MARKETING & SUPPLY
CONCLUSIONS Every UST owner should ask themselves: Is my tank system capable of performing continuous leak detection on my underground double-walled pip- ing utilizing vacuum, pressure, or hydrostatic methods? Was my double-walled piping system installed with secondary containment integrity testing engineered into the design and installation of the system? If you answered "No" to the questions above, you may be
a. b.
required to replace your underground piping. In an effort to ensure compliance with potential regula-
tions impacting your petroleum storage systems, you will need to be aware of this regulation and the impacts it could have on your specific systems. From the information found in the public responses to the proposed regulations, it appears that some tank owners and regulators have reservations whether this regulation is warranted, or not. As of the time this paper was written and published, the EPA has not responded to these comments, nor promulgated these rules. However, the EPA may determine that promulgating this rule is in the best interest of protecting the health of the public and the environment. To be prepared for upcoming regulatory changes, you should review each of your underground piping systems
to determine how the proposed regulation will impact compliance with this rule. Then develop a plan for com- pliance that may include contacting a consultant, petro- leum contractor or integrity testing firm to assist you in determining compliance. And if necessary, develop strate- gies and budgets for replacing piping that cannot meet the integrity testing requirements applicable to your systems. But don't wait! Other tank owners are already reviewing their tank system, and will scheduling their own projects. Poor planning could create a potential for missed compli- ance deadlines. One last thing you can do is to contact your regulators and let them know how you feel.
Author: Gregory M. Myka, with 20 years experience in petroleum storage regulatory compliance, is currently a graduate student at Rochester Institute of Technology and a petroleum storage system subject matter expert for an international communications com- pany.
Co-Author: Dr. Jennifer Schneider is a professor & the Russell C. McCarthy Endowed Chair in the Civil Engineering Technology, Environmental Management & Safety Department in the College of Applied Science & Technology.
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46 SEPTEMBER 2012 NPN Magazine n www.npnweb.com
