Storage Tanks

Storage Tanks Management

Environmental concerns have led to a significant increase in the number of compliance requirements across all global regulatory environments. In order to comply with those requirements, some conditions must be met.

Storage Tanks Management

Storage tanks are widely used in industrial processes to store chemicals, hazardous substances, and petroleum products. Depending on their design, these tanks and containers are known as either underground storage tanks (USTs) or aboveground storage tanks (ASTs).

Since ASTs and USTs are widely used by industry and could potentially cause hazardous substance releases, several federal and state environmental laws regulate the management of storage tanks.
The U.S. Environmental Protection Agency (EPA) promulgates regulations that affect storage tank management under the Clean Water Act (CWA) and the Resource Conservation and Recovery Act (RCRA).

In addition, ASTs are primarily regulated at the state level. States and local governments may have their own laws that affect UST management as well.

Why is it important to comply with the storage tank regulations?

Storage tanks contain hazardous substances or petroleum products, which can contaminate the air, surface water, and groundwater if released.
For example, storage tank leakage can contaminate drinking water sources by releasing chemicals or oil pollutants into groundwater.

Furthermore, ASTs can release vapors into the air that can cause harm to public health and the environment. Depending on the size and contents of the tanks, a storage tank owner or operator can be subject to several federal, state, and local regulatory requirements.

That is why storage tank management is a key issue for most companies using hazardous substances or petroleum products

Important storage tank provisions

Because storage tanks are widely used and can potentially have a number of different impacts on human health and the environment, the Clean Water Act (CWA) and the Resource Conservation and Recovery Act (RCRA) contain provisions that affect storage tank management.

Clean Water Act

Under the CWA regulations, facilities are required to create a Spill Prevention, Control, and Countermeasure Plan (SPCC) to prevent oil releases from storage tanks to navigable U.S. waters. The SPCC is a facility plan that establishes procedures, methods, and equipment requirements to prevent and control spills from oil-containing tanks. A facility is subject to the CWA SPCC requirements when its aggregate AST capacity is greater than 1,320 gallons or it has an aggregate UST capacity greater than 42,000 gallons. This aggregate only includes tanks 55-gallons or larger. Under the CWA, tanks must be regularly tested for structural integrity, especially whenever material repairs are made, by inspecting the container for signs of deterioration or discharges.

Resource Conservation and Recovery Act

While the storage tank provisions under CWA only apply to oil-containing tanks, RCRA’s UST requirements apply to tank systems that contain hazardous substances or petroleum and have a 1,100 gallon capacity or more. Under RCRA, these storage tanks must conform to certain design standards to ensure they can contain their hazardous substances or petroleum products. For example, tanks must be made of a material that is compatible with the stored substance. Furthermore, storage tanks must be equipped with secondary containment to prevent spills. Finally, storage tanks must be installed in accordance with good engineering practices to avoid releases.

Resource Conservation and Recovery Act Overlap with Clean Air Act

Large Quantity Generators (LQG) that store hazardous waste in tanks must comply with RCRA and 40 CFR 265, Subpart CC. This subpart contains standards that regulate organic air emissions from tanks with average volatile organic concentrations of 500 ppmw (parts per million weight) or more. Owners and operators must maintain emission controls and follow testing procedures to reduce organic air emissions from their tanks. This subpart also requires owners and operators to certify that the tank is equipped with these air emission controls.

Importance of implementing an active regulatory watch on the storage tank regulations

In June 2015, the EPA significantly amended the RCRA UST regulations. The new rules require tank designs that are less likely to result in releases as well as secondary containment systems for new tanks.

In addition, individual states can implement storage tank programs that are stricter than the federal standards that apply to ASTs and USTs. ASTs in particular are largely regulated at the state level.
A regulatory watch is beneficial because it indicates whether and how the state tank regulations change in response to any federal amendments, or whether new state-specific requirements have been enacted.


Definitions

Aboveground Storage Tank (AST)

An aboveground storage tank, also known as a bulk storage container, is a tank that has at least 55 gallons capacity and is aboveground. Though the federal requirements for Spill Prevention, Control, and Countermeasure (SPCC) Plans apply to such tanks, ASTs are primarily regulated at the state level.

Underground Storage Tank (UST)

An underground storage tank system consists of a tank, connecting piping, ancillary equipment, and a containment system that have at least ten percent of their combined volume underground.
The UST federal rules apply to tank systems that contain hazardous substances or petroleum and have a 1,100 gallon capacity or more.

Spill Prevention Control and Countermeasure (SPCC) Plan

Under the Clean Water Act, a SPCC is a facility plan that establishes procedures, methods, and equipment requirements to prevent and control oil releases to navigable U.S. waters.
Facilities are required generate a SPCC when they use aboveground storage tanks or containers that exceed 1,320 gallons or underground storage tanks that exceed 42,000 gallons capacity.

Good Engineering Practices

Good engineering practices are technical activities that ensure that a product is manufactured or installed at the required level of quality.

What is a Large Quantity Generator (LQG)?

Under the Resource Conservation and Recovery Act, LQGs are facilities that generate 1,000 kg of hazardous waste or more per month.

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