COMPLIANCE MANAGEMENT STRATEGIES. Presented by: Megan Kazmierczak, ECS Eclipse



Similar documents
UPDATE ON MAINE'S UNDERGROUND TANK LAWS

Welcome UST Owners & Operators!!

Dollars And Sense Financial Responsibility Requirements For UndergroundStorage Tanks

UST Site Inspection Guidance Document

District of Columbia Municipal Regulations UNDERGROUND STORAGE TANKS: GENERAL PROVISIONS 5500 COMPLIANCE WITH OTHER DISTRICT LAWS

Underground Storage Tank Operational Compliance Field Guide

Spill Prevention, Control and Countermeasure (SPCC) Rule

FUELING AND FUEL STORAGE

FACILITY ENVIRONMENTAL COMPLIANCE

Design of a Fuel Oil Storage Facility

OIL STORAGE REQUIREMENTS OF THE SPCC REGULATIONS. Christopher J. Ecsedy, P.E. Fuss & O'Neill, Inc. 146 Hartford Road Manchester, CT 06040

Spill Control Prevention Plan (SCPP)

Agenda Item 16 Compilation of States Above-Ground Storage Tank Programs and Regulations

Tanks: What's in store?

CHAPTER PETROLEUM CONTACT WATER

Secondary Containment & Spill Buckets Inspection, Testing, and Repair Solutions. Allen Porter May 28, 2015

APPENDIX G Materials Storage and Handling Guidelines

Doing Inventory Control Right For Underground Storage Tanks

SPILL PREVENTION AND RESPONSE PLAN TEMPLATE FOR BUSINESSES IN DAYTON S SOURCE WATER PROTECTION AREA

Straight Talk On Tanks Leak Detection Methods For Petroleum Underground Storage Tanks And Piping

Northern Region. Underground Storage Tank

MAINE DEPARTMENT OF ENVIRONMENTAL PROTECTION

Waste Oil Collection / Storage

Shop Fabricated Aboveground Tank Construction Standards


Pollution Prevention And Best Management Practices For Dry Cleaners Operating In Broward County

NDEP Bureau of Corrective Actions Secondary Containment Regulations Guidance Document April 7, 2010 (Revision)

Spill Prevention, Control and Countermeasure (SPCC)

ACTIVITY NAME. Training Requirements for Spill Prevention Control and Countermeasures (SPCC) 40 CFR Part 112 Naval Air Station Corpus Christi Texas

DRAFT REVISED Musts For USTs DRAFT. Printed on Recycled Paper. Updated June 2015

STORAGE TANK INSPECTION AND COMPLIANCE PHILLIP BENTON CERTIFIED TANK INSPECTOR

Spill Prevention, Control, and Countermeasures (SPCC) Course Material

Spill Prevention, Control, and Countermeasures (SPCC) Regulations Update

History of the SPCC Rule

Underground Storage Tanks

1) Named Insured: 2) Insured s Street Mailing Address:

Spill Prevention, Control and Countermeasure (SPCC) Training

Secondary Containment Options for Aboveground and Underground Tanks. Wayne Geyer Steel Tank Institute

DIRECTIVE 055: STORAGE REQUIREMENTS FOR THE UPSTREAM PETROLEUM INDUSTRY. August 2012

Spill Prevention Control & Countermeasure (SPCC) for Farms

Storage Tank Systems for Petroleum products and allied petroleum products regulations

AUTOMATIC TANK GAUGING SYSTEMS Achieving Compliance. John D. Sieger, Tanknology

UST RULES CHANGES. Heather Peters, Environmental Specialist

KANSAS STORAGE TANK PROGRAM ABOVEGROUND STORAGE TANK OVERVIEW March 2, 2015

The Federal Spill Prevention, Control & Countermeasures (SPCC) Rule Overview

~CSRMA ALERT~ REVISED SPCC RULE WILL IMPACT MOST POTW S

Tank Environmental Regulations. Aisha Beaty Barr Engineering Company

Petroleum Tanks at Municipal Facilities

This page left intentionally blank

Alabama Air and Waste Regulatory Update

SPILL PREVENTION, CONTROL, AND COUNTER MEASURES PLAN (SPCC)

Application for the Construction or Installation of Aboveground Storage Tank (AST) Systems or Associated Underground or Over-water Piping Systems

STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS DEPARTMENT OF ENVIRONMENTAL MANAGEMENT OFFICE OF COMPLIANCE & INSPECTION

The Fuel Storage Tank Regulations 2009

Improper storage of fuel on construction sites will increase the risk of water pollution that may occur as a result of leaks or spills.

