, the requirement to frequently inspect the outside of an aboveground storage container. The integrity testing requirement applies to large (field constructed or field-erected) and small (shop-built) aboveground containers; aboveground containers on, partially in (partially buried, bunkered, or vaulted tanks), and off the ground wherever located; and to aboveground containers storing any type of oil. Generally, visual inspection alone is not sufficient to test the integrity of the container. It must be combined with another testing technique and must include the container’s supports and foundations. Testing techniques include but are not limited to:
• Hydrostatic testing;
• Radiographic testing;
• Ultrasonic testing;
• Acoustic emissions testing; and
• Another system of non-destructive shell testing.
Testing on a ‘regular schedule’ means testing per industry standards or at a frequency sufficient to prevent discharges. The frequency of integrity tests should reflect the particular conditions of the container such as the age, service history, original construction specifications, prior inspection results, and the existing condition of the container.

28. Training Required for Oil-handling employees only Conducted annually
Training includes:
Spill control equipment
Emergency procedures
Laws, rules, regulations
General facility operations
The plan
This slide describes the training requirements. Training is the best way to prevent spills and discharges. Knowledge is power and ensures that everyone will know what to do in the event of a spill.

29. Security/Plan Updates
Requires fencing and locks or guard entrances for unattended facilities
If fencing is impractical, explain. Provide equivalent environmental protection
Plan must be reviewed at least once every 5 years
Upon review if changes have occurred which effect plan, plan must be amended within 6 months of review
Security requirements for facilities includes fencing and lighting, and the use of control equipment and procedures. The security requirements are meant to prevent discharges of oil that could result from acts of vandalism or other unauthorized access to oil-filled containers or equipment.
A facility owner or operator may achieve the security objective through alternative measures, as appropriate for the facility, if these measures provide equivalent environmental protection.
The frequency of Plan review has been reduced from every three years to every five years.

30. Summary Determine whether you are required to have a plan
If so, prepare one
Conduct training annually
Maintain adequate spill response materials on site
Update the Plan
Inspect equipment and your facility regularly
This slide summarizes the SPCC requirements and presents a graph showing that spills of oil have generally decreased over the years as the awareness and prevention has increased.

31. This slide presents a screen capture showing the location of the EPA website where more information on the oil program – which includes SPCC and FRP plans – may be found.

32. Problems Today
The next slides review common problems with ASTs including a discussion of converting USTs to ASTs, industry standards, maintenance and operations of ASTs, top causes of overfills, and key spill prevention concepts.

33. The Issues Converting USTs to ASTs = Higher Risk of Spills
Greater oil storage capacity
Greater number of ASTs
Greater annual throughput
= Higher Risk of Spills
Complying with SPCC regulations
Reduces number of spills, spill volume, and amount of oil migrating offsite
This slide discusses that facilities are trying to get out of the UST regulations by converting to ASTs. This translates to a higher risk of spills. Complying with the AST regulations reduces the risks.

34. What’s Aboveground?
The slide describes the parts of an AST. It includes:
Fill port
Pressure/vacuum vent
Emergency vent
Liquid level gauge
Internal fire valve
Block valve
Solenoid valve
Pressure relief valve
Pressure regulating valve
Suction pump
Monitored double-walled pipe (NOTE: Optional. Not a good idea)

35. Industry Standards SHOP BUILT TANKS
Steel Tank Institute SP-001 Standard for Inspection of Aboveground Storage Tanks
Underwriters Laboratory (UL) Standard 142 Steel Aboveground Tanks for Flammable and Combustible Liquids
National Fire Protection Association (NFPA) Code 30A Automotive and Marine Service Station Code, Chapters 1 and 2
National Fire Protection Association (NFPA) Code 30 Flammable and Combustible Liquids Code, Chapter Two
FIELD ERECTED TANKS
American Petroleum Institute (API) Standard 620 Design and Construction of Large, Welded, Low-Pressure Storage Tanks
API Standard 650 Welded Steel Tanks for Oil Storage
API Recommended Practice 651 Cathodic Protection of ASTs
API Recommended Practice 652 Lining AST Tank Bottoms
API Standard 653 Tank Inspection, Repair, Alteration, and Reconstruction
API Recommended Practice 920 Prevention of Brittle Fracture
API Standard 2015 Safe Entry and Cleaning of Tank
API Recommended Practice 2350 Overfill Protection for Petroleum Tanks
API Standard Design, Construction, Operation and Maintenance and Inspection of Terminal and Tank Facilities
Industry standards are technical guidelines created by experts in a particular industry for use throughout that industry. These guidelines assist in establishing common levels of safety and common practices for manufacture, maintenance, and repair.
Note that SP-001 is the standard for shop-built tanks. The API standards are standard for field erected tanks.
The SPCC rule requires that the Plan be prepared in accordance with good engineering practices, including the consideration of applicable industry standards. Use of a particular standard is voluntary. If a standard (or parts of a standard) is incorporated into a facility’s SPCC Plan, then adherence to that standard is mandatory for implementation of the Plan.

