Antea Group’s oil and gas segment team members attended the New England Interstate Water Pollution Control Commission’s National Tanks Conference (NTC2018) in Louisville, Kentucky last month. The event was widely attended by federal and state regulators, underground storage tank (UST) owners, industry groups, consultants, vendors, and insurers. NTC2018 was a unique interface for these groups, given the important changes occurring in the UST regulatory world.
Here are some of the hot topics that we found fascinating at this year’s event:
Novel remediation methods and High-Resolution Site Characterization (HRSC) led the way as top remediation topics—with carbon injectate, in situ remediation approaches, geophysics, Light Non-Aqueous Phase Liquid (LNAPL) recovery, and how HRSC can reduce lifecycles and costs also being highlighted. HRSC and 3-dimensional data visualization are becoming more widely used tools to support a more targeted investigation and enhancing remediation implementation and performance. Antea Group’s own Joshua Orris presented two posters on these topics—view them here.
- We saw deliberate interest in regulatory agencies promoting innovation through advocacy for HRSC to drive more refined source area characterization, LNAPL delineation, and remediation performance evaluation.
- While HRSC is still emerging, regulatory agencies see the value in data density, data quality, and how investing in HRSC on the front end can shorten lifecycles and the agencies’ caseload.
- Agency representatives want to see increased use of technology-based tools and solutions that can promote site management efficiency and, in the long-term, be more cost-effective.
State and Tribal Programs
Presentations about the maintenance of state funding centered on keeping the funds healthy. State funds have been replenished, and agencies have been given a directive to close sites. Multiple presentations discussed relationship building between government and industry—and managing liability through insurance.
- One notable presentation referenced large numbers of abandoned USTs in one state—the management strategy will need to accommodate the backlog.
- We also gleaned that agency programs are sharing management strategies for reducing risk with the limited available funding/preserving the existing funding.
New Regulatory Requirements
The 2015 federal regulatory changes are being phased in, with the final deadlines affecting the non-state plan agreement (non-SPA) states this week. The presentations on regulations and equipment did not necessarily focus on the deadlines, though—the focus was on the “how” of secondary containment and overfill protection equipment, compatibility for emerging fuels, corrosion effects on equipment, and efficacy of alternative inspection methods. Stay tuned for our upcoming blog post on the deadlines and what owners should do next, where we will look at the new regulations and incorporate lessons learned from this conference.
- Operator certification is part of the regulatory requirements that will be changing with the implementation of the new regulations, and Antea Group’s Angela Dunn connected with Storage Tank Operator Training (STOT) content approvers from multiple state agencies as our STOT solution increases its geographical coverage. Find out more about our online solution for STOT here.
- Sump testing and alternate methodology was another key topic on the regulatory track. Alternate methodologies—such as filling the sump only to the level of the sensor—may create cost savings for those facilities where the equipment performs well.
- Lastly, operators that invest in and maintain their equipment will reduce their risk of releases and their risk of regulatory action.
Any opportunity to connect with our friends and colleagues in the UST industry is a valuable one, but the NTC2018 conference had an especially solid base of speakers presenting informative topics. We all benefitted from being in attendance, and we are already looking forward to the next conference!
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