Farm Fuel Tank Safety Guide

Used Oil Guidance. Tank and Secondary Containment Requirements For Used Oil Processors

Maryland Containment System Testing Protocol. The individual performing the inspection and testing as outlined in this protocol must be either:

SPCC for Food Services

Bulk Storage Program. Cornell University 8/22/2014

Background Document for Public Comment. February, 2014

Appendix E: Spills. Spill Prevention, Control, and Countermeasure Plans Your Role in Spill Response: What to Do if You Have a Spill...

1. Who is your current pollution carrier? Expiration Date: Premium: Retroactive Date:

UNIVERSITY OF WISCONSIN MADISON

ABOVE-GROUND STORAGE TANKS

Safety Manual Title: Spill Prevention & Response Review Date: 6/1/2014

Title: Fuel Transport - Tank Truck

Brian Derge Tanknology Inc. February 26, 2015

OIL POLLUTION PREVENTION REGULATIONS

ALL UST SYSTEMS. MOTOR FUEL, USED OIL, BULK HEATING OIL STORAGE (Federal/State Regulated Systems)

SPILL PREVENTION, CONTROL AND COUNTERMEASURE PLAN

Pollution Liability Exposure: Adjustments your automotive business should consider to maintain compliance

SUBJECT: Effective Date: Procedure Number: Contractor Environmental Management. 09/03/13 emp11 Procedures

Petroleum Storage Tank Compliance 101

How To Get A Stormwater Discharge Permit In A City Of Scottsdale

CONTRACTOR ENVIRONMENTAL LIABILITY 101. Violation of environmental laws may result in fine or imprisonment or both.

The Federal Spill Prevention, Control & Countermeasures (SPCC) Rule Overview

TRAINING SPCC/SWPP Training UGA. Automotive Center. Campus Transit

Regulations and Recommended Practices. Introduction. American Petroleum Institute Recommended Practices 2350

LEHMAN COLLEGE: DEPARTMENTAL RETENTION SCHEDULE 11/18/2013 ENVIRONMENTAL HEALTH & SAFETY. Report and recommendation resulting from investigation

Monitoring an Underground Storage Tank Facility

PCB STORAGE. 1) 2-drum unit (4 x 2 x 4 ) 2) 4-drum unit (4 x 4 x 4 ) 3) 8-drum unit (8 x 4 x 4 ) 4) 16-drum unit (8 x 8 x 10 )

How To Safely Handle A Spill

Spill Prevention Control and Countermeasure (SPCC) Regulations Fact Sheet

Kurt Wilson Louisiana Dept. of Environmental Quality Business & Community Outreach Division Small Business/Small Community Assistance Program

Daily Inventory and. Statistical Inventory Analysis. Daily Inventory and Statistical Inventory Analysis (SIA) are inventory control

Spill Prevention, Control & Cleanup SC-11

Environmental Standard Operating Procedure Originating Office: MCAS Miramar Environmental Management Department

Safe Operating Procedure

Leak Detection and Alternative Fuels 21 st Annual National Tanks Conference Sacramento, CA

Steel Tank Institute AST Inspections. Dana Schmidt, PE STI/SPFA

Spill Prevention Control and Countermeasure Plan

New York State Department of Environmental Conservation 625 Broadway, Albany, NY Environmental Self Audit For Small Businesses

AMERICAN INTERNATIONAL COMPANIES

SILICON VALLEY CLEAN WATER. May 2015

Outdoor Storage of Raw Materials SC-33

UST System Inspection Checklist

DIRECTIVE 055: STORAGE REQUIREMENTS FOR THE UPSTREAM PETROLEUM INDUSTRY

SPCC. Created by EPA in 1973 under the Clean Water Act. 10/22/2014. Spill Prevention Control & Countermeasure Plan

Transcription:

COMPLIANCE MANAGEMENT STRATEGIES Presented by: Megan Kazmierczak, ECS Eclipse

AST vs. UST Compliance requirements Aboveground Storage Tanks (ASTs): Misconception that ASTs are unregulated Most are subject to federal requirements and some may also be subject to state or local requirements ASTs generally have fewer compliance items to track Underground Storage Tanks (USTs): Subject to federal, state and sometimes local requirements In most cases, have more compliance requirements than ASTs

AST Compliance Background No single federal regulatory program for ASTs Several federal and state regulations, laws, codes Examples of requirements that may apply to ASTs: Spill Prevention Control and Countermeasure (SPCC) regulations Federal EPA program Developed under Clean Water Act, 40 CFR Part 112 Purpose is to protect from discharge into water Applicability depends on material stored and quantity

