Sheldon Schall

1
The Wisconsin Initiative to Regulate Hazardous
Substance Storage tanks
Sheldon Schall Bureau of Storage Tank
Regulation Division of Environmental and
Regulatory Services
2

• Effort to incorporate CERCLA hazardous substances
  into storage tank rule began in 1989.
• Initiating factor was the EPA UST rules
• Failure to incorporate authority violated EPA UST
  rule.
• Statute change fall 1999 designating authority to
  regulate ASTs and USTs
• No national standards to associate technical
  requirements.
• Code revision discussion beginning June 2000.
• Subcommittee addressing Haz Sub storage has
  industry lead (WI Paper Council).
• Current subcommittee proposals or direction are
  very objective and safety oriented.
• Subcommittee represented with considerable
  industry experience.

3

• Trends
• Movement away from barrels and drums to reduce
  barrel handling, disposal and off-loading
  accidents.
• Movement to totes and tanks in vaults.
• Stacked totes with lower tote in semi-permanent
  placement.

4

• Challenges
• No existing standards.
• Wide range of chemical characteristics.
• Determine regulated concentration.
• Non traditional tank design and configuration.
• Most WI business using bulk storage are older
  facilities.
• Frequent change from one chemical to another.
• Variation in interpretation of terminology.
• Agreeing on capacity thresholds.
• Containment requirements.
• Tank and pipe life expectations.
• Retroactive or grandfather status.
• Out-of-service tanks.

5

• Primary topical code development areas
• Containment
• Maintaining storage system integrity and
  rectifying storage vessel.
• Qualifying designer and installer.
• Maintain continuity with or parallel to existing
  federal regulations (e.g., SPCC).