The costs of complying with the new rule on underground storage tanks won't be nearly as onerous for service stations and others in the aftermarket sector as once thought. The Environmental Protection Agency eased some of the mandates it had proposed back in late 2011 when it finally published a final rule in mid-July. Five years in the making, the rule adds maintenance and inspection requirements to equipment requirements for underground storage tanks (USTs) first established in 1988.
Underground storage tanks
holding petroleum and motor oil are ubiquitous in the automotive service
station sector. The changes the EPA made
to the final rule resulted in much lower compliance costs for service stations,
who, according to Bob Renkes, Executive Vice President
& General Counsel, Petroleum Equipment Institute, account for
about 360,000 of the 560,000 tanks that currently exist.
The Petroleum Marketers
Association of America (PMAA) estimated the proposed rule would have cost
upwards of $6000 per site. Mark Morgan, Regulatory Counsel to the PMAA, says
the burden is now estimated to be $2377 per site.
Kirk McCauley, Director of
Member Relations and Government Affairs WMDA Service Station &
Automotive Repair Association, states the final rule is "not as bad as I
expected." His group had a number of problems with the proposed rule after
it was published in 2011. "Not having to check containment sumps
monthly will save a lot of backs; some covers are in the 200 pound class,"
he notes. They will have to be visually checked once a year.
And the elimination of
interstitial space testing on storage tanks' underground piping and sumps is
the right decision," adds McCauley. That would have been a major problem,
and cost, for service stations with old tanks with secondary containment. The
owners would have had to break through concrete or asphalt to get to the
interstitial opening in order to do the test.
A lot of what is in this
regulation is already standard practice. Overall I think it will cause some
heart burn but not as bad as the industry was expecting," notes McCauley.
But the PMAA's Morgan
adds, "However, we believe that testing requirements for sumps under
the final rule would be very costly and burdensome. We are seeking clarification
from EPA and will then reassess." The initial rule was established in
1988. It set standards for spill, overfill, corrosion protection, and release
detection. But there are still approximately 6,000 releases each year.
The EPA says lack of proper operation and maintenance of UST systems is the
main cause of new releases. For example, EPA required spill prevention
equipment to capture drips and spills when the delivery hose is disconnected
from the fill pipe, but did not require periodic testing of that equipment.”
The final rule doesn't
require anyone to install new equipment, or for service stations (or others)
buying new USTs to purchase tanks with newer, more expensive features. The rule
is all about inspecting and testing equipment that was specified in the
1988 rule. The implementation date for most of the new requirements is three
years hence.
The inspection
requirements are not expected to be onerous. Some of the testing requirements
could be costly, though, especially for service stations and gasoline retail
locations which don't have the expertise to do the testing. They will hire
outside contractors, according to Wayne Geyer, Executive Vice President, the
Steel Tank Institute.
The new testing requirements include testing of spill prevention equipment (using vacuum, pressure, or liquid methods) every three years unless the equipment is double-wall spill prevention equipment and both walls are periodically monitored for integrity. Integrity monitoring must be performed at least once every 30 days. The rule includes a three-year testing requirement for containment sumps used for interstitial monitoring of piping unless the containment sumps are double wall and the integrity of the walls is periodically monitored. Integrity monitoring must be performed at least once every 30 days. The rule also requires annual operation and maintenance tests on electronic and mechanical components of release detection equipment to ensure they are operating properly. This includes automatic tank gauge systems and other controllers, probes and sensors, automatic line leak detectors, vacuum pumps and pressure gauges, and handheld electronic sampling equipment associated with vapor and groundwater monitoring.
Author bio:
Mr. Barlas, a freelance writer based in Washington, D.C., covers topics inside the Beltway.
The new testing requirements include testing of spill prevention equipment (using vacuum, pressure, or liquid methods) every three years unless the equipment is double-wall spill prevention equipment and both walls are periodically monitored for integrity. Integrity monitoring must be performed at least once every 30 days. The rule includes a three-year testing requirement for containment sumps used for interstitial monitoring of piping unless the containment sumps are double wall and the integrity of the walls is periodically monitored. Integrity monitoring must be performed at least once every 30 days. The rule also requires annual operation and maintenance tests on electronic and mechanical components of release detection equipment to ensure they are operating properly. This includes automatic tank gauge systems and other controllers, probes and sensors, automatic line leak detectors, vacuum pumps and pressure gauges, and handheld electronic sampling equipment associated with vapor and groundwater monitoring.
Author bio:
Mr. Barlas, a freelance writer based in Washington, D.C., covers topics inside the Beltway.
