Contributed by Jacob Pongetti, Project Manager, PPM Consultants
Most environmental projects don’t start with a catastrophic release. Most of the time, they start with something small. An alarm that comes back every day. Water showing up where it shouldn’t. An inconclusive test that gets pushed to the bottom of the to-do list because the site is, first and foremost, an active business.
At the time, none of these situations by themselves seem like they should lead to a costly environmental project. In many cases, they don’t. As environmental consultants, we are typically brought into a project after a problem has already been identified. By that point, we are past prevention and well into investigation. The questions become: What happened? How extensive is the issue? What do we need to do next? Many of these projects began, maybe years earlier, as something relatively minor.
The challenge is that a UST system, obviously, is underground, making it pretty difficult to “pop the hood” and check for issues. If a tank gauge starts acting up or a sump begins taking on water, the consequences may not be noticed for weeks, months, or even years. That’s why UST regulations include requirements for inspections, testing, leak detection, and recordkeeping. The goal is not simply to satisfy a regulatory requirement. The goal is to identify potential problems before they become larger ones.
When I hear the word compliance, I think about paperwork (a lot of it). Routine inspections help identify damaged equipment. Leak detection systems help identify potential releases. Testing helps verify that critical components are functioning properly. Individually, these activities may seem routine. Altogether, they provide multiple opportunities to catch problems early. Documenting all of these routine tasks gets pretty tedious. When everything is fine over and over again, it is easy to assume it will continue to be fine and that there isn’t a need for the ever-growing stack of paperwork. It is easy to view compliance records as paperwork for the sake of paperwork. However, if a release is discovered and State Trust Fund reimbursement is expected, those same records can suddenly become some of the most important documents at the facility. When the word “liability” comes into play, “if it isn’t documented, it didn’t happen” becomes very real.
One thing I’ve learned working on environmental projects is that problems rarely improve with time. A minor equipment issue today often becomes a larger issue tomorrow if it isn’t addressed. The best environmental investigation is the one that never needs to happen. Of course, that’s not always possible. Equipment ages, components fail, and the unexpected occurs. But facilities that stay proactive with inspections, testing, maintenance, and documentation generally put themselves in a better position to identify issues before they become environmental projects. If a problem does arise, having current records and maintaining state Trust Fund eligibility may be the difference between receiving assistance with cleanup costs and having to pay those costs out of pocket.
Another aspect that can be overlooked is having a strong line of communication with your testers. When the “30-day walk through inspections” are conducted they are essentially reporting and confirming your leak detection records each month. That information should be submitted and reviewed by the tank owner. These reports only provide value if someone reviews and follows up on the findings. If Interstitial monitoring is your leak detection method for tanks and/or lines, the 30-day walk through is where testers “run a tape” to confirm if the liquid level alarms are in alert condition. If using continuous statistical leak detection (CSLD), the monthly walk through is where tests are conducted (run the tape) to determine if the tanks are passing or failing. I can recall countless situations where testers submitted reports indicating an alarm condition or a failing test, but the issue was not addressed and months went by before a leak was identified. This can be costly in more ways than one! Inventory is not cheap, especially right now as costs near $4 per gallon. Not to mention, with each passing hour a tank leaks, the cost of cleanup and potential liability for the tank owner increases. This can often be avoided if the testers communicate the significance of unusual results when problems occur rather than assuming every report is fully reviewed and acted on. That being said, tank owners should study each report. Vigilance from all parties is the best solution.
Compliance records are maintained but not automatically submitted to the agency. There are good reasons for compliance requirements, and it pays to invest in that knowledge and take it seriously. If you are a tank owner and running your business does not give you the bandwidth to pay attention to these matters, then find someone in your organization that can get involved. Bring them up to speed, as it will pay dividends for your organization.
Every site is different, and not every alarm, failed test, or unusual condition indicates a major problem. Knowing when to investigate further can make a significant difference. If you have questions about UST compliance, environmental issues, release investigations, or State Trust Fund eligibility, contact PPM to discuss your situation. Reach out to me directly at jacob.pongetti@ppmco.com.
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