7.3 Underground Storage Tanks and Waste Minimization

Underground storage tanks pose serious environmental risks if they leak. RCRA regulations aim to prevent and detect leaks through strict design, construction, and monitoring requirements for tanks storing petroleum or hazardous substances underground.

Waste minimization strategies reduce environmental impact by cutting waste at the source. This includes modifying processes, recycling materials, and implementing pollution prevention techniques to align with RCRA's goals of conserving resources and protecting human health.

Underground Storage Tanks (USTs)

Definition and Regulatory Framework

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• Underground storage tanks store petroleum or hazardous substances underground
• Leaking underground storage tanks (LUSTs) pose significant environmental and health risks
• UST regulations established by the Environmental Protection Agency (EPA) under RCRA
• Regulations apply to tanks with at least 10% of their volume underground
• Exempt tanks include farm and residential tanks under 1,100 gallons, heating oil tanks for on-site use

Tank Design and Construction Requirements

• Double-walled construction mandated for new USTs
• Corrosion-resistant materials (fiberglass-reinforced plastic, steel with cathodic protection)
• Spill prevention equipment includes overfill alarms and automatic shutoff devices
• Secondary containment systems catch leaks before they reach soil or groundwater
• Installation must be performed by certified professionals following industry standards

Leak Detection and Monitoring Systems

• Monthly monitoring required for all USTs
• Automatic tank gauging systems measure product levels and detect discrepancies
• Interstitial monitoring checks space between tank walls for leaks
• Vapor monitoring detects fuel vapors in soil around tanks
• Groundwater monitoring wells sample nearby water for contamination
• Statistical inventory reconciliation analyzes delivery and sales data for inconsistencies

Waste Minimization

Source Reduction Strategies

• Waste minimization reduces or eliminates waste at the source
• Process modifications optimize production to generate less waste (lean manufacturing)
• Input material changes substitute hazardous materials with safer alternatives
• Improved operating practices include better inventory management and spill prevention
• Technology advancements lead to more efficient, less wasteful equipment (3D printing)

Recycling and Reuse Techniques

• Recycling converts waste materials into new products (paper, plastics, metals)
• Closed-loop recycling reuses materials within the same production process
• Open-loop recycling repurposes materials for different applications
• Reuse extends the life of products through repair, refurbishment, or repurposing
• Industrial symbiosis exchanges waste materials between different industries as resources

Pollution Prevention Approaches

• Pollution prevention (P2) focuses on avoiding the creation of pollutants
• Life cycle assessment evaluates environmental impacts throughout a product's lifespan
• Green chemistry principles design safer, less toxic chemical processes
• Energy efficiency measures reduce emissions and resource consumption
• Water conservation techniques minimize wastewater generation and treatment needs
• Employee training programs promote waste reduction and environmental awareness