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### Topics for ASTSWMO Meeting on August 28, 2012 Below is a list of questions for which it would be helpful to get ASTSWMO’s input. As OUST continues to work through the comments to the reg proposal, there will likely be additional discussion topics. For our meeting on the 28 th , we anticipate discussing the items below with yo u as time allows. If states have data, anecdotal information, reports, etc. that are responsive to any of the questions below, please share those documents with us. Please be aware that any documentation ASTSWMO provide s to OUST will become part of the public record and entered into the docket.

 General Program Implementation o Which states have a certified technician or similar program requirement for service providers to provid e UST sy stem testing on individual system equipment testing (e.g., release detection equipment, spill bucket, overfill prevention equipment, interstitial integrity testing)? o What do states require for a failed test or defective equipment? I s repairs/repl acement or otherwise returning the s ys tem to proper operation implied in state regulations or specifically stated? What has been the experience of state inspectors? o How are states implementing the 30

- day release detection monitoring requirement? I s ther e a strict adherence to a 30

- day monitoring frequency

or what allowances are made for owners and operators to meet the requirement?

 New Technologies o Do states allow technologies that construct a tank within an existing tank to be considered a new UST s ys tem (as opposed to a modification of an existing UST sy stem)? I f yes and the existing tank is steel, which states continue to require corrosion protection of the existing steel tank if it is not permanently closed? o Do states instead allow the existing t ank to be permanently closed (for example , require a site assessment) without removal or filling with a solid inert material?

 Spill/Overfill Prevention o Do states have any data on percent or size of releases from overfill and spill bucket failures? o If no, are states aware of any documented anecdotal reports, new stories, etc., that spill bucket and/or overfill prevention failures specificall y have led to releases? o Do states have any information regarding how often spill prevention equipment and/or overfill equipment is a reason for noncompliance during inspections? (I deally

separate info for overfill and for spill prevention.) o How often d o owner/operators replace spill buckets? o Are states seeing issues with double

- walled spill buckets?2

 Deferrals o Emergency

Generator Tanks (EGT)
 Are states tracking these sy stems? Are states being notified when these sy stems are brought into service, as currently required?
 Have states experienced challenges with release detection on these sy stems? If so, how have states addressed these challenges?
 Are an y release detection methods prohibited to be used on these type tanks? I f so wh y? o Field Constructed USTs
 Has an y state established a specific definition for field constructed UST?
 EPA has assumed that all of the fi eld

- constructed USTs are owned or operated b y the DoD. But we have heard from at least one industry group (EHSCP) that they also own field

- constructed USTs. They say that they have notified states of these tanks. Do any UST state programs keep track of these FCTs (versus some other state program office)? I f so, how many do they believe are non

- DoD and who owns them? o Wastewater treatment tanks
 Which state office manage s these sy stems?
 Do states track these s ys tems? I f so, how man y do state s have?
 Do s tate s inspect them?
 Any know releases from these sy stems?

 Compatibility o Are an y states activel y i mplementing EPA’s Compatibility Guidance? o What are state inspectors finding? o Have states encountered any releases due to incompatibility? I f so, what equipme nt was incompatible and what type of fuel was the UST storing? o Do an y states require owners/operators to demonstrate compatibility before storing a particular product? I f so, what are states finding?

 Interstitial Monitoring Results (including Alarms) o Do state s have any specific policies or guidance pertaining to addressing alarms indicating the presence of water? I f so, what are they? o Do state s have any specific policies or guidance pertaining to preliminary investigations to address a suspected release? These would be actions that might negate the need for involving a third party s ervice provider. o How man y UST systems are using secondary barriers (liners around or beneath the s ys tem) in state s ?

 Operator Training o How do states address in

- house training conducted by companies ? Specificall y interested in how the verification of training is addressed.3 o Is there any variance in operator training requirements by type of facility

or are operator training requirements req uired uniformly

across all ty

pe UST sy stems?

 Ground Water and Vapor Monitoring o How are states monitoring these and how is it working? o Are new gw/v monitoring wells going in? o Are there i nstances in which gw/v monitoring was in place but missed detecting a spill? o Are these methods allowed for any typ e of facility or do states only allow gw/v monitoring at certain facilities?

 Ball Floats o Do states have any (documented) information about operational issues or release experience associated with ball floats? o What percent of USTs in state s use coaxial stage I vapor recovery? o What percentage of USTs in states have non - tight tank tops such that ball floats would not restrict flow? High

- through Put Facilities

o How do states implement the 3 gallon per hour within 1 hour performance requirement for automatic line leak detectors? I s this enforced as a per hour test or does the equipment have to perform some task in the event of a leak within the period of 1 hour? o What has been state experience with enforc ement of the 3 gallon per hour performance standard? Does this differ according to facility (e.g., line remaining pressurized over short periods of facility closure)? o Do states allow sump sensors to be use d to meet the 3 gallon per hour performance requirement for automatic line leak detectors? I f so, are there any special circumstances for their use?