APPENDIX K - CCAMP UST RECOMMENDATIONS 



October 1987 Page K-2 



Local governments on Cape Cod have recognized the threats imposed by 

 USTs and most of them have adopted local bylaws or Board of Health regula- 

 tions to inventory all tanks. When EPA recognized the potential threat 

 posed by USTs, it proposed regulations in 1987 placing primary program 

 responsibility with the States (final regulations will be issued in 

 1988). In Massachusetts, the Department of Public Safety (DPS) has prima- 

 ry authority over USTs. Key regulations include 527 CMR 9.00 and 502 CMR 

 3.00. The DPS regulations in turn accord authority for implementation to 

 local Fire Departments (FDs) . 



FINDINGS 



The present state regulations, DPS's 527 CMR 9.00 and DEQE's 310 CMR 

 30.00, do not go far enough in protecting groundwater from contamination. 

 CCAMP's investigation identified the following shortcomings. 



STATE REGULATIONS DO NOT: 



Place all state regulations on All tanks. 



Directly discourage new household fuel tanks from being installed 



underground. 



Discourage the location of USTs in sensitive areas. 



Encourage the removal of older USTs from the ground. 



Provide a financial source for program implementation. 



Provide sufficient guidance for installation, construction, testing, 



cleaning and removal. 



These shortcomings have led CCAMP to identify the following areas where 

 efforts to improve local control over USTs should be focused. 



NEED FOR A LOCAL BYLAW TO PROTECT AND INVENTORY ALL TANKS . 



A release of significant size can come from even the smallest tank. 

 Yet, Massachusetts regulations exempt residential and farm gasoline tanks 

 less than 1100 gallons and oil tanks of any size used for consumptive use 

 on premises from notification requirements. The small, lower Cape town of 

 Eastham has a total of 264 tanks averaging 929 gallons and ranging up to 

 30,000 gallons of capacity per tank that fall into these exempt catego- 

 ries. Only 30 tanks in town, or about 10%, are covered by the state's 

 notification, testing and strict construction standards. Protection must 

 be across the board; towns must ensure that they have identified and ade- 

 quately controlled all tanks with the potential to contaminate groundwa- 

 ter. 



NEED FOR INCREASED LOCAL COORDINATION 



A number of towns in Barnstable County have more than one fire dis- 

 trict. There are also towns with local regulations granting UST 



