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Protecting the Aquifer by Licensing PBS Tank Contractors

State: NY Type: Promising Practice Year: 2020

The Nassau County Department of Health (the Department”) located in Mineola, New York, was established in 1938. Nassau County is a suburban county on Long Island, New York that borders Queens County to the west, Suffolk County to the east, and Connecticut to the north across the Long Island Sound. The Department provides services to a population of 1.34 million residents that includes 448,528 households, and 340,523 families. The population density is over 4,700 people per square mile. (U.S. Census Bureau, 2010).

Nassau County has been severely impacted by hazardous discharges into the soil and groundwater, predominantly from petroleum and chemical spills. These discharges have resulted in the extensive contamination of groundwater resources in Nassau County, which is dependent on the United States Environmental Protection Agency (USEPA) designated Nassau/Suffolk, Long Island Sole-Source Aquifer” as the source of all drinking water. To better protect the aquifer system, preventative measures must be taken to limit the number of petroleum spills in Nassau County.

After the delegation of Petroleum Bulk Storage (PBS) regulations was granted by the New York State Department of Environmental Conservation (NYSDEC) to the Department, a thorough review of the program found that there were numerous deficiencies in both formal training and experiential requirements that contractors needed to meet before engaging in such work. Additionally, there were no set procedures to ensure that contractors were correctly installing, repairing, testing, or removing petroleum tank systems. To correct these deficiencies, the staff at the Department underwent extensive training on the subject matter and received input from other knowledgeable stakeholders in the community.

The goal of this practice was to assure that all regulated petroleum tanks in Nassau County are installed, repaired, tested, operated, and removed in a manner that will protect the public health by preventing the release of petroleum into the sole-source aquifer system.

The practice had two main objectives. First, the Department implemented licensing exams using manufacturers' guidelines, industry standards, and regulations to ensure that petroleum tank contractors are well-trained and competent. To sit for a licensing exam, contractors were required to obtain manufacturers' training for tanks and electronic telemetry consoles. Second, the Department developed procedures that contractors must follow while they work on these petroleum tanks. These procedures include inspections by the Department and documentation that the contractors must complete in order to verify that the work was conducted properly.  

With these two objectives successfully met, the risk of petroleum discharging into the soil and groundwater has been substantially mitigated. This is evident base on several factors. In the years prior to the implementation of this practice, an average of 32% of all PBS enforcement cases each year involved tank equipment deficiencies. After the first year of this practice, this was reduced to an average of only 9% of cases each year. Additionally, the Department's acceptance rate of small PBS tanks installed without plans has increased. These tanks are installed by contractors and then inspected by the Department. In previous years, these tanks had an acceptance rate of 82.81% with the Department. The rejected tanks either had to be modified, moved, or removed entirely. Since this practice has been in place, all small tanks undergoing inspection have been approved. Finally, the data show that number of reported spills in Nassau County to the DEC is fewer than years prior, and fewer than what predictive models using historical trends would show for the years this practice has been in place. There was an average of 1113 reported spills per year in the 10 years prior to this practice. Based on the trend, there should have been approximately 969 reported spills per year during the years this practice was in place, yet there was an average of only 839 reported spills per year, with one year having the fewest number of reported spills in over 30 years.

This practice resulted in more competent, well-trained, and experienced contractors who work on PBS tanks systems. They know how to properly install, maintain, and remove tanks resulting in fewer violations, better tank maintenance, and fewer petroleum discharges into the soil groundwater. As a result of the practice, the aquifer system is better protected from potential contamination, thereby protecting the public through lowering the potential for adverse health effects from contaminants in their drinking water. It is expected that the implementation of the practice will also result in a reduction in long-term costs to the water suppliers in Nassau County incurred by the need to remove petroleum contaminants from the public water supply.

http://www.nassaucountyny.gov/agencies/health/

This practice is new to public health in that, previously, such oversight of PBS tanks was completed by a different agency that did not have the training or experience necessary to regulate these tanks in a manner cognizant of the environment and the public's health.  Innovations related to this practice involved adding a public and environmental health protection philosophy to the already established safety goals of the regulation. Specifically, regulations were developed with the protection of the USEPA designated Nassau/Suffolk, Long Island Sole Source Aquifer” in mind as all potable water in Nassau County comes from the supply wells that draw water from this extensive aquifer system.

