cost up to three times more than conventional components. Yearly service calls, mandatory testing, and
downtime also add expense that could prompt fuel
marketers to consider decommissioning their Stage
II systems, required or not.
"The return on investment to decommission a
site can be less than a year in some instances. If
Stage II testing is due, it is an even more attractive
option, where the cost of the Stage II tests can easily
exceed $1,500 per location," Gaff said.
Obviously, decommissioning has some upfront
capital costs as well which are of course multiplied by the number of sites in the operation
to be decommissioned. Should decommissioning
be done all at once or gradually? That will likely
depend upon the individual operation and the
cycle of the specific state's Stage II maintenance
and testing requirements.
"Our recommendation has been to look at
what your maintenance and testing costs are on an
annual basis," Derge said. "So if you have five-year
frequencies for inspection and maintenance you
then have time, depending on what the compliance
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date is, to do this and make that capital investment. Your maintenance costs are going to be fairly
stagnant."
As Baker noted, "Since approval will be needed
to decommission Stage II systems, it's a good idea
for fuel marketers to be proactive in planning to
replace them," he said. "For example when a pump
goes down in a vacuum assist system, rather than
replace an expensive pump it would be a good time
to apply to phase out the Stage II system instead."
And it cannot be over emphasized—get everything possible in writing and understand that there
is at least some risk involved with decommissioning even if everything "seems" clear. "You are not
protected from EPA enforcement unless the state
revises its SIP plan. So from that perspective, marketers are hesitant," Derge said. "However, with the
proper guidance from the state authorities having
jurisdiction, they are moving forward as allowed by
the local regulations."
April 2013
19
