The EPA has made it easier for anyone in the community to report a fuel release or other environmental violation. A new form on their website allows citizens to make these reports anonymously online, triggering a red flag that will be passed to state agencies for immediate investigation.

In describing this community outreach effort to create more citizen-partners in compliance, the EPA “seeks help by asking you to provide EPA with information about potentially harmful environmental activities in your communities.”

The site additionally provides a list of incidences classified as “environmental crimes.” 

Self-Reporting Requirements

Obviously, the last thing a UST owner or operator wants is to have a UST incident reported by citizens before they can properly do so. With the legal responsibility to report suspected or known fuel releases to your state’s regulatory authority “as soon as possible,” (interpreted by most states as within 24 hours), now may be a good time to review proper reporting criteria with your staff.

Per the EPA’s website, the following situations must be reported:

  • Any spill or overfill of petroleum that exceeds 25 gallons or that causes a sheen on nearby surface water. (Spills and overfills under 25 gallons that are contained and immediately cleaned up do not have to be reported. If they can’t be quickly cleaned up they must be reported to your regulatory agency.)
     
  • Any released regulated substances at the UST site or in the surrounding area — such as the presence of liquid petroleum; soil contamination; surface water or groundwater contamination; or petroleum vapors in sewer, basement, or utility lines.
     
  • Any unusual operating conditions you observe — such as erratic behavior of the dispenser, a sudden loss of product, or an unexplained presence of water in the tank. However, you are not required to report if the system equipment is found to be defective, but not leaking, and is immediately repaired or replaced.
     
  • Results from your release detection system indicate a suspected release. However, you are not required to report if the monitoring device is found to be defective and is immediately repaired, recalibrated, or replaced and further monitoring does not confirm the initial suspected release, or, in the case of inventory control, a second month of data does not confirm the initial result.

Emergency Response Plans

If you don’t currently have one, now may also be a good time to create an Emergency Response Plan. This is a simple document containing a list of pertinent numbers that facility attendants can reference in case of an emergency. In fact, as most states adopt the Class C Operator Training requirements outlined in the Energy Act of 2005, they will begin enforcing that these Emergency Response Plans be posted in a prominent location at every UST facility.

Here is an example of an acceptable Emergency Response Plan format from the EPA. However, please note that every state may adopt individual requirements beyond the EPA’s baseline.


 

For more information on managing UST compliance or initiating approved site-specific Class C Operator training, please contact ROI@titancloud.com.

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