36. Corrosion Uniform Localized Microbial Influenced Galvanic Erosion
Environmentally Assisted Cracking
This slide present pictures of corroding metals and lists the different types of corrosion. Corrosion control is important to:
Preserve Assets
• Reduce Maintenance Costs
• Reduce Inspection Cost
• Preserve The Environment
An EPA study into the causes of oil releases indicates that the operational piping portion of an underground storage tank system is twice as likely as the tank portion to be the source of a discharge. Piping failures are caused equally by poor workmanship, improper installation, corrosion, or other forms of deterioration. The SPCC piping requirements aim to prevent oil discharges from aboveground or buried piping due to corrosion, operational accidents, or collision.
EPA recommends that a PE certifying an SPCC Plan consult appropriate industry standards (consulting a qualified corrosion professional may also be appropriate) when evaluating the adequacy of cathodic protection and corrosion prevention systems at the facility.

37. Tank Testing Hydrostatic Radiographic Ultrasonic Thickness Acoustic
For Large ASTs
Robotic applications
Vacuum
Magnetic Flux
This slide describes the type of non-destructive integrity tests used to detect leaks or ‘holidays’ in the metal shell of ASTs.
Hydrostatic test: Test of strength and leak-resistance of a vessel, pipe, or other hollow equipment by internal pressurization with a test liquid.
Radiographic test: A technique for revealing flaws and defects in a material or device without damaging or destroying the metal using the ability of short wavelength electromagnetic radiation to penetrate the metal. Cracks show up on the film.
Ultrasonic test: A technique for revealing flaws and defects in a material or device without damaging or destroying the metal using high-frequency reflection or attenuation . Cracks show up as an echo blip on the screen.
Acoustic test: A technique used to listen for bubbles of air indicating leaks or cracks.
Vacuum: A technique used at the bottom and shell of an AST to determine the strength of a shell-to-bottom weld seam.
Robotic applications: A camera mounted on a small magnetic robotic device that inspects the interior of ASTs.
Magnetic flux leakage: Flux leakage at a metal-loss region is caused by a local decrease in the thickness of the pipe wall. A sensor positioned on the inside (magnet side) of the pipe is typically used to measure the magnetic field adjacent to the pipe wall.

38. Factory Built Emergency Vents
Vents and Piping
Good Condition
Leaking Dispenser Piping
Factory Built Emergency Vents
Rubber Piping
All ASTs should have emergency relief vents. Emergency relief valves prevent ASTs from becoming over-pressurized and allow either pressure or vacuum to vent. Common problems are: rusting vents, vents painted shut, and general deterioration. Emergency relief valves in good condition are shown on this slide.
Piping associated with ASTs should be properly supported, protected against damage and stress, and be constructed of noncombustible materials. It should be free from leaks, identified as to product, and coated or painted to prevent corrosion. This slide shows two examples of piping in poor condition.

