Flow-through process USTs 2

[vollEngineer]

I would like to know the rationale behind exempting flow-through process USTs from UST regulation. I'm not for or against it - just would like to know what the reasoning is. Anyone have a clue?

 

[jdonville]

vollEngineer,

I can't say with any authority, but my best guess would be that a flow-through process UST might be considered not so much as storage but rather more like a pipe, reactor or conduit.

Jeff


Jeffrey T. Donville, PE
TTL Associates, Inc.

http://www.ttlassoc.com

 

[bimr]

As defined under EPA Resource Conservation and Recovery Act, any solid, semi-solid, liquid, or contained gaseous materials discarded from industrial, commercial, mining, or agricultural operations, and from community activities. Solid waste includes garbage, construction debris, commercial refuse, sludge from water supply or waste treatment plants or air pollution control facilities, and other discarded materials.

The key word is discarded. In general, EPA is set up to only regulate waste materials, not products, such as turpentine, etc. So if the processing tank is used to make a product it would not be regulated.

Also, if there was no breakpoint between a product and a solid waste, then you would conceivably regulate the entire refinery from the back end. You would start from the effluent and then continue upstream to the crude oil input to the refinery.

"Processing" means chemical or physical operations designed to produce from used oil, or to make used oil more amenable for production of, fuel oils, lubricants, or other used oil-derived product. Processing includes, but is not limited to the following: blending used oil with virgin petroleum products, blending used oils to meet the fuel specification, filtration, simple distillation, chemical or physical separation, and re-refining.

So the answer is that as long as you are getting some kind of product out of the processing tank, it would not be regulated.

 

[vollEngineer]

Thank you for your thoughts. The tank in question is not in the middle of a process, in my opinion, so I'll have to keep an eye on what happens. Have a great day!