The next big headache for UST owners: Y2K
Informational Web sites
How tank owners are coping with the new standards
Some dates to watch
OK, so you've already survived the U.S. Environmental Protection Agency's (EPA) new standards for upgrading underground storage tanks (USTs) that went into effect last December. With careful attention to detail, you ensured that all the USTs at your facility had the proper spill and overfill equipment, corrosion protection and leak detection devices, and had all substandard tanks replaced or closed. Well, don't throw away your migraine medication just yet, because another important deadline that can impact your USTs is fast approaching.
Most of the intense discussion surrounding the year 2000 problem (Y2K) has understandably focused on computers and computer programs. Stated in its simplest form, the Y2K problem - often referred to as the millennium bug - is that many computer programs and computers will not be able to correctly process dates that occur after 1999. Computer programs have traditionally been designed to display the date code as the last two digits of the year, e.g. 98 instead of 1998. Originally welcomed as a cost- and space-saving feature, this programming feature could trigger problems when Jan. 1, 2000 arrives. Many computers will consider the year 2000 (or 00) as the year 1900, while others may not be able to switch from 99 to 00 at all.
Owners and operators of underground storage tanks (USTs) need to be aware that their systems can also be affected by this programming limitation. The Y2K problem can impact date-sensitive devices controlled by embedded microprocessors (computer microchips) such as dispensers, leak detectors, tank monitors and fuel management systems. A UST leak detector that malfunctions due to a Y2K glitch and fails to detect gasoline leaks can be just as devastating to the environment as an older tank that leaks because it has not been upgraded to meet the new federal standards.
A gameplan for tackling the problem
As part of your efforts to deal with the potential Y2K problem that could impact your facility's UST systems, EPA recommends you follow the following course of action:
- Identify a staff member or a committee of staff members to assess your UST systems.
- Inventory components of your system that could be vulnerable to Y2K disruption. If your equipment was purchased recently, it may be Y2K-compliant. Check with your supplier, installer or equipment manufacturer.
- Prioritize the risks to your business of each potential threat. What are the financial and other costs if you do not correct the problem?
- Repair, modify or replace each threatened component in your UST systems. Begin a systematic process of correcting problem areas.
- Conduct a test of Y2K-amended items deemed critical for environmentally safe operations. If feasible, conduct your test as a simulation, or on a very small scale, to avoid major upsets of current operations, e.g.. large releases of petroleum products to the environment if the test fails. Testing should be conducted in accordance with the Y2K enforcement policies of EPA and your state environmental agency.
- Prepare a site contingency plan to anticipate and manage disruptions. Maintain hard copy plans for each automated system should a failure occur, or install manual overrides of safety and environmental control systems. Look particularly at those problems that you think have not been resolved.
Y2K Information Central
Prompted by requests from industry, municipal and state governments and oil companies, the Petroleum Equipment Institute (PEI) set up a database on its Web site (www.pei.org) of information related to the Y2K readiness of petroleum equipment. The database includes information voluntarily provided by members of the PEI Manufacturing Division regarding the Y2K compliance status of the systems or equipment that they produce.
UST owners and operators can scroll through the database to check out the Y2K compliance status of specific products that are part of their UST systems. The database also lists manufacturer contact information for people who want additional information about the products. Examples of the types of equipment listed include line leak detection systems, moisture and vapor analyzers, and tank monitors. On the Web site, the PEI management clearly warns people reviewing the information that the institute has not independently verified the representations made by the manufacturers concerning the Y2K readiness of their products.
Millennium bug benefits
While dealing with the Y2K problem, try to remember that it can actually lead to benefits for you. By upgrading your UST systems and implementing operational improvements, you'll be able to ensure that your USTs don't leak and cause you even worse headaches - namely, enforcement actions by governmental agencies and third party lawsuits by adjacent landowners.
E-sources
U.S. Environmental Protection Agency
www.epa.gov/year2000/problem.html
Petroleum Equipment Institute
www.pei.org
American Petroleum Institute
www.api.org
EPA's Chemical Emergency Preparedness and Prevention Office
www.epa.gov/ceppo
Chemical Safety and Hazard Investigation Board
www.chemsafety.gov
U.S. Small Business Administration (SBA)
www.sba.gov/y2k
Petroleum Marketers Association of America
www.pmaa.org
The Steel Tank Institute
www.sti.org
National Institute of Standards and Technology's Year 2000 Web site
www.nist.gov/y2k
How tank owners are coping with the new standards
EPA imposed the deadline of Dec. 22, 1998 for all UST owners and operators to have installed spill and overfill prevention and overfill protection on the metal parts of their UST systems. At the time the new standards went into effect, EPA estimated that more than half of the approximately 892,000 USTs in the United States were in compliance with the new standards and that about 200,000 would have to close.
The move was prompted by concern about the significant public heath threat posed by substandard tanks when leaks of petroleum products enter groundwater. Research shows that one gallon of gasoline can contaminate 5 million gallons of drinking water. Considering that one half of all U.S. residents depend on groundwater for their drinking water, it is understandable why EPA and the state environmental agencies are so concerned about upgrading USTs throughout the nation.
According to Sammy Ng, the director for the policy and standards division of EPA's office of underground storage tanks, approximately 80 percent of U.S. USTs were in compliance as of this August. "We hope that by the end of 2000 about 90 percent of all USTs will be in compliance with the new standards," Ng said.
Ng credits several factors for the increasing level of compliance. First, state governmental inspections are being regularly conducted to verify the compliance of USTs. Second, besides routine inspections, 15 state governments are taking the additional step of restricting fuel delivery to noncompliant USTs. As part of these "red tag" programs, governmental inspectors in these states are literally putting red tags on the fill caps of USTs they have determined to be out of compliance. Fuel suppliers who provide fuel to USTs clearly marked with red tags are risking liability by such actions. Third, major oil companies are exerting pressure on UST owners by refusing to deliver fuel to USTs that are not compliant with the new standards.
Owners who fail to upgrade their noncompliant USTs risk hefty fines that can reach $11,000 per day. The UST owners are also liable for cleaning up any contamination that results from their substandard tanks.
Those who want specific information about compliance levels in specific geographical areas should check out Petroleum Equipment Institute's (PEI) Web site. (www.pei.org). The organization has posted a national database that lists the 50 states' approaches to enforcing the 1998 upgrade standards. The statistics are updated periodically by the respective state environmental agencies.
Compliance rates listed on the database vary widely from location to location. For example, a representative of the West Virginia state environmental agency estimated, based on figures compiled in March 1999, that 40 percent of the state's active tank population did not meet the 1998 requirements. In contrast, a representative from the Florida Department of Environmental Protection estimated, based on statistics compiled in March 1999, that only 3 percent of all Florida USTs were out of compliance.
Some dates to watch
Jan. 1, 2000: Rollover may halt, confuse or otherwise disrupt many systems and devices.
Feb. 29, 2000: Many systems may not recognize 2000 as a leap year.
Oct. 10, 2000: First time date filed uses maximum length.
Dec. 21, 2000: Some systems may not recognize the 366th day.
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This article originally appeared in the 10/01/1999 issue of Environmental Protection.