39. Valving and Level Monitoring
Clock Face Gauge
Dikes and berms must contain the largest tank plus 10% for rainwater or the single largest tank plus freeboard allowance. Typical freeboard equals the minimum dike height to contain the largest tank plus 6 inches.
Secondary containment valves on dikes or berms should be closed and locked except when draining rainwater. Dikes may be emptied by pump or ejectors but should be manually activated and the water inspected prior to discharge. Pumps should be locked when not in use. The slide shows a closed and locked drain valve as well as the position of drain valves on an example dike.
Note that the federal requirement is for overfill protection. Personnel must have some method of knowing that tank is going to overfill before it happens. Any method of warning personnel that overfills will occur is acceptable; however, once the method is described in the SPCC plan, it must be followed.
Different methods of preventing spills includes liquid level indicators. These can be float types: electrical and mechanical, pressure transmitters, or ultrasonic transmitters.
Electrical float indicators give continuous readings. Mechanical float indicators use a tape measure and magnetic interlock. Pressure transmitters use a pressure sensitive diaphragm to measure the hydrostatic head of the liquid. Ultrasonic transmitters use sound waves to provide accurate continuous product level.
Smaller ASTs typically have the mechanical gauge shown on the slide. Common problems are that the gauges are not readable and are rarely marked with warnings levels.
Secondary Containment Valves

40. Top Causes of Overfills
Training
Tank size restrictions
Inaudible alarm
Incompatible equipment
Dependent alarms
Lines improperly marked
Multiple tanks on common fill port
Poor inventory reconciliation
Not familiar with location
Filling entire tank
This slide lists the top causes of overfills. Of these ten top causes, 50% are related to Operator Inattention.
Operator Inattention!

41. Key Concepts Checking, testing and maintaining Equipment.
Doing routine preventative Actions.
Keeping good Records.
Training for proper Response.
The key concepts for ASTs are the same as USTs.

42. 40 C.F.R. § 112.20-112.21 Spill Prevention Requirements
Spill Prevention Control and Countermeasure (SPCC) Plans
Spill Response Requirements
Facility Response Plans (FRP or OPA-90)
The next slides provide an overview of Facility Response Plans (FRPs).

43. C-I Attachment FRP Flow Chart
This slide identifies the FRP universe. It is significant to the FRP and SPCC regulated facilities. If you answer YES to any questions, then you are required to use it to determine if you should complete an FRP and submit it to the EPA.
If the response planning requirements are inapplicable to your facility, you must complete and maintain at the facility the certification form in 40 CFR part 112 Appendix C Attachment C-II. This form is usually part of a SPCC plan.

44. 40 CFR § Covers
FRP (OPA-90)
Conduct over water transfers of oil and have a capacity of 42,000 gallons or greater OR
Total oil storage capacity of one million gallons or more
AND
Inadequate secondary containment
Could impact fish, wildlife or sensitive environments
Could shut down drinking water intakes
Reportable spill greater than 10,000 gallons within the past 5 years
This slide provides the details on Attachment C-I as well as picture of the consequences of a catastrophic spill.
If the facility conducts over water transfers of oil and has a capacity of 42,000 gallons or greater, then a Facility Response Plan is required to be submitted to the EPA. If any of the other questions in Attachment C-I are answered YES, then a FRP is required to be submitted to the EPA.

45. Regulatory Requirements at a Complex
What is a Complex?
Some facilities must meet the requirements of two or more federal agencies, because they engage in activities that fall under the jurisdiction of those agencies.
Who is Responsible for Regulating?
EPA is responsible for non-transportation- related facilities located landward of the
The Minerals Management Service of the Department of the Interior handles offshore non-transportation-related facilities located seaward of the coastline, including certain pipelines.
The USCG under DOT is responsible for deepwater ports and transportation-related facilities located landward of the coastline.
The activities at many facilities may be entirely non-transportation-related, and therefore only regulated by EPA. A facility with both transportation-related and non-transportation-related activities is regulated by both agencies, and as such, it is a complex and must comply with all the regulatory requirements of both agencies. For example, a complex may have a transportation-related transfer area regulated by the U.S. Coast Guard (USCG) or a pipeline regulated by the Office of Pipeline Safety under DOT and a non-transportation-related oil storage area regulated by EPA. The owner or operator must compare calculated discharge volumes for the two agencies and plan for whichever quantity is greater.
EPA is responsible for non-transportation- related facilities located landward of the coastline (e.g., inland lakes and rivers, including certain piping and coastal areas landward of the low water mark).
The Minerals Management Service of the Department of the Interior handles offshore non-transportation-related facilities located seaward of the coastline, including certain pipelines. (See 30 CFR Part 254)
The USCG under DOT is responsible for deepwater ports and transportation-related facilities located landward of the coastline. (See 33 CFR part 154, Subpart F). DOT’s Office of Pipeline Safety in the Research and Special Programs Administration handles many onshore pipelines (others are state regulated). (See 49 CFR part 194)

