A presentation by Heather Peters, MDNR, on recent changes to UST regulations and anticipated changes driven by expected Federal rule requirements.

1. Celebrating 40 years of taking care of Missouri’s natural resources.
UST RULE CHANGES
Heather Peters,
Environmental Specialist

2. 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?

3. 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!

4. 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

5. 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

6. 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

7. Celebrating 40 years of taking care of Missouri’s natural resources.
State Specific Changes/Discussions
Interior 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

8. Celebrating 40 years of taking care of Missouri’s natural resources.
Interior Linings

9. Celebrating 40 years of taking care of Missouri’s natural resources.
State Specific Changes/Discussions
Installs
• 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

10. Celebrating 40 years of taking care of Missouri’s natural resources.
State Specific Changes/Discussions
Repairs/ Upgrades
• Cannot re-repair a spill basin
• CP protected metal piping must be replaced if
not protected for more than 90 days

11. 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

12. 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.

13. *Courtesy of Steel Tank Institute

15. *Courtesy of Franklin Fueling

16. OUTER PIPE
INNER PIPE

17. Celebrating 40 years of taking care of Missouri’s natural resources.
New ‘regulated’ tanks
Field constructed
(concrete) tanks
Oil/ water
separators??
Airport hydrant
systems

18. Celebrating 40 years of taking care of Missouri’s natural resources.
Sunset groundwater/vapor monitoring
Groundwater Monitoring Vapor Monitoring

19. 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

20. 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

21. 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

22. 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

23. 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

24. 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

25. Celebrating 40 years of taking care of Missouri’s natural resources.