October 23, 2023 [BIC Magazine]- As someone who has been dealing with aboveground storage tanks (ASTs) for over 35 years, I have seen drastic regulatory changes over that time.
In 1988 when I started on a Department of Transportation regulated pipeline, which is now Pipeline and Hazardous Materials Safety Administration (PHMSA), the only thing we had to do was to inspect a tank once per year; no one even told us what inspection was required. There were standards for emissions, or Kb standards, and some state emissions regulations, but even these were relatively simple. My, how things have changed.
Since then, we now have PHMSA mandating breakout tank owner/operators to follow API 653 (1999) for inspection and repairs. EPA Spill Prevention, Control and Countermeasure (SPCC) rules require owner/operators of tanks containing “oil” to either follow API 653, STI or have a professional engineer in the state write their own plan (2002) — as well as many more state and federal regulations on emissions. Many states have passed their own sets of regulations, including Pennsylvania, Florida, North Carolina and Wisconsin, to name a few.
Recently, EPA completed a soon-to-bepublished update to the Gasoline Distribution MACT and GACT, NSPS Subpart XX, Major Source Bulk Gasoline NESHAP Subpart R, NESHAP Subpart BBBBBB — even the titles and subjects are a mouthful. EPA has also just announced plans to update Kb tank regulations to Kc; and Texas just passed SB 900 that will impact around 36,000 currently unregulated tanks. How is an owner/operator supposed to keep up?
One way is to read the Federal Register and scour the internet every day for new and changing state regulations. This normally is reserved for larger organizations and is often spread among several people. Doesn’t sound like much fun to me.
Another choice is to hire a high-priced consultant to tell you what you need to know. This option works if you have the right consultant and they have a sufficiently large and experienced staff to handle all the variations.
Another option is to participate in industry associations and attend conferences and trade shows. In my not-so-humble opinion, this is not only the most cost-effective option, but also the most fun and rewarding. I attended my first conference in 1992 and was fortunate enough to speak for the first time in 1993; I wasn’t very good or knowledgeable at that time. Some might argue that I’m not much better now, but I’ll leave that to your discretion.
One of the conferences that covers tank issues, not just regulatory ones, is the National Institute for Storage Tank Management (NISTM). Founded in 1989, NISTM provides educational opportunities, resources and training seminars about the operation, regulation and management of AST and underground storage tank systems. There are several things that make NISTM unique.
One is that NISTM has a multitrack conference that runs simultaneously with a trade show. This allows participants to hear from industry experts and regulators on current and upcoming issues as well as existing and proposed regulations. Before and after sessions and during breaks and lunch, attendees can visit the booths to find solutions to their existing issues and problems, look for new and cutting-edge technologies, make new acquaintances and catch up with old friends and former colleagues.
Another item that makes NISTM stand out is that it has two major conferences per year. The original — 25 years and counting — and largest is a three-day event in Orlando, Florida, typically held in April. Also included is a golf tournament, receptions to meet new people and see old friends, opportunities for additional training by EPA on SPCC and Facility Response Plans and various other dedicated training — it’s kind of a one-stop shop.
The second conference will be held in early December in The Woodlands, Texas, just north of Houston. This 15-year-old conference is smaller and is held over two days. A golf tournament, receptions and various other dedicated training are still available. One advantage for people in the Houston area is that it’s close enough to participate without having to travel out of town.
Of the three choices above, I know what I chose in the past and the one I still choose today. I hope to see you in The Woodlands in December.
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