46. 40 C.F.R. § 112.20 Facility Response Plan (FRP)
Emergency Response Action Plan
Facility name, type, location, owner
Emergency notification information
Potential Discharges
Discharge detection procedures
Facilities that store and use oil are required to prepare and submit FRPs to respond to a worst case discharge (planning quantity) of oil and to a substantial threat of such a discharge. An FRP is a plan for responding, to the maximum extent practicable, to a worse case discharge, and to a substantial threat of such a discharge, of oil. The Plan also includes responding to small (2,100 gallons or less) and medium (between 2,100 and 36,000 gallons) or 10 percent of the worst case discharge, whichever is less) spills.
An important component of the FRP is the designation of Qualified Individual. This person must be able to obligate funds, and his/her duties during an emergency response must be clearly outlined.

47. 40 C.F.R. § 112.20 Facility Response Plan (FRP)
Plans for containment and disposal
Facility Inspection Plan
Training
Facility Diagrams of facility
Security Measures
The purpose of a FRP is to help an owner or operator develop a response organization and ensure the availability of response resources (i.e., response equipment, trained personnel) needed to respond to an oil discharge. The FRP demonstrates that the response resources are available in a timely manner, thereby reducing a discharge’s impact and severity. The FRP also helps a facility owner or operator improve discharge prevention measures through the early identification of risks at the facility. In addition, FRPs aid local and regional response authorities to better understand the potential hazards and response capabilities in their area.
The emphasis of the FRP is on the protection, deflection, and containment of spilled oil via the contingency planning. It allows the facility to appropriately plan a response and identify the resources necessary.

48. Critical Regulatory Aspects
Emergency Response Action Plan
Hazard identification
Vulnerability analysis
Planning distance calculation
Worst case discharge scenario
Equipment deployment and
NOAA environmentally sensitive environment maps
The slide describes the critical aspects of an Emergency Response Action Plan (contingency plan).
An oil spill contingency plan may appear complicated because it provides many details about the numerous steps required to prepare for and respond to spills. It also covers many different spill scenarios and addresses many different situations that may arise during or after a spill. Contingency plans usually have four major elements in common:
• Hazard identification
• Vulnerability analysis
• Risk assessment
• Response actions
Planners use hazard identification and vulnerability analysis to develop a risk assessment. The risk assessment is then used as the basis for planning specific response actions.

49. FRP Requirements Maintain copy of plan at facility and revisions
Log response training drills and exercises 40 CFR §
Record inspections
Review annually
Make changes, submit revisions within 60 days to EPA
The response plan must be maintained at the facility, along with plan updates reflecting material changes.
A log of response training drills and exercises must be kept. Annual response training drills are extremely important. The National Preparedness for Response Exercise Program (PREP) along with the discharge prevention, inspection, and spill monitoring aspects of the regulations are part of the overall logging and documentation process.
These documentation requirements must be retained for five years. Records of inspections of response equipment must also be kept for five years.
The FRP must comply with 40 CFR part 112 and any amendments. The relevant portions of the National Contingency Plan must be reviewed annually and revised to ensure consistency with these plans. Revised portions of the response plan must be submitted within 60 days

50. Things To Know SPCC plans and FRP are federal programs.
Additional federal oil spill plans are Vessel Response Plans and Shipboard Oil Pollution Emergency Plans .
States may have their own versions of these regulations and plans but do not enforce the federal programs.
State and federal plans can be combined as an Integrated Contingency Plan (ICP).
The SPCC and FRP programs are part of 40 CFR 112 which is not delegated to any states in the national program. A particular format is not specified for SPCC plans but a cross-reference table is required. The table must identify where all relevant sections of the SPCC plan are located in the document.
Vessel Response Plans and Shipboard Oil Pollution Emergency Plans are part of 33 CFR 151, 154, Substances addressed include not only petroleum products but also hazardous substances, animal fats, and vegetable oils.
Some states may have adopted similar programs and, at times, the states program can be more specific or stringent than the federal program. An ICP incorporating state requirements can be acceptable only if an appropriate cross-reference to SPCC requirements is provided.

