“Following the Great Molasses Flood in Boston’s North End on January 15, 1919, Massachusetts began regulating aboveground storage tanks (AST’s) greater than 10,000 gallons storing any fluid other than water. The molasses flood killed 21 people and injured 150 more. Many claim you can still smell the molasses in the North End on hot summer days.” – MA Department of Fire Services Website (http://www.mass.gov/eopss/agencies/dfs/osfm/fire-prev/aboveground-storage-tanks.html)
It is amazing how time flies when it comes to complying with the 2015 Federal Underground Storage Tank (UST) rule promulgated by 40 CFR Part 280. We outlined key provisions for you in this 2015 blog post. If you recall, the EPA established a three-year compliance window for many of the provisions that apply to your underground tank operation, such as containment testing, release detection monitoring, and overfill prevention.
I recently had the opportunity to attend the annual meeting of the Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”). ASTSWMO, to those unfamiliar with the organization, was established in 1974 to enhance and promote effective state and territorial environmental programs. The annual meeting afforded me a great opportunity to hear and see the perspectives from regulators and industry experts on current issues affecting the use and operation of underground storage tanks (“USTs”). While these issues are not necessarily new, hearing about firsthand experiences truly helps to put things into perspective. Two sessions in particular did just that for me.
What are the Requirements for Storage Tank Records?
There are an estimated half million underground storage tanks (USTs) in the US today, with most utilized to store petroleum, petroleum derivatives, or other potentially hazardous substances. Owners of storage tanks are subject to strict controls on adding, moving, and shutting down storage tanks. There are also records required for regular inspections, reporting of leak detection, testing processes, and more.
What is a Storage Tank Compliance Program?
Companies that utilize underground storage tanks (USTs) are subject to regulations by local, state, and especially federal regulations and controls. Requirements for prevention and detection of leakage from such containment tanks are intended to prevent ground and water contamination by hazardous chemicals and petroleum-based products.
If you think you are covered under the Massachusetts Underground Storage Tank Cleanup Fund, you may want to think again.
As of April 11, 2016, new or replacement underground storage tanks (USTs) must have secondary containment in order to be compliant with U.S. Environmental Protection Agency (EPA) regulations. If UST operators who have had new tanks and pipes installed in the last few years have followed best practices, their installations probably meet with the EPA’s new standards of UST environmental compliance. It is important to be aware, however, that simply having secondary containment is hardly an assurance that releases or leaks will be contained.
In Massachusetts, there are now just two agencies that oversee issues related to the operation, maintenance and use of underground storage tanks (USTs). While this is presumably more beneficial to the days when there were three, navigating through the two regulatory schemes can still be a challenge even for those that self-proclaim expert status.
“Technical Standards and Corrective Action Requirements for Owners and Operators of Underground Storage Tanks”
Although the most comprehensive underground storage tank (UST) training falls on the shoulders of the owner/operator (Class A) and the person responsible for the operations and maintenance of the UST system (Class B), it is the daily on-site employee (Class C) who more often than not will be the first responder to emergencies such as spills, fires and leaks at the facility.
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