Dear PEI Member:
The U.S. Environmental Protection Agency (EPA) has finalized amendments to
its Spill Prevention, Control and Countermeasure (SPCC) rules. The
amendments are meant to clarify some regulatory requirements, tailor
requirements to specific industry sectors, and streamline certain
requirements for regulated facility owners. Regulated facilities must
develop and implement SPCC plans that establish procedures and meet equipment
requirements to help prevent oil discharges from reaching navigable waters
or adjoining shorelines.
EPA finalized some changes in its November 2008 amendments that are
important to aboveground tank owners as well as PEI members who prepare SPCC plans
and supply equipment and services for these owners.
- Home heating oil tanks exempt. The amendments exempt
residential heating oil containers (i.e., those used solely at
single-family residences) from SPCC regulations.
- "Loading rack" defined. Tank car and tank truck
loading/unloading racks are subject to specific requirements, including
sized secondary containment. Since sized secondary containment requires
equipment sufficient to contain a release from the single largest
compartment of the cargo tank vehicle, the area described in the
definition of loading rack is critical. Section 112.2 defines loading rack
this way: "A fixed structure (such as a platform, gangway) necessary for
loading or unloading a tank truck or tank car, which is located at a
facility subject to the requirements of this part. A loading/unloading
rack includes a loading or unloading arm and may include any combination
of the following: pipe assemblages, valves, pumps, shut-off devices,
overfill sensors, or personnel safety devices."
- Other loading rack issues. Loading racks attached to
underground storage tanks exempt from the SPCC rule are regulated under
these amendments and must be equipped with sized secondary containment.
Exempted underground storage tanks, at an otherwise regulated SPCC
facility, equipped with a transfer area (for example, dispenser or other
transfer equipment) must meet the general secondary containment
requirements of Section 112.7(c). That section provides many options to
contain spills or releases from that equipment and are less onerous than
sized secondary containment.
EPA Amends SPCC
Stage II Action
RP200 Revised and
Service and Construction Manager's
St. Louis, MO
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- Security. EPA modified existing language to allow the tank
owner or operator to design the security arrangements at the facility to
address the unique, specific geographical/spatial factors that apply. The
more prescriptive fencing and other security requirements mandated in the
past have been
eliminated. Instead, the owner or operator will describe in the SPCC plan
"how he will secure and control access to all oil handling, processing and
storage areas; secure master flow and drain valves; prevent unauthorized
access to starter controls on oil pumps; secure out-of-service and
loading/unloading connections of oil pipelines; and address the
appropriateness of security lighting to prevent acts of vandalism and
assist in the discovery of oil discharges." EPA believes this will
eliminate the need for PE-certified environmentally equivalent
alternatives to the specified security requirements.
- Bulk plants under 10,000 gallons. Under the new language, in
lieu of preparing a full SPCC plan that is PE- or self-certified, an owner
or operator of a Tier I qualified facility will have the option to
complete a new SPCC plan template found in the rule. Tier I facilities are
defined as having a facility under 10,000 gallons of aggregate capacity
with no single storage tank greater than 5,000 gallons. A Tier II
qualified facility has an aggregate aboveground oil storage capacity of
10,000 gallons or less but has a storage tank capable of storing over
5,000 gallons. While owners and operators of Tier II facilities are still
permitted to draft, revise and self-certify their own SPCC plans, any
deviation from the SPCC requirements must be PE-certified.
- Tank integrity testing. The bulk storage container testing
requirements were amended to provide more flexibility to all facilities
subject to the integrity testing provision. Specifically, EPA will now
allow an owner or operator to consult and rely on industry standards to
determine the appropriate qualifications for tank inspectors/testing
personnel and the type and frequency of integrity testing required for a
particular container size and configuration. Where an alternative
integrity testing procedure is used that is not a recognized industry
standard, a PE would need to certify the reason for the deviation and that
the alternative measures are environmentally equivalent.
- Proposed SPCC compliance deadline. In a proposed rule announced
the same day, EPA proposed to extend the SPCC deadline for revising and
implementing SPCC plans from July 1, 2009, to November 30, 2009.
- Effective date. The regulations are effective 60 days after
publication in the Federal Register, which has not yet occurred.
Pre-publication copies of the 276-page rule, together with the proposed
compliance deadline proposal and fact sheets on the changes, are available
PETROLEUM MARKETERS ASK EPA TO ACT ON STAGE II VAPOR RECOVERY
Four trade associations representing petroleum marketers in the United
States have formally asked the Environmental Protection Agency (EPA) to
release its findings on Onboard Refueling Vapor Recovery (ORVR) technology.
When Congress passed the Clean Air Amendments in 1990, it permitted EPA
to remove Stage II requirements when onboard canisters on motor vehicles are
in "widespread use." Until EPA determines a definition for widespread use,
however, states are unable to develop a plan to phase out Stage II vapor
recovery. A copy of the letter from the trade associations to EPA is
PEI'S RECOMMENDED PRACTICE ON AST INSTALLATION REVISED
Numerous changes have been made to the text and drawings of PEI's
Recommended Practices for Installation of Aboveground Storage Systems for
Motor-Vehicle Fueling (PEI/RP200), which is now available for purchase from
PEI. The 2008 edition supercedes and replaces the 2003 edition of RP200,
which was written and revised in response to the environmental
considerations and emerging technology that prompted the industry to use
aboveground tanks to store motor-vehicle fuel.
