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Comments
on
Revising Underground Storage Tank Regulations – Revisions to Existing Requirements and New
Requirements for Secondary Containment and Operator Training
Docket ID No: EPA-HQ-UST-2011-0301
Submitted by
National Ground Water Association
601 Dempsey Rd
Westerville, OH 43081
800.551.7379, ext. 560
creimer@ngwa.org
Contact: Christine Reimer
March 16, 2012
General Comments: National Ground Water Association (NGWA) as the world’s largest organization of
groundwater professionals supports the proposed rule’s focus on preventing underground storage tank
releases that can negatively impact the environment. NGWA’s long held position is that control of
potential and active sources of contamination should be a national objective, thereby reducing the need
for remediation of groundwater. i NGWA actively participated in policy discussions that lead to the
underground storage tank provisions of the Energy Policy Act of 2005. Groundwater professionals
supported improved operation and maintenance by qualified individuals, greater tank integrity, early
detection and robust state oversight. The current rule proposal addresses the lessons professionals
have learned over time about how to better protect the groundwater resource. In particular, the
Association supports the requirements for secondary containment of new or replaced tanks and piping,
operator training, and the addition of provisions to ensure the continued operation and maintenance of
equipment so as to prevent and quickly detect releases, if they occur.
Specific Comments: Page 71742, 6. Phase Out Vapor Monitoring and Groundwater Monitoring as
Release Detection Methods:
NGWA supports the move toward interstitial monitoring as release detection for new double walled
tanks and piping with a goal of early leak detection prior to groundwater impacts. NGWA also agrees
with the proposal to move toward internal and interstitial monitoring as the first line of defense for
release detection on existing tanks. However, the Association suggests that the Agency make clear that
States have the flexibility to require groundwater monitoring and/or soil vapor monitoring for reasons
other than release detection at underground storage tank sites.
For example, groundwater monitoring wells could be used to establish baseline groundwater conditions
prior to tank installation and to evaluate groundwater conditions (water quality, water table depth,
groundwater flow direction) on an ongoing basis. Also, while recognizing the proposal requirements for
addressing release detection alarms or unusual operating conditions (page 71743), groundwater
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monitoring wells provide additional mechanisms to detect discharges in cases where release detection
equipment fails or small leaks or spills go undetected or possibly unreported, especially in areas with
high water tables or abundant clay layering.
The final rule should also make clear that States have the flexibility to require soil vapor monitoring in
the vadose zone, such as beneath a tank and above a deep water table. Soil vapor monitoring would
provide States, at their option, a redundant system so if interstitial tank alarms failed, one might detect
a release before the groundwater quality is impacted and results in an expensive remedial effort.
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The National Ground Water Association is a not-for-profit professional society and trade association for
the groundwater industry. Our members from all 50 states include some of the country’s leading public
and private sector groundwater scientists, engineers, water well contractors, manufacturers, and
suppliers of groundwater related products and services.
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For additional information contact NGWA Government Affairs Director Christine Reimer at 800/5517379, ext. 560, creimer@ngwa.org.
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i
National Ground Water Association. Groundwater Protection Issue Brief. 1990.
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