51. 40 CFR 110.6 Spill Reporting Requirements
Any person in charge of a vessel or of an onshore facility shall as soon as he or she has knowledge of any discharge of oil … IMMEDIATELY notify the National Response Center (40 CFR 110.6)
Discharge includes, but is not limited to, any spilling, leaking, pumping, pouring, emitting, emptying, or dumping (40 CFR 109.2) Discharges of oil include discharges that: (a) Violate applicable water quality standards; or (b) Cause a film or sheen upon or discoloration of the surface of the water or adjoining shorelines or cause a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines.

52. EPA Information and Hotlines
National Response Center (NRC):
NCP Product Schedule Information:
For SPCC, FRP, & OPA Information:
gov/oilspill
Additional telephone numbers, website, and address to contact for information on the National Contingency Plan (NCP) and SPCC, FRP, and Oil Pollution Act (OPA).

53. Region 2 and 9 EPA Contacts
For questions or clarifications on the SPCC or FRP Rules, call or
Christopher Jimenez, SPCC Coordinator
Arlene Anderson, FRP Coordinator
Region 9 For questions or clarifications on the SPCC Rule, call or
Pete Reich Or
Mark Calhoon
Elizabeth M Cox

54. Storm Water Pollution Prevention Plans (SWP3)
The Clean Water Act NPDES Storm Water Program Phase I storm water regulations require facilities that (1) discharge to waters of the United States and (2) engage in industrial activities, including construction activity of over 5 acres of land, to perform the following:
Obtain National Pollutant Discharge Elimination System (NPDES) Permit Coverage from the appropriate state or federal permitting authorities
Develop a Storm Water Pollution Prevention Plan (SWP3)
Implement Best Management Practices (BMPs), including structural and operational controls, to prevent the migration of pollutants (including sediments) off-site via storm water runoff.
Storm water runoff from residential, commercial, and industrial areas is responsible for 21 percent of impaired lakes and 45 percent of impaired estuaries in the United States. These impacts are caused not only by the quality of runoff (storm water contains heavy metals, bacteria, pesticides, suspended solids, nutrients, and floatable materials), but also by its quantity, as a high volume of flow contributes to erosion and sedimentation, and impacts aquatic habitats.

55. Clean Water Act Regulatory History
Amended 1987
National Pollution Discharge System (NPDES) established November 6, 1990.
NPDES consists of Phase I and II regulations
The earliest federal action toward protecting the nation's water was the Refuse Act of The act outlawed the "dumping of refuse that would obstruct navigation of navigable waters, except under a federal permit." In the 1960's the language of this act was interpreted by the courts to cover any industrial waste.
NPDES stands for National Pollutant Discharge Elimination System. Under the NPDES program, all municipal, industrial and commercial facilities that discharge wastewater directly from a point source (a discrete conveyance such as a pipe, ditch or channel) into a receiving waterbody (lake, river, ocean) are issued an NPDES permit.
“NPDES prohibits [discharges] of pollutants from any point source into the nation's waters except as allowed under an NPDES permit." The program gives the EPA the authority to regulate discharges into the nation's waters by setting limits on the effluent that can be introduced into a body of water from an operating and permitted facility.
The program became more complex in 1977 when Congress amended the Clean Water Act to enhance the NPDES program. The amendment "shifted the focus from controlling conventional pollutants to controlling toxic discharges."

56. NPDES Storm Water Program
Phase I
Medium and Large municipal separate storm water
Sewer systems (MS4s) in communities with populations greater then 100,000
Construction activities disturbing greater then 5 acres
Certain SIC codes
Phase II
Certain small municipal separate storm sewer systems (MS4s)
Construction activity disturbing between 1 and 5 acres
This slide discusses what entities are regulated by the NPDES program.
So-called "point sources" are generated from a variety of municipal and industrial operations, including treated wastewater, process water, cooling water, and storm water runoff from drainage systems. The NPDES Phase I Storm Water Program (EPA HQ) in place since 1990, regulates cities and counties with populations of 100,000 that operate a municipal separate storm sewer system (MS4), specific industrial operations, and construction activities that disturb 5 or more acres of land. The Phase II Storm Water Program (EPA HQ) became effective March It regulates MS4s located within "urbanized areas" as defined by the latest census from the U.S. Census Bureau and construction activities that disturb between 1 and 5 acres.

