Date Name Organization Deferral 

Type

Meeting Summary Notes

1/26/2012 Airlines for 

America

AHS 1.Discussed number of airports 

covered under proposed rule

2. Discussed differences between 

DoD and commercial AHS design

3. Explained extensive 

modification/contruction costs to 

meet release detection 

4. Asked for clarification of 

proposed definition

1. Followup with named 

airports

2. Clarification of definition to 

address ASTs and 

combinations

3. Relook release detection 

options

4. Look at costs to install DBB 

and segment systems.

1/26/2012 Petroleum Tank 

Piping Institute

WWTT Discussed onsite WWTTs

3/14/2012 Kevin Brackney Nez Perce Tribe WWTT (Verification that other 

regulations and state permitting 

programs may regulate these 

systems) 

get more information on UIC 

design and permitting

3/29/2012 Airlines for 

America

AHS 1. Discussed SPCC requirements 

for AHSs and how would this 

relate to UST regulations. 

2. Confirmed aiports that may be 

covered.

3. Gave information on JFK design 

and requested a functional 

definition 

4. How will intraststate pipelines 

be addressed (they are regulated 

by DOT and are offsite but part of 

the AHS).

5. Retrofits are budgeted into 

design/construction plans.

6. Testing freq. will be very costly, 

problematic, and challenging; 

other methods will not be feasible 

because of the variables and 

frequencies; (NEED TO INCLUDE 

REASONABLE ALTERNATIVES).

JFK/ORD -most critical but need 

the most retrofits. 

SPCC also covers AHS. How 

will SPCC and UST rules 

relate?

4/6/2012 Chris Wiesberg Missouri 

Department of 

Natural Resources

WWTT Received followup information on 

MO's experience with UIC wells

4/12/2012 Tom Groves NEIWPCC WWTT Discussed WWTT and UIC well

4/12/2012 Hess Corporation FCTs Discussed mounded tanks and 

state modified release detection

Get more info on modified API 

653

Talk to NY on requirement

4/17/2012 Maine Department 

of Environment 

Protection

WWTT Discussed state UIC regulations

If there is no access to the 

municipal water system, a class V 

UIC well is used; 
4/18/2012 Candace Cady Utah Dept. of 

Environmental 

Quality

WWTT Discussed OWS and WWTT not 

regulated under NPDES 

regulation depends on what is 

discharged before being 

discharged to UIC well.

4/18/2012 Chris Wiesberg Missouri 

Department of 

Natural Resources

WWTT Discussed state regulation of OWS

4/18/2012 Mary Hansen Washington State 

Department of 

Ecology

WWTT Discussed state regulation of 

WWTTs

Apr-12 Joe Cerutti Massachusetts 

Department of 

Environmental 

Protection 

WWTT Discussed regulation of WWTTs 

(UIC wells and holding tanks)

regulation is split among other 

programs (GW discharge; 

Industrial WW holding tank: 

carwashes/OWS)

4/19/2012 Ming Pan Massachusetts 

Department of 

Environmental 

Protection 

WWTT Discussed MA holding tank 

requirements

4/19/2012 Allen Slater Massachusetts 

Department of 

Environmental 

Protection 

WWTT Discussed state WWTT and drain 

regulation

5/9/2012 Karl Overman/Alan 

Anderson

Hansa Consult of 

North America, LLC 

AHS Discussed commercial airports 

and release detection (specifically 

Dulles, JFK, DoD, STL, ORD)

Search for A4A presentation 

at NISTM

Get more info on spill at 

Dulles

5/10/2012 Steve Hughes Virginia 

Department of 

Environmental 

Quality

AHS Discussed AHS leak at Dulles 

5/19/2012 Karl Overman/Alan 

Anderson

Hansa Consult of 

North America, LLC 

AHS Provided information on IAD, JFK, 

and STL release detection

5/30/2012 Russ Brauksieck New York State 

Department of 

Environmental 

Conservation New 

York State 

Department of 

Environmental 

Conservation 

AHS Asked for release detection report 

(JFK)

Will have to do FOIA for 

sanitized version 

6/13/2012 John Albert Missouri Dept of 

Agriculture

AHS Discussed inspection of MO's AHSs 

(STL/MCI)

DOA inspects AST for accuracy 

of device; check meter; 

calibrates for inventory 

reconciliation; does not verify 

tightness of lines (assumes 

being done - should check 

w/MDNR)

6/13/2012 Ken Koon Missouri 

Department of 

Natural Resources

AHS Asked if state inspects AHSs at STL 

and MCI

- state does not inspect because 

thought to be unregulated

Contact John Albert (Dept. of 

AG Weights and Measures)
6/18/2012 Raul Valdivia ORD AHS Inquiry on state inspection of AHS

