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MASSACHUSETTS UNDERGROUND STORAGE TANK (UST) PROGRAM

MASSACHUSETTS UNDERGROUND STORAGE TANK (UST) PROGRAM. Baseline Compliance Assessment. 1. MassDEP 8/2/2011. UST Program. UST program was transferred from DFS to MassDEP in July 2009 Between July 2009 and November 2010 MassDEP inspected ≈ 350 randomly selected facilities in order to:

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MASSACHUSETTS UNDERGROUND STORAGE TANK (UST) PROGRAM

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  1. MASSACHUSETTS UNDERGROUND STORAGE TANK (UST) PROGRAM Baseline Compliance Assessment 1 MassDEP 8/2/2011

  2. UST Program • UST program was transferred from DFS to MassDEP in July 2009 • Between July 2009 and November 2010 MassDEP inspected ≈ 350 randomly selected facilities in order to: • understand “baseline” compliance status of the sector as a whole and • aid in the development and implementation of the regulatory program 2 MassDEP 8/2/2011

  3. Main Discussion Topic Compliance with EPA “Significant Operational Compliance” Performance Measures (SOCs) related to: • Release Prevention • Release Detection NOTE: EPA uses different measures to quantify and evaluate the number of spills or leaks that have occurred. 3 MassDEP 8/2/2011

  4. UST Program Purpose • The UST Program ensures that underground storage tanks do not release regulated substances into the environment • The regulated substances include: • Gasoline • Diesel • Fuel oil • Waste oil • Acids • Bases • Hazardous substances • Solvents 4 MassDEP 8/2/2011

  5. UST Program Universe • There are: ≈ 3800 active facilities ≈ 9100 registered active tanks • These facilities include: • fuel dispensers • industrial operations • hospitals • schools • military bases • airports • authorities • Federal, state and local government agencies • small businesses 5 MassDEP 8/2/2011

  6. Key Program Requirements Per the Energy Policy Act of 2005: • Tank and pipe construction and installation must meet standards that prevent spills and leaks • Approved leak detection systems must be in place and operated to identify leaks so that they can be addressed before they become a serious problem • Leak detection and prevention systems must be maintained and tested to ensure their proper operation • Recordkeeping must be performed to document regulatory compliance • Facilities are inspected routinely to insure that the regulatory standards are met (In MA, Third Party and MassDEP inspections are used.) 6 MassDEP 8/2/2011

  7. Complexities • New program for MassDEP • Regulations currently in force were written by another agency (DFS) • Regulatory requirements may differ from facility to facility due to the variety of compliance options and UST systems 7 MassDEP 8/2/2011

  8. Release Prevention SOCs • Spill prevention equipment is present and operating properly • Overfill prevention equipment is present and operating properly • Tanks and pipes are tightness tested within six months of UST system repairs • Corrosion protection systems are tested for functionality within 30 days of UST system repairs • Corrosion protection systems are operating and maintained properly • Impressed current cathodic protection system is inspected every 60 days • Corrosion Protection is in place for all tanks and pipes Note: The SOC “Lined tanks are inspected periodically and lining is in compliance” was not included in the analysis because there were no facilities in the sample to which it applied. MassDEP 8/2/2011

  9. Release Detection SOCs • Leak detection systems are in place • Leak detection systems are operating properly • Leak detection systems meet the applicable performance standards • Proper response to suspected releases • All tanks and pipes are monitored at the required frequency and records are kept Note: The SOC “Hazardous substance USTs meet leak detection requirements” was not included in the analysis because there were no facilities in the sample to which it applied. The SOC “Out of service tanks containing product meet leak detection requirements” was excluded because it is not applicable in MA. 9 MassDEP 8/2/2011

  10. Gas Stations where owner owns >5 facilities (27% of universe, sample size = 55) Gas Stations where owner owns < 5 facilities (36% of universe, sample size = 48) Manufacturing / Utilities (10% of universe, sample size = 43) Misc. Small Business & Municipalities (18% of universe, Sample Size = 53) Institutional/State & Federal Government(9% of universe, sample size = 42) MassDEP assessed the performance of a random sample of facilities from 6 individual groups: each of the above categories and early submitters (by 7/1/09) of the required Third Party Inspection reports “Groups” of UST Facilities Assessed USTs facilities were grouped into one of five categories: 10 MassDEP 8/2/2011

  11. Overall Performance Based on a weighted average of the five facility categories* • 85% were in compliance with all EPA Release Prevention SOCs • 44% were in compliance with the all EPA Release Detection SOCs 42% of the facilities were in compliance with all EPA SOCs (both Release Prevention and Release Detection) * NOTE: The Third Party Inspection Group was not included in this calculation 11 MassDEP 8/2/2011

  12. Massachusetts Assessment Results vs Other States’ EPA SOC Performance • Release Prevention Measures • New England: 69% - 86% • National: 45% - 98% Average: 84% • Massachusetts: 85% • Release Detection Measures • New England: 68% - 82% • National: 55% - 98% Average: 79% • Massachusetts: 44% • All SOCs • New England: 54% - 84% • National: 36% - 90% Average: 71% • Massachusetts: 42% MassDEP 8/2/2011 12 • SOURCE: EPA Semiannual Report of UST Performance Measures Mid Fiscal Year 2011 as of March 31, 2011 (5/2011)

  13. Overall Facility Performance on EPA Release Prevention SOCS (Weighted average of the performance of each of the five facility categories) 13 MassDEP 8/2/2011

  14. Overall Facility Performance on EPA Release Detection SOCS (Weighted average of the performance of each of the five facility categories) 14 MassDEP 8/2/2011

  15. Each Group’s Performance on EPA Release Prevention SOCs MassDEP 8/2/2011 15

  16. Each Group’s Performance on EPA Release Detection SOCs 16 MassDEP 8/2/2011

  17. Requirements Generally Achieved Required Leak Detection Systems are installed and turned on UST systems have adequate corrosion protection Cathodic corrosion protection systems are operating Properly sized spill buckets are installed Overfill protection is installed 18 MassDEP 8/2/2011

  18. How Many Individual Requirements Did Facilities Violate? The average facility violated 21% of the requirements that applied to the facility 88% of facilities violated at least one of all of the requirements included in the assessment 58 % of facilities violated at least one SOC Based on a weighted average of the performance of each group 19 MassDEP 8/2/2011

  19. Average Facility Violation Score for Each Group % of applicable requirements the facility violated) Gas Station: Owner owns >5 facilities 13 % Gas Station: Owner owns <5 facilities 22% Manufacturing / Utilities 19% Institutional / State & Federal Government 22% Misc. Small Business & Municipalities 28% Facility submitted TPI before July 2009 20% MassDEP 8/2/2011

  20. Frequently Violated Requirements % of Facilities in Violation MassDEP 8/2/2011

  21. Violation Rates for Frequently Violated Requirements by Group

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