57. Federal Facilities Vehicle Maintenance Facilities!!! Fueling
Loading/Unloading to USTs or ASTs
Vehicle/Equipment Washing
Handling fuels, oils or chemicals
Federal facilities may be required to prepare Stormwater Pollution Prevention Plans (SWP3). It is not the major two-digit part of the SIC code that determines whether a SWP3 is required but the whole four digit code.
Common noncompliance issues for NPDES at federal facilities are:
SWP3 not developed
Inspections not conducted
BMPs not implemented
No training
Demonstration

58. SWP3 Elements Descriptions of Oil Storage Maps Stormwater BMPs
Employee Training
Inspections
Certifications
/Amendments
Monitoring
Requirements
Annual Compliance
Report
Spill Response/
Procedures
The same basic information is required in more than one place in the SWPPP and, once accumulated, can be used again.
Much of the information is based upon observation and common sense.
The major components of the SWPPP are:
Pollution prevention team;
Site map;
Description of potential pollutant sources;
Measures and controls for stormwater management; and
Comprehensive site compliance evaluation.
The next slides provide more detail on the pollution prevention team, measures and controls (BMPs and inspections), and the comprehensive site compliance evaluation.

59. P2 Team/Training Pollution Prevention Team Employee Training
Environmental Manager
Maintenance Technicians/
Operators
Employee Training
In-house employee training programs are established to teach employees about storm water management, potential sources of contaminants, and Best Management Practices (BMPs).
Employee training programs should present the SWP3, including BMPs, processes and materials at the facility, safety hazards, practices for preventing discharges, and procedures for responding quickly and properly to toxic and hazardous material incidents.
An employee training program should be an on-going, yearly process. Meetings about SWP3s should be held at least annually.
Demonstration

60. Stormwater BMPs Structural BMPs Non Structural BMPs Procedural BMPs
This slide discusses stormwater Best Management Practices (BMPs). These include:
Structural BMPs such as leak detection systems and secondary containment.
Non Structural BMPs such as employee training, good housekeeping, minimizing exposure, and preventive maintenance
Procedural BMPs such as tank filling, fuel dispensing, and spill prevention and response.
Additional information on BMPs are available through the new National Storm Water BMP Database and BMP design manuals and guidance prepared by EPA and other Federal agencies, states and local governments.

61. Inspections Exteriors of ASTs and oil storage containers
Spill response equipment
Secondary containment
Transfer areas
Visual inspection is a BMP in which members of a Storm Water Pollution Prevention Team visually examine material storage and outdoor processing areas, the storm water discharges from such areas, and the environment in the vicinity of the discharges, to identify contaminated runoff and its possible sources.
In a visual inspection, storm water runoff may be examined for the presence of floating and suspended materials, oil and grease, discoloration, turbidity, odor, or foam; and storage areas may be inspected for leaks from containers, discolorations on the storage area floor, or other indications of a potential for pollutants to contaminate storm water runoff.
Visual inspections may indicate the need to modify a facility to reduce the risk of contaminating runoff.

62. Comprehensive Site Compliance Evaluation
Annual Compliance Inspection
Inspection results
Changes to facility’s operations/activities
Data comparison
New BMPs/corrective measures
Previous year’s information
This evaluation must be conducted periodically and not less than once per year. This requirement ensures that the facility attains and remains in compliance. The comprehensive site evaluation must be included in the SWPPP and should include:
Review the SWPPP, BMPs, records and site map.
Walk the facility to verify compliance.
Identify existing problems.
Look for potential problems.
Determine if BMPs are being implemented and are adequate.
New sources of pollution should be identified and BMPs should be written.
Revise the site map and the SWPPP if needed.
Review monitoring results.
Include the date and person responsible for the site evaluation.
Record your findings. This information will be necessary for your annual report.

