ILTA provided input to EPA on a January 7 conference call on an agency plan to create a national alternative monitoring plan document for storage tanks regulated under 40 CFR Part 60 (Standards of Performance for New Stationary Sources), Subpart Kb. This effort was spurred by an increased number of source-specific AMPs being requested of the EPA regional offices and a desire by the agency to streamline the review and approval process.
EPA is considering a model AMP that, if adopted by an operator, could be approved under a streamlined review process. Some aspects of this model could include allowing in-service visual inspections of seals and gaskets and/or other alternative inspection practices. Further discussion with the agency is pending. For more information on this effort, you may contact Peter Lidiak at lidiakp@ilta.org.