The Department regulates the operation of forty-six (46) public water supply systems comprised of 380 potable water supply wells under the requirements of Part 5 of the New York State Sanitary Code and Article VI of the Nassau County Public Health Ordinance (NCPHO). Nassau County has been severely impacted by hazardous discharges into the soil and groundwater, predominantly from petroleum and chemical spills. These discharges have resulted in the widespread contamination of groundwater resources in Nassau County, which is dependent on as the source of all drinking water. The Department regulates over 2000 PBS facilities through the delegation of PBS regulations from the NYSDEC. These facilities must comply with Article XV of the NCPHO. In order to better protect the aquifer system, preventative measures must be taken to limit the number of petroleum spills in Nassau County.

The evidence of widespread groundwater contamination due to industrial spills has been widely studied and documented over the years. The 1999 Ground Water and Public Water Supply Facts for Nassau County, New York (Famiglietti, et al, 1999) described a widespread concern of raw water contamination found in all three of the major aquifers that serve county residents. The report shows the presence of a range of volatile organic chemicals, many of which can be found in petroleum products, were found in about 20 percent of the wells in the Magothy Aquifer, which contains a majority of all the production wells in Nassau County. While the quality of the drinking water itself has remained well within compliance limits, the impacts of groundwater contaminants on the raw water sources has forced water suppliers to install many multi-million-dollar treatment facilities in order to ensure that the drinking water remains of the highest quality. This cost however, has been passed down to the consumers.

To combat the extensive and potential for additional contamination, Nassau County enacted a policy in which single walled Underground Storage Tank (UST) Systems must be permanently closed after 30 years and replaced with double-walled tanks equipped with electronic monitoring systems that can detect overfills and leaks in the tank itself and associated piping. The installation of these contemporary PBS systems requires a deep understanding of tank handling, installation, operation and associated electronics. In short, entities that routinely perform this type of work must employ individuals who have been trained in areas that may not have been necessary in the past. Many of these single walled tanks have had to be replaced in the time this practice has been in place.

G. Mattney Cole, PhD, a chemistry professor at Colorado School of MINES, instructed and developed several courses related to petroleum and the environment, and authored two textbooks on the assessment and remediation of petroleum-contaminated sites. In his textbook Underground Storage Tank Installation and Management, Cole states that mandatory tank removals for older, less environmentally  safe tanks, can create a boom in the UST installation industry. The upsurge in tank removals and installations is good for the environment and legitimate UST installers. On the other hand, this new opportunity can attract the get rich quick” types with little training and less experience. Cole encourages that regulators should be emboldened to license contractors who work on petroleum tanks, both below and above ground.  He states that it discourages unqualified and inexperienced people from attempting installations, and it provides owners with some minimum indication of competence on the part of the installer. Cole further states that the use of competent installers should eventually sharply reduce the instances of petroleum contamination. (Cole, G. M., 1992.)

To protect the sole source aquifer, this practice targeted the contractors who install, repair, test, and remove petroleum tanks within the County. Currently, there are 59 contractors licensed to install, repair, remove, and test the functionality of PBS tank systems within Nassau County. There are an additional 23 contractors who are licensed to test the PBS tank systems for tightness. Since this practice has been in place these number have moderately fluctuated from year to year.

Central innovations to this practice involved creating connections between third-party contractors that perform common and routine work at PBS facilities with equipment manufacturers that can train and certify them in the proper handling, maintenance, and testing of storage tanks and associated systems. With the Department serving as the regulated authority, there is now an assurance that contractors attain the correct training, are well-versed in all aspects of their job duties, and continually produce reliable, high-quality outcomes that allow regulated facilities to remain in compliance with the regulations and, most-importantly, protect the public from the effects of petroleum product release into the environment. Furthermore, a reliance on utilizing developed industry best practice standards from well-respected and time-tested organizations, such as the Petroleum Equipment Institute (PEI) and the American Petroleum Institute (API), to create rigorous certification exams has gone a very long way in ensuring that only the most qualified contracting companies become certified to perform this type of work.

