accommodate pipe movement.
• Electronic inventory control is taken for granted today, rather
than as the luxury it was in the late 1980s.
• Overfill prevention valves came into use as a result of the EPA
• Prior to the EPA regulations, releases were kept in the ground
and away from public exposure.
• Today’s tank systems are significantly larger and more
complex. The use of compartments to store several fuels is
• Installation practices have improved and become
standardized. The use of clean backfill is pretty much taken
for granted today.
• Initially, secondary containment was mandated in New
England, Florida and California. Now, it is mandated in 48
states. Secondary containment, which applied to tanks and
pipe, has expanded to under-dispensers, sumps, etc.
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• New owners and personnel who do not have a background
with technology and regulations are more dependent on
service companies. As a result, EPA is mandating operator
training and equipment maintenance oversight.
Expert: MARSHALL MOTT-SMITH Position: President, Mott-Smith Consulting group; Coo, aet Compliance; Vice President, national institute for Storage tank Management
1987Q Twenty-five years ago, I was the administrator
for the Storage Tank Regulation Section for the Florida
Department of Environmental Regulation. I had just served
on the EPA committee of state representatives that helped
develop the federal UST [underground storage tank] rules.
The biggest effect I’ve seen from the rules is that experienced owners have an increased awareness and prevention
mindset. Most have learned that following the rules reduces
their risk and keeps them in operation. By doing so, they avoid
regulatory fines, downtime, bad press and costly cleanups.
In many states with a UST rule that is equivalent to the
federal rule, owners continue to use statistical inventory
reconciliation [SIR] for leak detection. While SIR is good for
catching big leaks, it does not provide a level of leak detection
comparable to other methods. I’ve seen many an owner
switch to other leak detection methods after multiple fails or
inconclusive results with SIR.
The good things that have come out of the federal rule
include the requirements for corrosion-resistant tanks and
piping. Leak autopsy data confirms that tanks are no longer
the biggest problem, and that the 1998-installed single-
walled piping out performs the older equipment that it
replaced. States that chose to require secondary containment
prior to the Energy Act of 2005 are experiencing even lower
numbers of releases. While sumps are not required in the
federal rule, many owners have chosen to use them to prevent
corrosion and leaks.
Another significant benefit of the 1987 regulations is on
the people side. Bright industry professionals have developed