6/18/2012 Sheldon Schall General Mitchell 

International 

Airport (MKE)

AHS Discussed AHS upgrade; release; 

and release detection

6/18/2012 Suzanne Foxworth Southwest Florida 

International 

Airport (RSW)

AHS Inquiry on state inspection of AHS

6/19/2012 Nick Velasquez Tuscon 

International 

Airport

AHS Discussed SFM duties when 

inspecting AHS at TUS

6/19/2012 William Hills Rickenbacker 

International 

Airport (LCK)

AHS Discussed hydrant system release 

detection

6/20/2012 Doug Mann Vista Precision 

Solutions

AHS Discussed where mobile release 

detection systems are located and 

capabilities of release detection 

systes at commercial airports

Not comfortable with 

providing information

6/21/2012 Karl Overman/Alan 

Anderson

Hansa Consult of 

North America, LLC 

AHS Discussed commercial airports 

and release detection capabilities

6/21/2012 Suzanne Foxworth Southwest Florida 

International 

Airport (RSW)

AHS Received AHS summary from state 

inspector on former AHS

6/28/2012 John Gunter Indiana 

Department of 

Environmental 

Management

AHS IN does not regulate AHSs and 

have not performed inspections.

7/11/2012 Environmental, 

Health & Safety 

Communications 

Panel 

EGTs Discussed typical facility EGTs and 

O&M

8/15/2012 Ken Wilcox and 

Associates

Deferred 

tanks

Discussed applicability of release 

detection on deferred tanks

8/29/2012 Association of 

State And 

Territorial Solid 

Waste 

Management 

Officials

Deferred 

tanks

Discussed state requirements for 

FCT/bunker tanks, and WWTT 

9/27/2012 Lamar Bradley Tennessee 

Department of 

Environmental 

Conservation

WWTT Talked to TN on Hydroswirl 

(WWTT)

1. Automobile plant in 

Chattanooga

2. Centrifuge

3. WW swirls into cone-shaped 

device and seperated

4. Covered under SPCC

Need more information on 

operation and regulation.
9/27/2012 Rick Barlow PanHandle Health 

District (PHD), 

Idaho

WWTT Discussed how WWTTs that 

discharge to grassy swale are 

regulated (not regulated under 

SDWA or CWA)

10/1/2012 Bruce Rohrbaugh Tennessee 

Department of 

Environmental 

Conservation

WWTT Received information on 

Hydroswirl

Answers comment

10/2/2012 Kansas City 

International 

Airport (MCI)

AHS Discussed airport deign, 

operation, and maintenance

10/2/2012 Kansas City 

International 

Airport (MCI)

AHS Received AHS schematics

10/10/2012 General Mitchell 

International 

Airport (MKE)

AHS Received MKE response to airport 

survey and schematics 

Need info on # DBB and 

segments to meet proposed 

leak rate

10/10/2012 General Mitchell 

International 

Airport (MKE)

AHS Received email on costs to install 

one isolation pit

10/10/2012 General Mitchell 

International 

Airport (MKE)

AHS Discussed airport design, 

operation, and maintenance

10/16/2012 Al Vokle Allied Aviation 

(STL/MCI)

AHS Discussed STL/MCI release 

detection

can not meet leak detection 

rate; can not tell rate of 

leakage

10/16/2012 Nancy Young, Tim 

Poehle, Katharine 

Preston

Airlines for 

America

AHS Wanted more information on 

EPA's fact finding and discussions 

w/commercial airports

1. Was the right person identified?

2. How were contacts decided?

3. Oral conversations may not 

convey the right information

4. Be clear that information is not 

being used as way to generate 

NOVs 

1. A4A will suggest provide a 

suggestion for integration of 

data quality and improvement 

for data gathering.

10/16/2012 Kansas City 

International 

Airport (MCI)

AHS Received MCI response to airport 

survey

Need info on # DBB and 

segments to meet proposed 

leak rate

10/17/2012 Fred Brinker Tuscon 

International 

Airport

AHS Fact finding on AHS design and 

operation

10/23/2012 Tuscon 

International 

Airport

AHS Received AHS survey, schematics, 

and notification form
11/14/2012 Rickenbacker 

International 

Airport (LCK)

AHS Received responses to survey 

information on AHS system design 

and operation and maintenance

Need operator training, spill 

prevention info

11/20/2012 Tuscon 

International 

Airport

AHS Received followup email on DBB 

installation and segment isolation 

for testing. 

11/26/2012 Kansas City 

International 

Airport (MCI)

AHS Email response on least number of 

DBB needed 

11/28/2012 Rickenbacker 

International 

Airport (LCK)

AHS Received followup information on 

testing, spill prevention, and 

operator training.