Proper tank work requires practical experience, sound judgment, and careful adherence to recommended practices and procedures. One of the objectives of this practice is to provide a concise and reasonably complete procedure set for working on petroleum tanks. While the contractors are provided with detailed procedures, the intent is to explain the reasons behind recommended practices. Sound judgment is the result of understanding, rather than routine adherence to a list of instructions.

This practice has familiarized all contractors with the standards set forth in Article XV of the NCPHO. As such, related projects are being completed in a uniform fashion and continue to result in a much more efficient, organized, and environmentally-conscious completion. The continued use of this practice has benefited, and will continue to benefit, all residents of Nassau County. In the past, PBS was regulated by a different agency. The agency involved did not have the training and experience  with the technicalities of environmental health, science, and engineering that would have allowed for such a wide scope of protection involving public and environmental health concerns related to water quality, the hydrology of Long Island's aquifer system, and engineering principles now needed to be considered. With these additional concerns in mind, the Department understood that additional oversight of the contractors performing this work and a set of specified requirements involved in conducting testing of the petroleum tank systems at PBS facilities was needed.

Since all potable water in Nassau County comes from supply wells that draw water from the aquifer system, all county residents, and those who come to Nassau County to work and play, benefit from this practice. County residents and visitors who use the potable water are directly affected by the contamination of groundwater resources due to by petroleum spills. Additionally, the entire population of Nassau County benefits from a reduction in the overall release and exposure to contaminated groundwater, as this not only benefits the health of all county residents, but their finances as well. The water consumers ultimately bear the brunt of the cost of contamination remediation, as the water suppliers must invest large sums of money into remediation efforts, and ultimately pass these costs onto the consumers by increasing their water bills. A reduction in contamination will lead to less extensive remediation efforts.

The current practice has greatly improved aspects of the petroleum tank installation/removal and testing programs. There is now a centralized set of standards and policies in place that all contractors must abide by. In the past, contractors could take more liberties with certain procedures which resulted in a wider range in the quality of the work. With these new standards in place, contracting companies can most efficiently, environmentally-consciously, and cost-effectively distinguish themselves from their competitors and enable themselves to set a foothold in Nassau County.

The goal of the practice was to protect Nassau County's sole source aquifer by preventing the release of petroleum into the ground.  To accomplish this goal, this practice targeted the contractors who install, repair, test, and remove petroleum tanks within the County.

The practice had two main objectives. First, the Department implemented licensing exams using manufacturers' guidelines, industry standards, and regulations to ensure that those contractors installing, repairing, testing, and removing petroleum tanks in Nassau County are adequately trained and competent. Second, the Department developed procedures that contractors must follow while they work on these petroleum tanks. These procedures include inspections by the Department and documentation that the contractors must complete in order to verify that the work was conducted properly. This ensures that all items involved in the installation, removal, and/or testing of each storage tank and associated equipment are evaluated and properly certified by qualified individuals and/or entities.

The practice was initiated through the delegation of PBS regulations from the NYSDEC to the Department. Following the delegation, PBS regulations were codified in Article XV of the Nassau County Public Health Ordinance (NCPHO). At this time, the Department assumed responsibility for the oversight of the licensing and work of contracting companies that install, remove, repair and test PBS tank systems, which was previously regulated by another agency. An extensive review of the existing licensing procedures for PBS tank contractors that installed, removed and tested petroleum tank systems and found that there were numerous deficiencies in both formal training and experiential requirements that contractors should meet before engaging in such work. Additionally, there were no set procedures to ensure that contractors were correctly installing, repairing, or removing petroleum tank systems.

