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A presentation by Heather Peters, MDNR, on recent changes to UST regulations and anticipated changes driven by expected Federal rule requirements.
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Celebrating 40 years of taking care of Missouri’s natural resources.
UST RULE CHANGES
Heather Peters,Environmental Specialist
Celebrating 40 years of taking care of Missouri’s natural resources.
Today’s Topic• 2011 Rule package- what’s left?
• Upcoming rule changes
• Federal regulation changes
• How are “you” doing?
Celebrating 40 years of taking care of Missouri’s natural resources.
2011 Rule Package• You:
– Provided input and experience– Suggested new and creative solutions– Identified pitfalls and problems– Got involved!
THANK YOU!
Celebrating 40 years of taking care of Missouri’s natural resources.
What are we still working to enact?• Emergency generator tank issues• Lining inspections (repair/compatibility)• High throughput facilities• SIR records• Out of use tanks
Celebrating 40 years of taking care of Missouri’s natural resources.
Out of Use Tanks• Within 12 months- site assessment
– “Closure” site assessment• Within 5 years (of pump out date)- closure
– Removal or fill in place• May be able to use the site assessment at
closure• May be able to re-open
Celebrating 40 years of taking care of Missouri’s natural resources.
Upcoming Rulemaking• State specific changes
– Will be open for comment/debate
• Secondary containment (double walled)
• Federal regulation changes
• Operator training
Celebrating 40 years of taking care of Missouri’s natural resources.
State Specific Changes/DiscussionsInterior linings• Inspections with photo/video documentation• Technician must be NACE or ICC certified• Include UL 1856• No interior lining inspection required IF
conducting interstitial monitoring
Celebrating 40 years of taking care of Missouri’s natural resources.
Interior Linings
Celebrating 40 years of taking care of Missouri’s natural resources.
State Specific Changes/DiscussionsInstalls• Cannot install a UST within 300 feet of well• Change install notification from 30 to 14 days• Post-installation tank tightness tests must be
NWGLDE certified as a tightness test• Tie-down all new USTs• Revisit UL1856 stand alone system• Establish a section for marinas
Celebrating 40 years of taking care of Missouri’s natural resources.
State Specific Changes/DiscussionsRepairs/ Upgrades
• Cannot re-repair a spill basin
• CP protected metal piping must be replaced if not protected for more than 90 days
Celebrating 40 years of taking care of Missouri’s natural resources.
Secondary containment• New (including replacement) tanks only• Piping replacement (50% or more of a
piping system within 1 year)• Does not apply to existing systems (until
replaced)
Effective July 1, 2017
Celebrating 40 years of taking care of Missouri’s natural resources.
Secondary containment• Double wall tanks• Double wall piping• Containment sumps• Interstitial monitoring the system
• We will not include spill basins, siphon piping, remote fills or vent piping.
*Courtesy of Steel Tank Institute
*Courtesy of Franklin Fueling
OUTER PIPE
INNER PIPE
Celebrating 40 years of taking care of Missouri’s natural resources.
New ‘regulated’ tanks
Field constructed (concrete) tanks
Oil/ water separators??
Airport hydrant systems
Celebrating 40 years of taking care of Missouri’s natural resources.
Sunset groundwater/vapor monitoring
Groundwater Monitoring Vapor Monitoring
Celebrating 40 years of taking care of Missouri’s natural resources.
Routine Site Checks (O&M)• Dispensers• All tank top manholes/containment sumps• Release detection equipment• Spill basins• Monitoring wells• Cathodic protection (if present)• Document these checks
Celebrating 40 years of taking care of Missouri’s natural resources.
New Testing Requirements• Containment sumps/double walled systems
• Overfill prevention equipment
• Automatic tank gauges/probe
• Spill basins
Celebrating 40 years of taking care of Missouri’s natural resources.
Operator Training• Training/testing online 2014
• By July 1, 2016 qualified Class A/B– Must pass Missouri’s online training/testing– Be certified in an adjacent/bordering state
• By July 1, 2016 trained or test Class C
Celebrating 40 years of taking care of Missouri’s natural resources.
State Program Approval• EPA enacts UST rules• NOT in effect immediately in Missouri• MDNR will promulgate rules• MDNR will ‘renew’ program approval
EPA Compliance Dates ≠ Missouri Compliance Dates
Celebrating 40 years of taking care of Missouri’s natural resources.
Inspection Compliance Rates• From three years of inspections:
– 3740 compliance inspections
– 92% of our active site inspections find something
– Only 3% needed an LOW– Approximately 1% have been issued an NOV
Celebrating 40 years of taking care of Missouri’s natural resources.
Three Years of Inspections
In Compliance at Inspection
Letter only
LOW issued
NOV issued
Celebrating 40 years of taking care of Missouri’s natural resources.
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