Underground Storange Tank Systems

An underground storage tank (UST) system is a tank, and any underground piping connected to the tank, that has at least 10 percent of its combined volume underground. Federal UST regulations apply only to underground tanks and piping storing either petroleum or certain hazardous substances. Fleet service centers often have fuel dispensing equipment that store fuel in USTs.

When a fleet service center has applicable USTs, several requirements must be met, including operator training, periodic inspection and maintenance, cathodic protection, etc.

Regulatory citations:

• 40 CFR parts 280, 281, and 282

Related Compliance Network subjects:

• Tank Systems (SMS topic: UST)

Aboveground Storage Tank Systems

A fleet service center that stores fuels or other hazardous substances in aboveground storage tanks (ASTs) has a variety of regulatory requirements that may apply to the facility, depending on the type of tank, material being stored in the AST, and volume of material. ASTs are regulated at the federal level in a somewhat piecemeal way. Consequently, it is necessary to look in several different places for AST requirements:

• The storage of hazardous waste in ASTs is covered in 40 CFR part 112.
• OSHA requirements, in 29 CFR 1910.106, address ASTs that contain flammable or combustible liquids. The rules apply to liquids with flashpoints below 200°F.
• Storage of petroleum products (oils and fuels) in an AST, may be regulated under the Spill Prevention, Control and Countermeasure (SPCC) regulation, covered in the next section.

Additionally, most AST regulations are found at the state and local level. Check with your state and local agencies to see if there are more stringent AST requirements that you need to know about.

Regulatory citations:

• 40 CFR Part 112
• 29 CFR 1910.106

Related Compliance Network subjects:

• Tank Systems (SMS topic: Tank systems)

Spill Prevention Control & Countermeasure

Fleet service centers with large fuel storage tanks likely trigger the Spill Prevention Control & Countermeasure (SPCC) rule. SPCC applies to those fleet service centers that have a total aggregate petroleum product storage capacity of greater than 1,320 gallons in aboveground containers 55 gallons or greater or storage in completely buried storage tanks greater than 42,000 gallons in containers 55 gallons or greater. Last, SPCC applies to any facility that could be reasonably expected to discharge oil in quantities that may be harmful into navigable waters or adjoining shorelines.

If SPCC applies to an organization, then several requirements specific to the SPCC rule must be met. Including preparation an SPCC Plan, conducting annual trainings, routine audits, and more.

Regulatory citation(s):

• 40 CFR 112

Related Compliance Network subjects:

• Oil Spill Prevention

Emergency Planning and Community Right-to-Know Act

Emergency Planning and Community Right-to-Know Act (EPCRA) was first written to reduce the likelihood of chemical related disasters in the U.S. The Community Right-to-Know provisions of EPCRA, increase the public access to information about chemicals in their community. EPCRA has five major provisions, all of which could apply to a fleet service center, but the most common overlap is found in the hazardous chemical storage reporting requirements (also known as Tier II).

The Tier II section of EPCRA requires facilities handling or storing any hazardous chemicals in an amount equal to or greater than their threshold levels to file an inventory report. EPCRA does not have a chemical list, rather it covers all hazardous chemicals, means any hazardous chemical as defined by OSHA, with some extremely hazardous substances having lower reporting thresholds.

Fleet service centers often trigger EPCRA Tier II reporting for hazardous chemicals including sulfuric acid, found in large lead acid batteries used in vehicles, vehicle fuel, and hydraulic fluids.

Regulatory citation(s):

• 40 CFR 350
• 40 CFR 355
• 40 CFR 370
• 40 CFR 372
• 40 CFR 355 Appendix A
• 40 CFR 355 Appendix B
• 29CFR 1910.1200(c)

Related Compliance Network subjects:

• CERCLA, SARA, EPCRA
• Hazardous Materials Table

Water Programs

Fleet service centers that clean transportation equipment may be subject to the Transportation Equipment Cleaning (TEC) Effluent Guidelines and Standards. The regulation covers discharges from the interior cleaning of tank containers on trucks, rail cars, barges and ships, sent directly to surface waters or publicly owned treatment works (POTWs). Additionally, cleaning of tank interiors solely for the purpose of repair and maintenance is covered a separate section of the effluent guidelines (40 CFR Part 438).

Regulatory citation(s):

• 40 CFR Part 442
• 40 CFR Part 438

Related Compliance Network subjects:

• Water Programs

Waste Generation and Disposal

Due to the nature of fleet service centers, being a combination of office and vehicle maintenance activities, these businesses generate a variety of regulated wastes. These commonly include waste solvent rags, fluorescent light tubes, batteries, electronics, and more.

Solvent contaminated industrial rags used to clean up parts, equipment, or small spills, that are contaminated with certain solvents and managed according to the specific exclusions in 40 CFR 261.4. This management includes storing rags in closed, non-leaking containers, labeling containers, removing free liquids, send wipes off-site within 180 days, and recordkeeping requirements.

Federal regulations identify five specific categories of materials that can be managed as universal wastes: batteries, pesticides, mercury-containing equipment, lamps, and non-empty aerosol cans. Universal wastes must be stored universal wastes in appropriate containers, be collected in containers labeled with the words “Universal Waste,” and the type of universal waste (e.g., waste batteries, waste lamps), be shipped offsite within one year.

Regulatory citation(s):

• 40 CFR 261.4
• 40 CFR 273

Related Compliance Network subjects:

• Waste (SMS topics: universal waste, waste rags, special waste)

Air Programs

The operation of fleet service centers can trigger several air related regulations and reporting. The first of these regulations covers refrigeration system repair and maintenance, including sections that cover stationary systems and those systems in motor vehicles. These regulations include requirements for technician training, system inspection and repair, and reporting.

In addition, a variety of area source (or minor source) National Emissions Standards for Hazardous Air Pollutants (NESHAPs) can apply to fleet service centers, depending on the equipment and activities at the location. These include:

• Gasoline Distribution, Gasoline Dispensing Facilities (subpart CCCCCC)
• Reciprocating internal combustion engines (subpart ZZZZ)
• Plating and Polishing Operations (subpart WWWWWW)

Last, some state and local agencies have minor source programs that apply to activities at fleet service centers.

Regulatory citations:

• 40 CFR 82
• 40 CFR 63

Related Compliance Network subjects:

• Air programs (SMS topic: ozone depleting substances, air permits, air emissions)