The Association of State and Territory Solid Waste Management Officials ("ASTSWMO") adopted a revised policy position paper on October 27, titled:

Open cofferdam sealing system for underground storage tanks at retail refueling facilities ("Policy Position")

This policy position concerns the open berm containment system used in commercial retail facilities to meet the overflow prevention and equipment requirements of underground storage tanks ("UST") as outlined in 40 CFR 280.20(c) (a part of the Code of Federal Regulations) ( "BCS"). UST regulations).

BCS is described by Policy Position as being configured as:

... The infill riser of the UST system is surrounded by small concrete berms or curbs, which are usually used in large-capacity facilities.

It is said that BCS floors are usually constructed of concrete. Most systems have a drain to transfer any spilled liquid, rain or melted snow to the oil/water separator. Some spill pipes extend above the ground, and the filling hose is permanently fixed to the pipe and remains open at the end.

40 CFR 280.251(d) allows owners and operators of regulated airport fire hydrants and UST systems and on-site storage tanks to use the following military construction standards:

Uniform Facilities Standard (UFC) 3-460-01, Petroleum Fuel Facilities

The policy position describes it as a standard code issued by the Department of Defense for the design, installation, and testing of such systems. It may also be part of the leakage prevention, control and countermeasures (ie SPCC plan). However, it is worth noting that retail facilities are usually not built in accordance with such standards and are not included in the SPCC rules.

The policy position states that the federal UST regulations provide an overflow container (ie, overflow bucket) as an example of an overflow prevention device that will prevent the product from being released into the environment when the transfer hose is separated from the pipeline. It also partially states:

Oil spill barrels are generally accepted as meeting the requirements of anti-spill equipment. When determining whether an open berm containment system is acceptable, it must comply with the same requirements, that is, it must prevent leakage when the conveying hose is separated from the filling pipe, and design and install it according to the established practice code. Nationally recognized associations Or an independent testing laboratory.

ASTSWMO pointed out that the organization’s policy position is:

... The open cofferdam containment system provides less protection for human health and the environment, and may not prevent leakage when the delivery hose is disconnected from the filling pipe for the following reasons:

This policy position has been adopted by the ASTSWMO board of directors.

A copy of the revised policy position can be downloaded here.

Disclaimer: Due to the generality of this update, the information provided here may not be applicable in all situations, and action should not be taken without specific legal advice based on specific circumstances.

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