In anticipation of BLR’s upcoming underground storage tank (UST) Master Class, Emily Remmel sat down with copresenter Dennis Oberdove, owner and president of Tank Integrity Services, to get a sense of the daily troubleshooting issues that arise on the ground when testing UST systems.
Q. What is the most common compliance issue you come across in the field?
A. I run across many compliance issues. Paperwork is a big one. Making sure owners and operators keep good records and remain organized is something we all struggle with. Monthly leak detection and annual compliance issues are other common issues. I also see compliance issues with Stage I vapor recovery.
Q. Do you have any advice to owners and operators to avoid enforcement action in the situations you mentioned?
A. Try to stay on top of the recordkeeping requirements, and be more organized.
Q. Is there a specific situation that you can recall where you uncovered a violation during UST testing?
A. One time the UST owner and operator shut down the electricity and disabled the sump sensors to save money. When in reality shutting down the electricity is like turning off a lightbulb—doing this sort of thing does not save you much in energy and could potentially cost you a lot if the sump overfilled.
Q. With the updated 2015 UST regulations, what specific areas will be the most difficult for owners and operators to implement?
A. I see compliance issues most readily with A, B, and C Operators. Often entities attempt or want to delegate out Class C designations. Not having trained Class C operators on duty all the time is an important issue because Class C operators are the first responders to spills and leaks. Even though many states already require Class C operator training, it is not getting done correctly. Therefore, I foresee operator training will be the most difficult to implement.
Interested in the UST Master Class? This 1-day class is packed with compliance information every environmental professional or corporate counsel needs to know when dealing with UST systems and understanding EPA’s updated 2015 UST regulations.
The UST Master Class is December 1, 2015. The Master Class will be held in Columbus, OH at the Embassy Suites Columbus—Dublin. Environmental Legal Editor Emily Remmel and Dennis Oberdove will copresent the event. More information can be found here.
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Dennis Oberdove, President/Owner of Tank Integrity Services, has been in the petroleum business since 1979. As the president and owner of Tank Integrity Services, he is responsible for all operations and is certified in 4 different tank and line testing methodologies. He reviews all test results of storage tanks, lines, leak detectors, and stage II systems. He is State Certified Instructor for Stage II Vapor Recovery Systems and Steel Tank Institute Certified Inspector for aboveground shop fabricated tanks. Oberdove troubleshoots and recommends action for customers regarding compliance procedures according to the Executive Orders for Stage II Systems. He is also certified in Alert tank testing, Petro Tite line testing, Cathodic Protection Testing, Ohio UST Installer, API Work Safe, Omntec–Installer & Service and Veeder Root–Level 1and NACE Membership, and he is a Board Member of the Ohio Petroleum Contractors Association.
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Emily Remmel, J.D., is an environmental legal editor for BLR’s environmental publication team. She focuses on stormwater regulations, NPDES permitting, CERCLA, USTs/ASTs, and brownfields. Before joining BLR®, she clerked for the U.S. Environmental Protection Agency in Boston and the Environmental and Natural Resources Legal Clinic in Vermont. She holds a JD and Certificate in Water Law from Vermont Law School. While in law school, Ms. Remmel was the editor-in-chief of the Vermont Journal of Environmental Law. In addition, she received a BS and MS in Zoology from the University of Oklahoma, where she researched freshwater ecology and invasive species. She is a member of the American Bar Association as well as the New Hampshire Bar Association and is licensed to practice law in New Hampshire.
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