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July 1999, Volume 2.1
The Bottom Line, Newsletter

Well December 22, 1998 has come and gone. According to the EPA's estimates only 56% of the UST's operating in the US are in compliance. But the enforcement that the industry expected has become selective. On December 9, 1998, the EPA announced that for the first six months following the deadline, enforcement would concentrate their efforts on federal facilities, operators with multiple UST's and those sites with tanks that could endanger the ecosystem or drinking water.

In response to the confusion, petroleum industry groups have formed a coalition consisting of PMAA, the National Association of Convenience stores (NACS), Service Station Dealers of America (SSDA), Society of Independent Gasoline Dealers (SIGMA), the Steel Tank Institute (STI), American Methanol Institute (AMI), and Oxygenated Fuels Association (OFA). The coalition made an announcement that they will "support consistent and stringent enforcement" of the tank regulations and will work with the states to encourage fair enforcement.

The EPA released a new statement in the end of January stating it did not extend the Dec. 22, 1998 deadline. It also made clear that violations were subject to state enforcement and they should therefore contact their state agencies and self-disclose prior to Feb.12.

Most states agree, if your tank has not been upgraded, then non-compliant tanks should be temporarily closed until the upgrade can take place. This is the best way to avoid fines.

How do you measure up?
Getting in compliance was one thing, staying in compliance is another. Everyone's focus for the last year has been upgrading and replacing. Now that this is done you need to put in place mechanisms to prevent a release.

To be effective these leak detection preventatives must be maintained and operated on an ongoing basis.

  • Pressurized Piping Systems and UST's
    It is required that an annual test is run to insure that automatic line-leak detectors are operational and annual tightness testing or monthly monitoring is performed on the UST. Depending on the state, monthly monitoring can be interstitial monitoring, automatic in-tank gauging, vapor or ground water monitoring or SIR (Statistical Inventory Reconciliation).
  • Cathodic Protection
    Must be tested six months after installation as well as every three years after that. Systems that have been upgraded with impressed current systems must be inspected every 60 days except Connecticut where it is every 30 days. The amp and volt readings must be recorded and kept at the location.
  • Interior lined tanks
    These tanks must be inspected ten years after installation and every five years after that.
  • Suction Piping
    Must be tested every three years if not equipped with monthly monitoring.
Additional things to keep in mind are:
API coloring codes- is the appropriate color on the correct product? Is the color faded or worn?
  • Alarms ­ Are all alarms in working condition? Are they visible, audible and placed in an area where immediate action can take place?
  • Signs ­ Are the appropriate signs in place to alert delivery people of certain conditions? Are the signs legible?
  • Spill Kits ­ Are they easily accessible? Do they need to be replaced or replenished?

Regulations
EPA Tank Office Looking for New Focus
It was generally assumed that once December 1998 date had passed and the EPA tank enforcement officials had accomplished their mission, the responsibility of tank enforcement would be turned over to the state agencies. Once this happened the EPA's Office of Underground Storage Tanks would be phased out. Well think again. Officials are now targeting nine new areas where they intend to focus their energies. These regulations will be targeting stricter AST compliance and monitoring the effectiveness of the UST leak detection regulations.

Other Regulatory Briefs

New Jersey
A bill (AB 2926/SB 1679) has been signed into law. This provides a grant to small business owners of obsolete metal USTs for up to 1/3 of the replacement cost. Prior to this bill, only ten percent of the costs were covered by grants.

California
The California Air Resources Board (CARB) is having a meeting June 24 to discuss a proposed regulation that would require the labeling of pumps that dispense gasoline containing MTBE throughout the state.

Wisconsin
EPA plans to approve the state's request for removal of Stage II vapor recovery. This was proposed as a contingency measure from the Kewaunee, Sheboygan and Walworth County ozone maintenance plans.

ES&H is constantly working with our customers to continue to find cost effective ways to get you and your customers in compliance.

Exploring new horizons
ES&H, is now offering the service of monitoring your cathodic protection remotely. In order to meet EPA requirements regarding cathodic protection you need to record the rectifier readings at each location every sixty days. In the state of Connecticut these readings need to be recorded every 30 days.

In order to meet this requirement many of our customers are outsourcing this to contractors who charge upwards of $150.00 per visit. ES&H has put together a program in which we gather these readings, send a report to the location and archive readings for considerably less money.

Coming up in the next issue of The Bottom Line...

  • Do your operators know proper inventory procedures?
  • Benefits of SIR in Marketing
  • Keeping up with new technologies




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