UST Training staff has been attending, organizing and presenting at this conference over the years since 1996 and this 2012 Conference was probably the best one yet.
Several dozen sessions, a great tradeshow, over 700 attendees, and an inspirational talk by the founder of the national UST program, Ron Brandt, showed us how much the UST profession has grown over the years into a mature regulatory program.
UST Operator Training was the subject of two sessions and mentioned in a several more, making it clear that the training deadline was on everyone’s mind. Ben Thomas presented at one session that was run as a mock debate among speakers and offered a national perspective on how to best ensure high quality training as a means of increasing operational compliance.
Phase separation, rusty pumps and fouled fuel quality issues continue to plague the UST world, and some excellent presentations showed the learning curve is still going up as we try to understand the extent of the problem and decide how to react as new fuels like E15 enter the market. EPA presented an interesting study that showed how tanks with E10, combined with vapor leaks into tight tank top sumps were more likely to have accelerated rust issues.
EPA is proposing some significant rule changes to 40 CFR 280, which, if adopted, should greatly improve the weaknesses found in the current body of rules. Many of the proposed changes have to do with better testing, maintaining and inspecting. The Petroleum Equipment Institute is currently developing a new recommended practice, RP 1200, Recommended Practices for the Testing and Verification of Spill, Overfill, Leak Detection and Secondary Containment Equipment at UST Facilities.
You can still download the proposed rule changes and make comments through April 14 by clicking here.
Perhaps the most attended session was Measuring Progress in the UST Program – What Can We Learn From 10 Years of UST System Testing Data?
Several speakers presented thousands of data points and here are the highlights (Thanks Marcel!):
- Overall performance of tanks and piping is good. Remember, however, that piping testing generally doesn’t include submersibles or dispensers.
- “As found” condition of containment sumps (STP and UDC) is not good; periodic testing improves tightness over time.
- Pressure decay testing (as a result of air rules) revealed tank top leaks are common; periodic testing improves tightness over time.
- USTs will leak as much as regulations let them.
- Testing data doesn’t tell the whole story – many leaks are visually observed (think dispensers and STPs) and repaired without benefit of tightness test.