EPA Proposed Requirement Description Increased Cost Per 

Facility

Increased Costs For 

Industry Cost Information PMAA Alternative Proposal PMAA Proposal Cost per Facility

PMAA Proposal for 

Industry

Release Prevention

Walk Through Inspections including; Spill Prevention Equipment, Sumps, Dispenser 

cabinets, Monitoring/Observation Well Covers, Impressed Current Cathodic 

protection systems and Release Detection Systems

$3,600.00 $803,365,200.00

Costs assume that a Third Party will need to 

perform the inspection. Typical station 

personnel do not have the right work 

classification to perform the inspection. It 

will cost $300 per month to hire contractor.

PMAA agrees that Monthly Walk Through 

Inspections make sense, however they 

should be based on they type of equipment 

installed at the UST systems. See the 

attached Schedule of proposed inspections 

in Appendix A

$900.00 $200,841,300.00

Over-Fill Prevention Equipment Tests $135.00 $30,126,195.00

The cost to have Overfill Prevention tested 

will be $400 to test three Overfill devices. 

Overfill only needs to be tested once every 

three years, therefore it will cost $135 

annually.

PMAA endorses this proposed rule, however 

if the manufacturer has a specification for 

inspection, that should be allowed to be 

used and should only be required once every 

5 years. 

$80.00 $17,852,560.00

Spill Prevention Equipment Tests $750.00 $167,367,750.00

It will cost $350 to have the Spill Buckets 

tested & $400 to dispose of waste. 20 gallons 

of waste water is anticipated to be generated 

by three Spill Buckets and one Stage I bucket. 

Disposal of one drum of waste water is $400.

PMAA agrees that Spill Prevention 

Equipment(Spill Buckets) should be tested at 

the time of installation. PMAA also thinks 

that all existing Spill Prevention Equipment 

Should have one passing test within three 

years of the implementation. No further 

testing should be required. PMAA has 

attached testing data over time to support 

no further testing after the initial test. 

$750.00 $167,367,750.00

Periodic Testing of Secondary Containment including; UST Interstitial Space, 

Double-Wall Piping Interstitial Space and Containment Sumps $1,050.00 $234,314,850.00

It will cost $250 per UST to test the 

interstitial space. It will also cost $100 per 

line to test the interstitial space and $2,100 

to test 7 sumps and dispose of waste water. 

Based on three USTs, four dispensers it will 

cost $3,150 to test every three years or 

$1,050 annually.

PMAA supports the requirement to test 

secondary containment at the time of 

installation. PMAA also supports the 

requirement to have all containment sumps 

have one passing test within three years of 

the implementation. No further testing 

should be required. PMAA has attached 

testing data over time to support no further 

testing after the initial test. 

$3,150.00 $702,944,550.00

Testing Repairs to Spill & Over-Fill Prevention Equipment and Interstices $175.00

It will cost an additional $175 to have the 

repaired Spill Bucket or Overfill tested. We 

are assuming that the test will be performed 

by the technician doing the repair. If an 

independent contractor is required the cost 

would be $350.

PMAA endorses this proposed rule. 

Equipment repairs should be tested before 

returning to service.

$175.00

Eliminate Flow Restrictors in Vent Lines for all New Tanks and When Over-fill 

Devices are Replaced $2,200.00 It will cost $650 per drop tube for materials and $250 in labor to install.

PMAA endorses this proposed rule. However, 

Flow Restrictors should allow to be used as a 

secondary form of Overfill Protection.

$2,200.00

Release Detection
Operability Tests for Release Detection Methods $300.00 $66,947,100.00 It cost $300 to have a contractor certify a 

typical Leak Detection system.

PMAA endorses this proposal. UST owners 

should rely on technology. Equipment needs 

to be checked periodically for proper 

operation.

$300.00 $66,947,100.00

Add SIR/CITLD to Regulations with Performance Criteria PMAA endorses this proposed rule. It makes sense to have a consistent and 

uniform performance criteria.

Response to Interstitial Monitoring Alarms $350.00

It will cost $350 to have a service contractor 

come to the site to investigate alarms. Many 

containment areas cannot be accessed by 

station personnel.

PMAA endorses this rule. Electronic 

monitoring provides the best form of Leak 

Detection. Alarms need to be responded to 

and investigated.

$350.00

Eliminate groundwater and vapor monitoring as release detection methods PMAA endorses this proposed rule. 

Remove deferral for emergency generator tanks Not PMAA's fight 

Other

Require notification of ownership change $100.00 The cost represents the time it will take to fill 

out new Registration forms. PMAA endorses this proposed rule. $100.00

Closure of lined tanks that cannot be repaired according to a code of practice PMAA endorses this proposed rule.

Requirements for determining compatibility 

Remove deferrals for airport hydrant fuel distribution systems and UST systems 

with field-constructed tanks Not PMAA's Fight Not PMAA's fight

EPA ct-related Provisions

Operator training $500.00 $111,578,500.00 It will cost $500 to provide training for Class 

A/B/C Operators that need to be certified.

This rule is in affect in many parts of the 

country.

$500.00

Secondary containment for new installations $50,000.00

The cost to include secondary containment is 

estimated to be 10% of the total installation 

cost. The typical UST system replacement is 

estimated to be $500,000

PMAA endorses this proposed rule. We think 

for new installations this makes sense. $50,000.00

Under Dispenser Containment for all New Dispensers $5,000.00

It will cost $5,000 per dispenser to install 

Under Dispenser Containment as the rule is 

written. The concrete island will need to be 

replaced or modified, the electrical 

connections will have to be removed and 

replaced.

PMAA does support the idea of Under 

Dispenser Containment, provided that it is 

only required for new UST & Piping 

installations or if the horizontal piping needs 

to be replaced as part of the dispenser 

replacement.

$1,000.00

EPA Proposed Regulation Annual Costs $6,960.00 $1,553,172,720.00 PMAA Alternative Annual Costs $2,305.00 $514,376,885.00

EPA Proposed Regulation One Time Costs $57,200.00 PMAA Alternative One Time Costs $57,200.00

* The costs are based on Conventional UST Systems consisting of three USTs per system. Industry costs assumes 223,157 facilities.