63. Spill Response Identify source Take Action! Stop the spill
Immediately secure the spill area
If the material is flammable, remove all sources of ignition
Collect used spill material in a covered DOT approved container
Date, label, and staged in a secure area
Determine appropriate disposal method and contact waste hauler
Knowing what to do when spills happen is essential to employee safety as well as minimizing harm to the environment. Planning, training and drilling are the keys to helping everyone know what to do and when to do it when an emergency does arise.
By law, the Occupational Safety and Health Administration requires employers to train employees on hazards in the workplace (29 CFR ). In addition, if employees will respond to spills, they must be trained to be aware of the dangers the spill presents and how to respond in a safe manner. Steps for spill response are:
1. Identify the spill.
2. Notify. Train employees whom they should contact when they see a spill. Even if they can't identify the spill, they need to know who to tell so that identification can be made and response can be started.
3. Protect responders. If anyone is injured in the spill area and needs assistance, spill responders are trained to make recovering them their first goal.
4. Contain the spill. The first step for responders who will actually perform clean up operations is to contain the spill. The smaller the area, the less space that has to be cleaned up and decontaminated.
5. Stop the source. If the source of the spill has not stopped leaking, responders should next try to stop the source of the leak. supplies.
6. Clean up the spill.
7. Decontaminate.
Additional steps include completing paperwork and restocking.

64. Spill Notification Name, location, organization, and telephone number
Name and address of responsible party
Date and time of incident
Location of the incident
Source/cause of release
What was spilled and the quantity?
Danger or toxicity posed by the release/spill?
Any injuries? How many?
Weather conditions
Other information
An important part of an SWP3 is establishing a method for quick notification of the appropriate emergency response teams in the event of a spill.
In some facilities, each area or process may have a separate team leader and/or response team. These should include phone numbers of key personnel and appropriate regulatory agencies, such as local Pollution Control Agencies and the local Sewer Authority.

65. Spill Notification Contact the National Response Center (NRC),
at hours a day
See SWP3 for state and local contacts
Repeat of telephone number to contact for in case of spills.
The facility’s SWP3 should contain state and local contact numbers such as those for the fire department.

66. SWP3 Summary Best Judgment Required!
Applies to federal facility vehicle maintenance facilities
Major components of the SWPPP are:
Pollution prevention team;
Site map;
Description of potential pollutant sources;
Measures and controls for stormwater management; and
Comprehensive site compliance evaluation.
Must be updated when facility operations/activities change
Best Judgment Required!
Much of the information in a SWP3 is based upon observation and common sense.

67. Key Concepts Develop SWP3 Conduct inspections Implement BMPs
Train annually
Update annually
The slide describes the necessary actions to avoid the common noncompliance issues at federal facilities.

68. Other Federal AST Regulations
The next and final slides describe other federal AST regulations relating to air contaminants.

69. Other Federal AST Regulations
New Source Performance Standards (NSPS)
Resource Conservation and Recovery Act (RCRA), Subpart J
RCRA Subparts AA, BB, CC
Clean Air Act – Highway Rule
This slide describes other federal AST regulations applying to air permitting or releases from ASTs and USTs.

70. NSPS Tank Capacity Vapor Pressure Requirements > 40, 00 gallons
68 mm Hg – 570 mm Hg
Floating Roof
>570 mm Hg
Vapor Recovery System
10.3 kPA – 76.7 kPA
External Floating Roof OR Fixed Roof With Internal Floating Type Cover OR Vapor Recovery System
10,566 – 19,813 gallons -
Keep records only
NSPS standards require floating roofs and vapor recovery systems or equivalents for certain ASTs. The criteria become more stringent for newer petroleum storage vessels. Whether or not NSPS criteria will apply to an AST owner or operator depends on the storage capacity of the AST and the vapor pressure of the petroleum liquid stored. NSPS also requires at least annual inspections of seal gaps, notification to EPA of commencement of construction and start-up, and monitoring.
For bulk gasoline terminals, NSPS require installation of vapor collection systems for tank trucks during product loading. Loadings may only be made into gasoline tank trucks tested for vapor tightness. In addition, NSPS require monthly liquid and vapor leak inspections. Inspection records must be kept at the terminal for at least two years. Any leaks must be repaired within fifteen days.

