In anticipation of BLR’s upcoming underground storage tank (UST) Master Class, Emily Remmel sat down with copresenter Dennis Oberdove, owner and president of Tank Integrity Services, to get a sense of the daily troubleshooting issues that arise on the ground when testing UST systems.
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Q. What is the most common compliance issue you come across in the field?
A. I run across many compliance issues. Paperwork is a big one. Making sure owners and operators keep good records and remain organized is something we all
struggle with. Monthly leak detection and annual compliance issues are other common issues. I also see compliance issues with Stage I vapor recovery.
Q. Do you have any advice to owners and operators to avoid enforcement action in the situations you mentioned?
A. Try to stay on top of the recordkeeping requirements, and be more organized.
Q. Is there a specific situation that you can recall where you uncovered a violation during UST testing?
A. One time the UST owner and operator shut down the electricity and disabled the sump sensors to save money. When in reality shutting down the electricity is like turning off a lightbulb—doing this sort of thing does not save you much in energy and could potentially cost you a lot if the sump overfilled.
Q. With the updated 2015 UST regulations, what specific areas will be the most difficult for owners and operators to implement?
A. I see compliance issues most readily with A, B, and C Operators. Often entities attempt or want to delegate out Class C designations. Not having trained Class C operators on duty all the time is an important issue because Class C operators are the first responders to spills and leaks. Even though many states already require Class C operator training, it is not getting done correctly. Therefore, I foresee operator training will be the most difficult to implement.
Interested in the UST Master Class? This 1-day class is packed with compliance information every environmental professional or corporate counsel needs to know when dealing with UST systems and understanding EPA’s updated 2015 UST regulations.
The UST Master Class is December 1, 2015. The Master Class will be held in Columbus, OH at the Embassy Suites Columbus—Dublin. Environmental Legal Editor Emily Remmel and Dennis Oberdove will copresent the event. More information can be found here.