4436 North Brady Street, Davenport, Iowa 52806-4063

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                                mlp@prestonengineering.com

 

October 2002 Newsletter

USEPA REVISED OIL SPILL RULES

On July 17, 2002, the EPA modified the Oil Pollution Prevention Regulation (40 CFR part 112) which requires Spill Prevention, Control, and Counter-measures (SPCC) plans at many facilities that store or use oil. These regulations are intended to prevent discharges of oil from reaching surface waters, and to ensure effective responses to oil discharges.

SPCC plans are now required for facilities in which above ground containers have a total storage capacity of 1,320 gallons or greater. Oils such as vegetable oil or animal fats are included as well as petroleum products. Any container or storage reservoir with a capacity of 55 gallons or greater is counted toward the 1,320 gallon level. This could include 55 gallon barrels of oil, large equipment reservoirs of oil, above ground storage tanks and electrical equipment.

The SPCC rule requires updated plans by February 16, 2003. Measures required by the plan must be implemented by August 18, 2003. A professional engineer (PE) must certify that the plan has been prepared in accordance with good engineering practice, applicable industry standards, and the SPCC rule; that procedures for inspection and testing have been established; and that the plan is adequate for the facility. Administrative changes can be made without a PE review, but technical changes must be reviewed by a PE. Plans must be reviewed and updated every five years.

The SPCC rule requires secondary containment for storage tanks and around unloading operations. If secondary containment is shown to be impracticable, a facility may substitute a strong contingency plan for response and containment of releases. This plan must include a written commitment to quick control and removal of any harmful discharge of oil.

Exemptions to the rule include completely buried storage tanks, which are already subject to UST regulations in 40 CFR parts 280 and 281, oil storage containers less than 55 gallons, and wastewater treatment facilities.

PRESIDENT’S COLUMN

In December of last year the first major reorganization of Iowa DNR in fifteen years was announced. The new plan eliminated nine high level jobs for an annual savings of $500,000 in salaries. The plan also called for decentralization and increased customer service. All environmental functions were placed in the Environmental Protection Division under five bureaus – Water, Air, Geological Survey and Land, Field Services and Compliance, and Energy and Waste Management.

With the reorganization has come a passing of the guard. The Iowa Department of Environmental Quality was formed in 1972, and many of the senior staff that took retirement this last year had been with the department for 30 years or longer. Their expertise and dedication will be missed.

The new division administrator and bureau chiefs have been announced and represent a seasoned and experienced group. They have much environmental experience inside and outside of the Department. I look forward to working with them in the future.

In an effort to increase customer service, the department intends to move over 100 environmental jobs to the field offices. The director wanted to put more staff in direct contact with Iowans and environmental problems. This initiative appears to be moving slowly for a number of reasons. The department is reluctant to move existing employees to the field office because of relocation expenses and relocation hardships. Relatively inexperienced new hires will be placed in the field offices as vacancies occur. This is reminiscent of the influx of inexperienced staff when the Iowa Department of Environmental Quality was launched in 1972.

- Morris L. Preston, P.E. QEP

2001 QUAD CITY AREA ANNUAL AIR QUALITY

Preston Engineering, Inc. has compiled the 2001 Quad City Area Annual Air Quality Report. Data available from the eight operating monitors were compared to standards, known as the National Ambient Air Quality Standards. Pollutants that are currently monitored in the area are ozone, nitrogen dioxide, particulate matter, and sulfur dioxide. The air quality in the area is good, and the area has been and continues to be in attainment.

The Iowa Department of Natural Resources periodically issues news releases on air quality in the Quad City Area when the Air Quality Indexes have been exceeded. In 2001, there were no unhealthy ozone levels detected in the area, but particulate matter caused several days of unhealthy air for individuals with breathing difficulties. The vast majority of days in the area fall into the good to moderate categories. Additional details on the alert warnings and monitor locations can be retrieved on IDNR’s Air Quality Bureau web site at:

http://www.state.ia.us/epd/air/prof/emiss/files/new2001.pdf.

In 2000, minor industrial sources in Eastern Iowa were asked to complete emission inventory questionnaires (EIQ) as part of a statewide air quality survey by IDNR. Results from the QCA data showed that the largest contributor of volatile organic compounds and nitrogen oxide compounds was from transportation which is not regulated. Point or industrial sources, which are regulated, emitted less than 20% of the total volatile organic compound emissions.

The IDNR, in conjunction with the USEPA, conducted a special air toxics monitoring study in Davenport and four other Iowa metropolitan areas in 2001. The USEPA funds these special studies to identify potential air quality concerns. The study indicated that acetaldehyde, benzene, and formaldehyde levels were above the USEPA’s one per million cancer risk benchmark. The levels found in Davenport were similar to levels found in other Iowa cities. Benzene levels are generally attributed to evaporation of gasoline or incomplete combustion of gasoline. The other compounds are typically associated with combustion of various fuels.

These results will be considered by the USEPA in establishing future regulations for emission controls on internal combustion engines, formulation of gasoline, and distribution of gasoline.

For additional information about the QCA Air Quality Report, contact Jerry Tonneson at (563) 388-8288.

 

 

 

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