71. RCRA 264/265, Subpart J Hazardous Waste Tanks
Proper installation, operation and inspection
Integrity of primary containment system
Monitoring for leaks
Response to releases
Proper closure and post-closure
Subpart J specifies requirements for the design, construction, installation, operation, inspection, maintenance, repair, release response, and closure of hazardous waste tanks. Also, the regulations make a distinction between "new" and "existing" tanks.
Existing hazardous waste tanks are those for which construction commenced on or before July 14, New hazardous waste tanks are those for which construction commenced after that date. Existing tanks that are returned to service after being repaired are also considered "new“ tanks. The requirements for the two tank classifications are substantively the same, except that existing tanks are subject to integrity testing requirements, and new tanks require a secondary containment system. Additionally, continued operation of existing tanks will require installation of a secondary containment system.

72. Subpart J Additional Elements
Corrosion Protection
Vaults
Secondary containment for ancillary equipment
Spill control equipment (e.g., check valves, freeboard)
Inspections
Waste analysis and trial tests
Corrosion protection measures are mandatory for certain new tank systems and components.
In a vault system, the hazardous waste tank rests in an underground chamber usually constructed with concrete floors and walls and an impermeable cover. Concrete vaults must have a waterproof exterior and be lined inside with a leak-proof sealant.
Secondary containment is an emergency short-term storage system designed to hold releases from hazardous waste tanks.
Spills or overflows from the tank or secondary containment system must be prevented by using spill prevention controls such as check valves, overfill prevention controls such as high level alarms and automatic feed cutoffs, and sufficient freeboard in uncovered tanks to prevent overflow due to wave or wind action or precipitation.
Properly conducted inspections should minimize the probability of accidental releases into the environment and contribute to safe working conditions in and around the storage area. Secondary containment systems and cathodic protection devices also require regular inspection.
Owners and operators of interim status hazardous waste tanks must perform additional waste analysis and trial tests beyond what is required for all treatment, storage, and disposal facilities.

73. RCRA, Subparts AA, BB, CC
AA, BB – Emissions from Process Vents Associated with Hazardous Waste
CC – Organic Air Emission from Large Quantity Generators and Treatment, Storage and Disposal Facilities
Subpart AA applies to six specific types of units that have associated process vents: steam strippers, distillation units, fractionation units, thin-film evaporation units, solvent extraction units, and air strippers. Owners and operators of facilities subject to Subpart AA must install control mechanisms that reduce organic air emissions from vents covered by the standards to both 3.0 pounds per hour (1.4 kg/h) and 3.1 tons per year (2.8 Mg/y) or reduction of organic air emissions at the facility by 95 percent by weight.
Subpart BB sets equipment leak standards and applies to the following: Units subject to the permitting standards of Part 270, recycling units located at hazardous waste management facilities, and less than 90-day large quantity generator units.
Subpart CC controls volatile organic air emissions and applies to non-exempt hazardous waste tanks. Hazardous waste tanks must be equipped with a cover or floating roof, or be designed to operate as a closed system, to be in compliance with the air emission control requirements. Subpart CC includes waste determination, monitoring, inspection, recordkeeping, and reporting procedures that are applicable to tanks that control volatile organic air emissions through the use of covers.

74. Diesel Fuel Content 15 ppm sulfur required – June 2006
2007 Heavy Duty Diesel exhaust standards
The Highway Diesel and Nonroad Diesel Rules implement more stringent standards for new diesel engines and fuels.
The rules mandate the use of lower sulfur fuels in diesel engines beginning in 2006 for highway diesel fuel, and 2007 for nonroad diesel fuel.
80% of highway diesel fuel must be Ultra Low Sulfur Diesel [ULSD] (≤ 15 ppm sulfur) beginning June 1, 2006.
These fuels will enable the use of aftertreatment technologies for new diesel engines, which can reduce harmful emissions by 90 percent or more. Aftertreatment technologies will start phasing into the diesel sector beginning in 2007 for highway and 2011 for nonroad.
These programs will yield significant, long-term benefits for public health and the environment.

75. Summary Limit VOLs emissions from ASTs
Specific Regulations for Hazardous Waste Tanks and Their Emissions
Diesel Fuel Sulfur Content Reduced
Additional regulations limit emissions of Volatile Organic Liquids (VOLs) from ASTs.
The Resource Conservation and Recovery Act (RCRA) Subparts J, AA, BB, and CC apply to air emissions from hazardous waste tanks and pipelines.
Diesel fuel now stored in ASTs and USTs must have 15 ppm of sulfur.