On April 13, 2000, the EPA announced an opportunity for the regulated community to participate in the Storage Tank Emission Reduction Partnership Program. Companies electing to participate in this program must submit a notice of intent by June 12, 2000, and an executed partnership agreement by December 11, 2000. The EPA solicited public comment on this proposed program on January 14, 2000 (see our February newsletter at

http://www.your-rcp.com/newsletters/uscgnewsfeb2000.htm. The more salient features of the Storage Tank Emission Reduction Partnership Program are summarized below:

• Each company intending to participate must notify EPA of its intent to participate within 60 days and there identify each facility it intends to include under this program, using its unique EPA Identification Number.
• Participating companies must assess all of their NSPS Subpart Ka/Kb external floating roof tanks with slotted guidepoles and are encouraged to assess all of their NSPS Subpart Ka/Kb internal floating roof tanks with slotted guidepoles.
• Acceptable slotted guidepole controls under this program are identified. Use of such controls does not affect other regulatory obligations that may exist under state or federal law (e.g., to sample tank contents for compliance with other regulatory programs).
• EPA is not requiring that penalties be paid as a condition of program participation, but if a participating company fails to implement its agreed-to controls in a timely manner, stipulated penalties would be imposed.
• The terms and conditions for program participation are specified in the participation agreement that each participant must execute.
• Each participating company must submit an executed participation agreement, including a complete Annex A, within 240 days. Annex A must provide a facility listing (using its EPA identification Number) that identifies its NSPS Subpart Ka/Kb external floating roof tanks with slotted guidepoles and those of its NSPS Subpart Ka/Kb internal floating roof tanks that it intends to include under this program. Annex A must also specify the controls that were or will be installed, as well as predict the emission reductions that will be achieved after these controls are installed.