AST Compliance Background Examples of requirements that may apply to ASTs: National pollutant discharge elimination system (NPDES) storm water permitting Also developed under Clean Water Act Developed to protect runoff to storm water from activities at industrial facilities Ohio EPA program: http://www.epa.ohio.gov/dsw/storm/index.aspx Flammable/Combustible Liquid Storage Regulated under Ohio Fire Code Local fire department may also have requirements

UST Compliance Background 1983 - CBS s 60 Minutes aired Check the Water which brought national attention to the effects of leaking underground storage tanks (USTs) At this time UST s were: Steel tanks unprotected from corrosion Had no spill or overfill prevention/protection Were not being monitored for releases 1984 - Congress required EPA to develop regulatory Underground Storage Tank Program (required by Subtitle I of Resource Conservation and Recovery Act (RCRA)) The UST Program was developed in response to the problems created by more than 2 Million USTs operating in 1984, many old and leaking, threatening groundwater.

UST Compliance Background 1986 Congress amended Subtitle I of RCRA and created Leaking Underground Storage Tank (LUST) Trust Fund To oversee cleanups To pay for cleanups at sites where owner/operator cannot or does not pay 1988 EPA issued the new UST regulations 40 CFR Part 280, 40 CFR Part 281 and 40 CFR Parts 280.50 282.105 Allowed approved state UST programs to operate in place of federal program In Ohio, regulated by State Fire Marshal, Bureau of Underground Storage Tanks (BUSTR)

UST Compliance Background 1989 New Requirements Started Phase-In of Leak Detection began, including Tank/Line tightness testing New tanks must have spill/overfill, corrosion protection 1998- Existing Tanks Upgrade Deadline Spill, Overfill Prevention Monthly Leak Detection Corrosion Protection Double Wall Tanks

UST Compliance Background 2002 - EPA reported 26% of USTs still had significant problems March 2003 GAO Report Concluded 200,000 Tanks (30%) not operated and maintained properly (May 2001) Tanks significantly still leaking into environment Even tanks with new equipment still leaking EPA and States Reported -DID NOT have sufficient manpower and funds to inspect all tanks 2005 Energy Policy Act amended Subtitle I of the Solid Waste Disposal Act Required all regulated USTs be inspected every 3 years Secondary containment for new installs Delivery prohibition (red tags) Operator training (8/8/2012 deadline)

AST/UST Compliance Future Where are we going? New state and federal UST regulations Mandatory removal requirements for single-wall systems More stringent requirements for monitoring and testing of secondary containment New regulations allowing decommissioning of Stage II vapor recovery New regulations requiring periodic testing of Stage I vapor recovery

Ohio Petroleum Underground Storage Tank 2012 Annual Report Statistics required by 2005 US Energy Policy Act 2012 Annual Report info posted April 2, 2013 Covers period October 1, 2011 through September 30, 2012 Total number of UST facilities at the end of the reporting period: 7,596 Total number of underground storage tanks at the end of the reporting period: 22,144 Inspection info: Number of facilities inspected: 2,877 Percent of UST facilities inspected meeting release prevention (corrosion protection, spill and overfill) and release detection requirements: 89%

Ohio Petroleum Underground Storage Release info: Tank 2012 Annual Report Covers release reporting period October 1, 2011 through September 30, 2012 Only UST releases that were identified to have taken place during the reporting period were been included in this report. Total new UST releases that took place during the reporting period: *72 *There are 12 multiple sources identified for the reported 72 releases

Ohio Petroleum Underground Storage Tank 2012 Annual Report Release info: Detail about source of releases Tanks: 9 releases (13% of 72 releases) Physical/Mechanical Damage: 1 (11% of 9 releases) Corrosion: 1 (11% of 9 releases) Unknown: 7 (78% of 9 releases) Piping: 18 releases (25% of 72 releases) Physical/Mechanical Damage: 8 (44% of 18 releases) Unknown: 10 (56% of 18 releases)

Ohio Petroleum Underground Storage Tank 2012 Annual Report Release info: Detail about source of releases Dispenser: 13 releases (18% of 72 releases) Physical/Mechanical Damage: 7 (54% of 13 releases) Other: 1 (8% of 13 releases) Unknown: 5 (38% of 13 releases) Submersible Turbine Pump (STP): 3 releases (4% of 72 releases) Unknown: 3 (100% of 3 releases)

