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1988 UST Regulations vs. Proposed UST Regulations - UST Training

November 12, 2011

AREA PROPOSED REQUIREMENT, IMPLEMENTATION,
AND PREAMBLE LOCATION
OUR COMMENTS
Operator Training • Owners and operators designate at least one individual for each of three classes of operators. Designated operators must be trained on minimum defined areas and may need to be retrained if the UST system is not in compliance.• Owners and operators retain a list of designated operators trained at each facility and proof of training or retraining.• EPA adds definitions for Class A operator, Class B operator, Class C operator, and training program.

Implementation: phased in over three years based on tank installation date

• Good for states that don’t have rule yet.• Probably won’t have a big impact on most states with existing rules.

 

Secondary Containment •  Owners and operators install secondary containment and interstitial monitoring for all (including petroleum) new and replaced tanks and piping (except safe suction piping and piping associated with field-constructed tanks and airport hydrant systems). Owners and operators must replace the entire piping run when 50 percent or more of piping, excluding connectors, is removed and other piping is installed.• Owners and operators install under-dispenser containment for all new dispenser systems.• EPA adds definitions for dispenser system, replaced, secondary containment, and under-dispenser containment.

Implementation: immediately

• Most states already do this.• Won’t help Kansas and Missouri who don’t require new secondary containment in the first place.• Could use more emphasis on continuous monitoring.

 

Operation and Maintenance (O&M) •  Walkthrough inspections – owners and operators conduct monthly walkthrough inspections which look at: spill prevention equipment; sumps and dispenser cabinets; monitoring/observation wells; cathodic protection equipment; and release detection equipment•  Implementation: immediately•  Spill prevention equipment – owners and operators test annually for liquid tightness or use a double-walled spill bucket with continuous interstitial monitoring.

Implementation: within one year

• Monthly inspections are essential to maintaining a healthy UST system.• Leaking spill buckets should greatly be reduced. 
More Operation and Maintenance (O&M) •  Overfill prevention equipment – owners and operators test every three years to ensure equipment is set to activate at the appropriate level in the tank and will activate when regulated substances reach that height.•  Implementation: phased in over three years based on tank installation date•  Secondary containment areas – owners and operators test every three years to ensure the interstitial area has integrity or use specific continuous monitoring methods.

•  Implementation: phased in over three years based on tank installation date

•  Release detection equipment (including LLDs) – owners and operators test annually to ensure equipment is operating properly.

Implementation: within one year

• Testing overfill equipment should reduce overfills plus it is good O&M.• Secondary containment systems can leak over time and should be tested.• Annual functional testing of all leak detection equipment: we’ve been recommending
it for years.
Deferrals •  EPA removes deferral and requires owners and operators to perform release detection.Implementation: within one year •  Emergency power generator USTs can leak too:
test them!
Flow Restrictors In Vent Lines •  EPA eliminates flow restrictors in vent lines as an option for owners and operators to meet the overfill prevention equipment requirement for newly installed UST systems and when flow restrictors in vent lines are replaced.Implementation: immediately •  This will be consistent with current tank installation standards•  Ball float can cause overfills. Get them off the rule books.
Internal Lining •  Owners and operators permanently close tanks using internal lining as the sole method of corrosion protection, if the internal lining fails the periodic inspection and cannot be repaired according to a code of practice.Implementation: immediately •  About time this tanks were delisted as meeting cathodic protection requirements!
Compatibility •  Owners and operators demonstrate compatibility for UST systems storing greater than 10 percent ethanol or greater than 20 percent biodiesel, or any other regulated substance the implementing agency identifies, by one of these methods: listing by a nationally recognized independent testing laboratory; equipment or component manufacturer approval; or another method the implementing agency determines to be no less protective of human health and the environment than the other methods.•  Owners and operators maintain compatibility records for the life of the equipment or component for all new or replaced equipment and for UST systems storing greater than 10 percent ethanol or greater than 20 percent biodiesel.•  EPA removes references to two codes of practice.

•  EPA revises definitions of motor fuel and regulated substance.

Implementation: immediately

•  We have a ways to go before we have all UST systems be compatible with modern fuels but this is a start.•  We’d like to see all third party certifications for ATGs and ALLDs ensure they are compatible with E10.
Repairs •  EPA revises definition to remove the link that a repair must be associated with a release and adds examples of other UST system components that can be repaired.•  Owners and operators test within 30 days after a repair to spill or overfill equipment and secondary containment areas. •  This is an old gripe of ours: that repair means fixing a leak versus preventing one. We like this broader interpretation.
Vapor andGroundwaterMonitoring •  EPA phases out vapor and groundwater monitoring as release detection options for owners and operators.Implementation: within five years •  Finally we can delete these slides from our operator training slides and quit grousing about how ineffective and dangerous these methods are.
InterstitialMonitoringResults •  EPA adds interstitial monitoring alarms as an example of an unusual operating condition under release reporting.•  EPA adds interstitial integrity testing for secondarily contained tanks and piping using interstitial monitoring for the system test under release investigation and confirmation.•  EPA adds closure as an option if a system test confirms a leak.

 

Implementation: immediately

 

•  Since double-walled is required in most states now for new systems, this alarm should be added.
NewerTechnologies •  EPA adds newer technologies: clad and jacketed tanks, non-corrodible piping, continuous in-tank leak detection, and statistical inventory reconciliation. •  Maybe they could go a bit further require flexible plastic piping to meet non-corrodible standards as well.

For more information go to: http://epa.gov/oust/fedlaws/proposedregs.html

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