The 41-page manual provides a concise reference to preferred practices
and procedures for the installation of aboveground storage tank systems at
service stations, marinas and other fueling sites. The recommended practice
contains chapters and drawings on all phases of proper tank installation,
including site planning; foundations, supports and anchorage; dikes; vaults
and special enclosures; tanks; pumps and valves; fills, gauges and vents;
piping and fittings; corrosion protection; environmental protection;
electrical installation; testing and inspection; and documentation,
maintenance and training. Three appendices describe size calculations for
dikes, venting sizing, and fire code requirements. An appendix of documents used for
reference is also included.
The single-copy price for RP200/08 is $40 for members; $95 for
nonmembers. You can place an order online or download an order form at
www.pei.org/shopping. You can also
request an order form from PEI by calling 918-494-9696 or faxing
EPA STILL WRESTLING WITH ETHANOL BLENDS HIGHER THAN E10
Margo Oge, director of EPA's Office of Transportation & Air Quality,
told an audience at the Carbon Market Insight Americas conference on
November 13 that the agency will consider allowing ethanol to be blended in
conventional gasoline in levels up to 20 percent (E20), provided that it not
present "unintended consequences of impacting the environment or impacting
vehicles." It is widely understood that EPA is under pressure to find more
uses for ethanol, given the 2007 energy law's ever-increasing renewable fuel
mandates and the fact that the industry will hit an E10 "blend wall" as soon
as 2010. PEI has gone on record with EPA stating the agency should consider
the effect E20 has on new and existing petroleum marketing equipment before
allowing an ethanol blend higher than 10 percent (E10).
PEI MEMBER NEWS
LSI Industries Inc., Cincinnati, Ohio, has announced that
Walsh, Long & Company, Inc., Naperville, Illinois, will represent LSI in
northern Illinois, North Dakota, South Dakota, Wisconsin and Minnesota.
Samson Corporation, Swannanoa, North Carolina, has named Philip J.
Parker president of the company. The announcement was made by Alberto
Moratiel, chairman of the board of Samson and chairman of Samson's corporate
parent, Samoa Group, headquartered in Gijon, Spain.
DOE STUDY ON E15 and E20 RELEASED
In summer 2007, the Department of Energy (DOE) initiated a test program to
assess the potential impacts of intermediate ethanol blends on legacy
vehicles (non-flexible-fuel vehicles) as well as other engines that rely on
gasoline. The latter include small engine non-road engines such as those
used in lawn and garden equipment and engines for marine applications,
motorcycles, and snowmobiles.
DOE's test program focuses specifically on the effects of E15 and E20,
but considers both E0 (gasoline) and E10 as baseline fuels. Through a wide
range of experimental activities, DOE is evaluating the effects of these
intermediate ethanol blends on the emissions (both tailpipe and
evaporative), catalyst and engine durability, vehicle driveability or engine
operability, and vehicle and engine materials compatibility.
DOE has issued a
which provides the results available to date from the first stages of the
much larger overall test program. The purpose of the initial study was to
quickly investigate the effect of adding up to 20 percent ethanol to gasoline.
Thirteen vehicles were included in the study. According to DOE, tailpipe
emissions were not effected by the ethanol and catalyst temperatures under
closed-loop operating conditions were cooler or unchanged with higher levels
of ethanol. Six of the tested thirteen vehicles had somewhat higher catalyst
temperatures when run at wide-open throttle. No operability or driveability
issues were identified.
US OIL DEMAND AT 12-YEAR LOW
The U.S. Energy Information Administration (EIA) said that September oil
demand figures were just 17.8 million barrels per day (b/d). That is down
2.6 million b/d, or 13 percent, compared to the same month last year. The
September number is the lowest monthly demand reading since September 1996,
while the year-on-year percentage decline is the biggest since 1980.
ALTERNATIVE FUEL NOTES
An interagency panel that includes EPA is crafting a plan to
research the environmental effects of cellulosic ethanol, a
second-generation renewable fuel that has so far garnered less scrutiny than
the more-controversial corn ethanol.--INSIDE EPA, November 7, 2008.
The cities of San Francisco, Oakland and San Jose have teamed with
Palo Alto-based Better Place to install electric vehicle recharging stations
in homes, businesses, parking lots and government buildings by 2012. Better
Place would own the batteries in the electric vehicles and charge drivers a
subscription fee to use its recharging facilities.--The Mercury News,
November 20, 2008.
INTERESTED IN ATTENDING A PEI-SPONSORED DEF CONFERENCE?
PEI is considering sponsoring a one-day conference on diesel exhaust fluid
(DEF) for PEI members and their customers (see November 24, 2008 TL). If you
would be interested in either attending, presenting and/or exhibiting at
such a conference, please respond to
this survey. PEI staff will decide this
month whether or not to hold a DEF Conference in 2009.
John Robison, former chairman of the National Fire Protection
Association's Technical Committee on Automotive and Marine Service Stations
(NFPA 30A), died suddenly November 22. He was 63. Robison served as Alabama
State Fire Marshal for 15 years before his retirement in 2003. Survivors
include his wife, Jamie, and three children.
Texas environmental services firm. Accent Environmental Services
Inc., 523 FM 1819, Pollok, Texas 75969, has applied for affiliate division
membership. Danny Brevard is president of the company, which was established
in 1983. Accent provides UST and AST recordkeeping and consultation. Sponsored
for PEI membership by Thomas K. Bagby, Bagby, Pinson, AL.
Wisconsin compliance testing firm. Compliance Testing and Technology,
Inc., N106 W13131, Suite 600, Germantown, Wisconsin 53022, has applied for
membership in PEI's service and construction division. Greg Goeks is
operations manager for the firm, which was established in 2007. The company
provides site inspections, tank tightness testing, secondary containment
testing, and Stage II vapor recovery testing. Sponsored for PEI membership
by Glen Corkill, SourceIL, Arlington Heights, IL.