Ohio Petroleum Underground Storage Tank 2012 Annual Report Release info: Detail about source of releases Delivery problem: 3 releases (4% of 72 releases) Spill: 1 (33% of 3 releases) Overfill: 2 (67% of 3 releases) Unknown: 25 releases (35% of 72 releases) Unknown: 25 (100% of 25 releases) To view report, or for past reports: http://www.com.ohio.gov/fire/bustrannu alreports.aspx

Why Maintain Compliance? Reduce environmental risks Fumes from leaks can cause explosions or fire Leaking USTs and ASTs contaminate groundwater, surface water and soils Be prepared for inspections The number of compliance requirements is increasing Inspections have increased. BUSTR inspects UST facilities every 3 years Once issues found, may be subject to increased scrutiny

Why Maintain Compliance? Avoid fines and penalties Fines and penalties could be the result of not maintaining compliance A reminder from the BUSTR Operational Compliance Guide: IF YOUR UST SYSTEM IS NOT EQUIPPED AND OPERATED IN COMPLIANCE WITH FEDERAL AND STATE REGULATIONS, THE FIRE MARSHAL HAS THE AUTHORITY TO FINE YOU UP TO $10,000 FOR EVERY DAY YOU REMAIN IN VIOLATION. Stop station disruption Avoid red tag shutdowns Also from the BUSTR Operational Compliance Guide: THE FIRE MARSHAL HAS THE AUTHORITY TO PLACE A RED TAG ON YOUR UST AND PROHIBIT DELIVERY OF FUEL TO YOUR UST.

Why Maintain Compliance? Ensure cleanup fund eligibility Eliminate the possibility of rejection, due to noncompliance, by state cleanup fund Improve facility performance Improve facility recordkeeping and employee training Identify maintenance or risk issues before they become a problem

How to Achieve Compliance? Understand what is required Agencies Regulations Establish a compliance program Review options, determine best for you

Important Aspects of Compliance Equipment inventory Know what you have Permitting and fees UST related: BUSTR registration, fees, UST permits for work, out of service, etc. State fund: PUSTRCB certificate, financial responsibility Air quality: Ohio EPA Permits to install and operate (PTI and PTO) or Permit to install/operate (PTIO), Permit by rule (PBR, if applicable), emissions related filings and fees Local (if applicable) Federal (if applicable)

Important Aspects of Compliance Testing and inspections Determine requirements for periodic testing and inspections Keep track of due dates Make sure required testing and inspections are performed Maintenance and equipment info Keep equipment in good working order May be specific inspection forms / checklists BUSTR Operational Compliance Form Stage II equipment inspection and maintenance logs Impressed current rectifier check logs

Important Aspects of Compliance Training Class A, B and C UST operator training Stage I/II vapor recovery training Release detection Need passing result each month ATG, interstitial monitoring or other approved method (Statistical Inventory Reconciliation (SIR)) Next steps for non-passing results Alarm management (ATG) Release reporting

Important Aspects of Compliance Recordkeeping Maintain organized records related to all aspects of compliance management NOV resolution Regulatory changes Follow and understand

Compliance Management Options How can owner/operator manage all compliance requirements? Do it yourself Some third-party assistance Mostly third-party assistance

Compliance Management Options Do it yourself How to do it: Understand aspects of compliance management Develop own program Pros: Little cost (if compliance is maintained) Cons: Requires time investment, discipline, organization, welltrained employees

Compliance Management Options Some third-party assistance How to do it: Different vendors for managing different aspects: testing contractor, maintenance contractor, release detection Pros: Can pick and choose which aspects need most assistance Cons: Multiple parties involved, possible communication issues, more costly than DIY

Compliance Management Options Mostly third-party assistance How to do it: Use one vendor to assist with all aspects: Maintain equipment inventory Track, renew, maintain permits, pay required fees Scope, dispatch, maintain required tests and inspections Manage and/or perform release detection Document storage (recordkeeping) NOV resolution Regulatory guidance Owner still maintains responsibility

Compliance Management Options Mostly third-party assistance (continued) Pros: Higher level of compliance, fewer parties involved, all info in one place, requires less involvement and time investment by owner/operator Cons: More costly than DIY

Consequences of Non-Compliance

Conclusion Determine best approach Understand what is required Achieve and maintain compliance

Thank You Contact info: Eclipse, a Division of ECS, Inc. Megan Kazmierczak, Manager of Compliance Services 614-433-0170 or 888-302-4875 mkazmierczak@ecseclipse.com www.ecseclipse.com