PMAA Represents Marketers at ASTSWMO Conference

Yesterday, PMAA UST Task Force member Bruce Garrett of Volta Oil Company (Plymouth, Massachusetts) represented PMAA before the national Association of State and Territorial Solid Waste Management Officials’ (ASTSWMO) conference regarding PMAA’s alternative sump testing method and ULSD corrosion concerns. The EPA’s Office of Underground Storage Tanks (OUST) approved PMAA’s low liquid level integrity test as an alternative method for containment sump testing that is required under the 2015 federal UST regulations. The 2015 regulations require liquid testing every three years of all containment sumps used for interstitial monitoring of piping. However, the test method cited in the rule requires filling sumps with water above the penetration points in the sump wall. This sump test method would be prohibitively expensive for tank owners. Instead, the PMAA UST Task Force developed an alternative test for containment sumps.

The alternative requires filling sumps only to the level of a liquid sensing device equipped with a positive shutdown that is mounted below penetration points in the sump wall. PMAA’s alternative test method will significantly reduce reoccurring sump testing compliance costs for tank owners while being equally protective of the environment as filling the sump to the top, according to the OUST. This is an important victory for petroleum marketers that builds on previous cost saving flexibility won by the PMAA UST Task Force during the rulemaking process.

PMAA is continuing to work with OUST on additional flexibility measures for compliance with the 2015 UST requirements. In June, PMAA submitted comments to the EPA’s Regulatory Reform Task Force requesting a 3-year compliance extension of the 2015 underground storage tank regulations.

Meanwhile, Mr. Garrett highlighted PMAA’s concerns with ULSD corrosion studies to date. PMAA believes that the focus of accelerated corrosion studies on retail sites alone is misguided and could result in unfairly shifting responsibility for all corrective action to petroleum marketers. PMAA supports fuel quality studies along the entire petroleum production and distribution chain to determine the cause of accelerated corrosion. Until a broader study is undertaken, PMAA will refrain from funding studies that focus solely on finding causes downstream of the terminal rack.