To better reflect the manufacturers' guidelines, industry standards, and regulations within the testing documents and to develop proper procedures for construction, the staff at the Department went through extensive training on the subject matter. The first portion of this training included reading through guidance documents including Recommended Practices for the Testing and verification of spill, overfill, leak detection, and secondary containment at UST facilities” (PEI/RP1200-12), Understanding line leak detection equipment” (California Environmental Protection Agency), and UST Systems: Inspecting and maintain sumps and spill buckets” (USEPA). This was a good basis for staff to learn the terminology and tank components and how these components properly operate. The staff then attended training on tank testing techniques from Leighton O'Brien, training on Fiberglass Storage Tank Installation Instructions and Operating Guidelines” from tank manufacturer Containment Solutions, Authorized Service Contractor Training for Proteus Electronic Monitoring System” from telemetry system manufacturer Omntec Corporation, a seminar on petroleum tank regulations from the NYSDEC and the USEPA, and joint facility inspections with NYSDEC authorized inspectors. The Department also conducted in -person meetings and conference calls with many of the licensed contractors to gain a better understanding of their experiences and field conditions that they encounter. This training took approximately three months to complete.

Regarding the licensing of contractors, it was determined that in order to ensure that the highest quality of installation, maintenance and system testing work is conducted the following requirements needed to be implemented by the Department:

First, the contractor must complete and pass certified tank manufacturer training in order to ensure that the contractor has been exposed to, and comprehends, the proper procedures in transporting, handling and installing tank systems. This training must be given directly from a specific tank manufacturing company and proof of training completion must be provided to the Department.

Next, the contractor must complete and pass certified electronic monitoring equipment manufacturer training in order to confirm that the contractor has been exposed to, and comprehends, the proper procedures in installing, testing and maintaining all probes, sensors, panels and other electronics associated with petroleum storage tank systems. This training must be given directly from a specific electronic telemetry company and proof of training completion must be provided to the Department.

Finally, the contractor must pass a written exam administered by the Department that ensures that all local regulations regarding petroleum tanks are understood, as well as verifying the training described previously. Application forms were developed for the contractors that wanted to be licensed. These exams were 40 question multiple choice exams that required a minimum of 70 percent correct to pass. There were several different versions of the exams administered to ensure the integrity of the exam. Questions were designed with guidance from PEI documentation, including relevant information about tank procedures as well as site safety. In addition, specific items included in Article XV of the NCPHO were used as a source for questions in order to ensure that candidates were familiar with the local regulations. Upon the passing of an exam, the Department issued Certificates of Fitness and identification cards to the qualified entities.

After the members of the staff involved with this practice completed their training, the Department reviewed the existing procedures that petroleum tank contractors used while performing tank work and found that there were numerous deficiencies. To better reflect the manufacturers' guidelines, industry standards, and regulations the Department developed a set of procedures for petroleum tank contractors to follow. These procedures covered installing, repairing, testing, and removing petroleum tank systems.

To develop these procedures, the Department utilized various resources. Two such resources were the Inspection & Maintenance of Motor Fuel Dispensing” best practice standard (PEI/RP500) and the Installation of Underground Liquid Storage Systems” best practice standard (PEI/RP100). The RP500 published by the PEI provided a basic reference that consolidated information from equipment manufacturers, installers, and end users concerning the proper inspection and maintenance of motor-vehicle fuel-dispensing equipment. RP500 provided the most current information on sound engineering and construction procedures with regard to the proper installation of underground liquid storage systems. The document contains sections on excavating, backfilling, anchoring, piping, release detection, cathodic protection, secondary containment, and other aspects of tank system installation. Other documents used were Standard 653: Tank Inspection, Repair, Alteration, and Reconstruction” and Standard 650: Welded Tanks for Oil Storage” both by the API. These two documents effectively covered procedures for installing, repairing, removing, and testing aboveground tanks.

By taking relevant information from the best practice standards, incorporating NCPHO Article XV regulations, and learning what the licensed contractors experienced in the field the Department was able to generate procedures that are safe, effective at protecting the environment and the public, and practical for real world situations. This process of developing testing documents and procedure forms took the Department approximately 3 months to complete.

As policies regarding this practice were developed, mass mailings and e-mails were sent out to each contractor in order to make them aware that these procedures were being implemented as of specific dates. Additionally, an in-house policy of having Department inspectors observe approximately 50 percent of all tank testing and 100 percent of all installations further allowed for the dissemination of the new policies from the Department to the contractors. Within a matter of only a few months, all contracting companies were aware of, and were actively implementing, the required policies. 