11/29/2012 Kansas City 

International 

Airport (MCI)

AHS Email response on whether leak 

rate could be met if segmented 

Line B

11/30/2012 O'Hare 

International 

Airport

AHS Received ORD response to airport 

survey and schematics

12/4/2012 Southwest Florida 

International 

Airport (RSW)

AHS Received AHS survey and 

clarification of release from 

former AHS

12/5/2012 Clark Conklin Nebraska State Fire 

Marshall's Office

FCTs Received email on regulation of 

230K gal FCT that contains #6

Answers comment

12/11/2012 Joe Burke SPEC Engineering 

PLLC 

Inspections Received information on the 

components of an API 653 

inspection

12/11/2012 St. Louis 

International 

Airport

AHS Received AHS survey

12/17/2012 Mihir Metha South Carolina 

Department of 

Health and 

Environmental 

Control

AHS Received list of SC airport releases 

for December 2012

12/18/2012 Mark Restaino O'Hare 

International 

Airport

AHS Did an tour of hydrant systems 

and met with ORD personnel 

(Mark Broudeau - A4A; Mike 

Loverage - ASIG)

Do more followup w/ORD

12/18/2012 Robert Davies North Carolina 

Department of 

Environmental and 

Natural Resources

AHS Received list of NC airport releases 

for December 2012

Do followup on MCAS - Cherry 

Point Releases

12/20/2012 General Mitchell 

International 

Airport (MKE)

AHS Received email on MKE system 

downtime for DBB installation 

1/22/2013 Ronald Wallace Georgia 

Environmental 

Protection Division

AHS Received site release information 

on Hartsfield Airport
1/22/2013 William Logan Georgia 

Environmental 

Protection Division

AHS Received site release information 

on Hartsfield Airport

1/23/2013 Renee Kwait Southwest Florida 

International 

Airport (RSW)

AHS Received information on RSW's 

AHS; discussed timing of O&M; 

spill response; and system 

calculations

1/30/2013 Mike Loverage O'Hare 

International 

Airport

AHS Obtained more information on 

ORD system design and 

operations

Followup on AHS calculation 

to determine if 10% is met

2/1/2013 Heather Peters Missouri 

Department of 

Natural Resources

AHS Received various sample site 

contamination remediation letters 

for leaks at STL

2/1/2013 Mike Loverage O'Hare 

International 

Airport

AHS Received email that calculations 

are correct.

2/6/2013 Mike Loverage O'Hare 

International 

Airport

AHS More discussions on ORD AHS 

design

2/6/2013 O'Hare 

International 

Airport

AHS Received ppt showing future 

planned demo of 18 USTs

2/12/2013 David Yarmartino Guam AHS Asked whether AHS would be 

regulated by UST regs ased on 

calculations

followup to have airport 

answer survey

2/14/2013 Yolanda Queseda San Juan 

International 

Airport

AHS Received a summary of a sampling 

report for a spill that occurred at 

Luis Muñoz Marin Airport in 2008

2/20/2013 John F. Kennedy 

International 

Airport (JFK)

AHS Discussed airport deign, 

operation, and maintenance

2/28/2013 Department of 

Defense

AHS Discussed AHS/FCT operation and 

maintenance; AHS definition; dual 

regulation w/SPCC; bunkered 

tanks

DoD to send release info on 

AHS and FCTs

3/18/2013 Department of 

Defense

AHS Discussed AHS/FCT operation and 

maintenance; dual regulation 

w/SPCC; bunkered tanks

4/4/2013 Association of 

State And 

Territorial Solid 

Waste 

Management 

Officials

AHS/Bunke

red Tanks

Discussed how AHS would be 

regulated based on definition and 

how are bunkered tanks 

regulated.

5/30/2013 Dan Manweiler Virginia 

Department of 

Environmental 

Quality

Bunkered 

Tanks

Asked about historical and 

damage information on bunkered 

tanks (at Reagan National Airport 

and others in Virginia)
5/30/2013 Steve Hughes Virginia 

Department of 

Environmental 

Quality

Bunkered 

Tanks

Discussed bunker (cut and cover 

tanks) and their use in VA.

Mentioned the Navy Fuel Depot in 

Yorktown case amd JP8 tanks that 

the Navy has at Oceana

Bunkered tanks were removed 

a while ago

Yorktown Naval Facility (1M 

gallon Bunker C fuel) - tanks 

were closed years ago but 

records are not available

Nuclear Naval Fleet use 

Bunker C

DCA bunker tanks closed in 

1993 (closure files not 

available)

11/22/2013 Jim Roewer Utility Solid Waste 

Activities Group 

DOE/NRC Discussed comment that UST rules 

should mirror SPCC language.

"not limited to 10 CFR part 50" 

because facilities can be licensed 

under part 52.