This practice has been in place since 2017. The Department was able to develop this practice within one year. Several stakeholders were involved in helping the Department develop this practice, including numerous local contracting companies that assist regulated facilities in maintaining compliance, other government agencies including the USEPA, the NYSDEC, tank manufacturers Containment Solutions, Xerxes Corporation, and Roth USA, telemetry system manufacturers Omntec and Veeder-Root, and trade organizations APE and PEI.

To best develop the licensing exams and construction/testing procedures, several manufacturers were contacted and provided the Department with training seminars. Over a three-month period, manufacturers of certain components such as belowground double walled fiberglass tanks, belowground double walled flexible piping, electronic tank monitoring, and primary and emergency tank venting visited the Department to provide training on their products to a staff of twelve people. This staff consisted of ten sanitarians and two public health engineers. These in-person training seminars lasted anywhere from an hour and a half to four hours. By providing the Department with this free training, manufacturers were able to demonstrate that their products would meet or exceed regulations. The Department expanded its knowledge of these products, which allowed it to develop more pertinent questions on the licensing exams and how to correctly develop construction/testing procedures for these products. This also gave the manufacturers better insight to the concerns the Department has with certain tank systems, allowing them to draw on these concerns when designing new products.

Numerous contractors also had a role in planning and implementing this new practice. The Department reached out to approximately 80 percent of all licensed contractors by calling and emailing them in an effort to solicit their opinions and learn from their experiences. Over half of the 88 contractors responded and   described certain procedures that they used while they worked on tank systems. By having a number of companies explain how they worked on tanks and the problems that they encountered, the Department was able to gain a better understanding of what procedures would work best. This understanding helped develop a standard set of procedures that could be used across a multitude of tank systems and situations. Various licensed contractors expressed their satisfaction with the practice stating that having all of the procedures standardized and explained in a concise way made the application and permitting process faster. The licensed contractors also were pleased with the licensing portion of the practice. These licensed contractors take pride in their work, and by having a license from the Department, it gives their clients a degree of reassurance that their contractor will do the correct work. This licensing requirement also prohibits non-licensed contractors from performing tank work. In the past, companies that didn't follow all of the required and recommended practices could underbid companies doing the correct work. Today, licensed contractors even inform the Department if they know of any unlicensed work that is ongoing. This unintended positive outcome demonstrates the sustainability of the practice as a large number of stakeholders have incentives to keep the practice in place.

Additionally, the NYSDEC provided the Department with assistance in planning this practice. Having delegated the authority to regulate petroleum tanks to the Department, the NYSDEC conducted a weeklong, in person conference with the Department, and several teleconferences thereafter. The NYSDEC provided the Department with guidance and information on standard procedures that they had seen across the state. By utilizing the experiences and knowledge of the NYSDEC, the Department was able to enact this practice faster than anticipated.

This practice is an internal program that is staffed by Department personnel. The personnel involved with this practice also carry out other duties such as plan review, enforcement, inspections, etc. The tank manufacturers, telemetry system manufacturers, trade organizations, and other government agencies provided the Department with training at no cost, therefore there was no start-up cost to train staff associated with this practice beyond the man-hours invested in the initial training and other aspects of the practice's development. Additionally, all of the manufacturers came to the Department, so there was no need to have staff travel. This is largely due to an effort on their part to demonstrate to the Department the integrity of their products, create networking connections, and initiate open lines of communication with the Department.

The Department received $9,700 in 2017, $7,775 in 2018, and $8,085 in 2019 as revenue from new licensing exams and renewals. While the goal of this practice is to assure that all petroleum tanks in Nassau County are installed, repaired, tested, and operated in a manner that will protect the public health and the sole source aquifer, this practice has been shown to be self-sustaining based upon the fees collected for licensing exams and renewals.

This initiative began with two main objectives in mind; develop a uniform procedure and requirements needed for third-party contractors to become officially qualified to conduct common work at petroleum bulk storage facilities including tank installation, tank removal, and tank system testing and to develop standard requirements for the contractors to follow when completing such work.

The Department was able to achieve these objectives through extensive staff training, and collaboration with other stakeholders. A staff of twelve people at the Department, ten sanitarians and two public health engineers, went through extensive training on the subject matter which included presentations and demonstrations by distributers, product certification training by tank and telemetry equipment manufacturers, seminars with the NYSDEC and the USEPA on petroleum tank regulations, and joint facility inspections with State inspectors.

A comprehensive set of examinations was developed that incorporated several manufacturers' guidelines, as well as industry best practice standards from well-respected and time-tested organizations, such as the PEI and the API. This ensures that those contractors installing, repairing, testing, and removing petroleum tanks in Nassau County are adequately trained and competent. Since the inception of the practice 10 new petroleum tank testers and 7 new petroleum tank installers/removers have been licensed by the Department. The Department has also processed the renewals of 23 petroleum tank testers and 60 petroleum tank installers/removers. Currently, the petroleum tank contractors have passed all the exams administered by the Department, and there has been no evidence that any tank work done in Nassau County has been done by an unlicensed contactor.  This shows that the petroleum tank contractors take this practice seriously and have learned how to properly transport, handle, and install tank systems, properly install, test, and maintain all electronic components, and understand all local regulations regarding petroleum tanks.

The Department also developed procedures that contractors follow while they are working on petroleum tanks. These procedures are augmented by Departmental inspections and documentation that the contractors must provide in order to verify that they are adhering to the proper procedures. Approximately 93 percent of all regulated tank work follows the procedures set forth by the Department. The other 7 percent required further review by Department staff and, ultimately, became compliant. If the procedures are not followed, the petroleum tank contractors must provide the Department with a valid reason as to why they deviated from the standard procedures. If the Department rejects their explanation, the petroleum tank contractors might have to restart portions of their project to ensure that they are following proper procedures. In the instances where the procedures are not followed, the facilities will fail to obtain a permit to operate. By not having a permit, that facility will lose money from not being open for business. If a facility chooses to operate without a permit, they will face significant fines and penalties from the Department, and possibly the USEPA. Therefore, it remains in everyone's best interest that the procedures developed by the Department are followed while petroleum tanks are being installed, repaired, tested, or removed.

Based on contractor feedback, in the future all requirements and forms will be made available on the Department's website in order to allow for a more expeditious application process. It is also beneficial to increase the pool of qualified contractors to as large as possible in hopes that competition will lead to higher quality work at a more competitive price point for the regulated facilities.

As previously stated, this practice had two main objectives. With these two objectives successfully met, the risk of petroleum discharging into the soil and groundwater has been substantially mitigated. This is evident base on several factors.

In the years prior to the implementation of this practice, an average of 32% of all PBS enforcement cases each year involved tank equipment deficiencies. After the first year of this practice, this was reduced to an average of only 9% of cases each year. Despite the regulation of hundreds of additional tanks at the start of Article XV, there has been a big drop-off in the amount of deficiencies related to tank equipment.

Additionally, the Department's acceptance rate of small PBS tanks installed without plans has increased. These tanks are installed by contractors and then inspected by the Department. In previous years, these tanks had an acceptance rate of 82.81% with the Department. The rejected tanks either had to be modified, moved, or removed entirely. Since this practice has been in place, all small tanks undergoing inspection have been approved. This shows that the quality of the installations and other tank modifications completed by contractors has greatly improved.

Finally, the data show that number of reported spills in Nassau County to the DEC is fewer than years prior, and fewer than what predictive models using historical trends would show for the years this practice has been in place. There was an average of 1113 reported spills per year in Nassau County in the 10 years prior to this practice. Based on the trend, there should have been approximately 969 reported spills per year during the years this practice was in place, yet there was an average of only 839 reported spills per year, with one year having the fewest number of reported spills in over 30 years. This is 15% fewer reported spills than what was expected. This evidence shows that this practiced improved the knowledge base and attitudes of all entities involved about how to properly install, maintain, and operate a safer facility resulting in fewer violations, better tank maintenance, and fewer petroleum discharges into the ground, thus better protecting the aquifer system from contamination.

This practice resulted in more competent, well-trained, and experienced contractors who work on PBS tanks systems. They know how to properly install, maintain, and remove tanks resulting in fewer violations, better tank maintenance, and fewer petroleum discharges into the soil groundwater. As a result of the practice, the aquifer system is better protected from potential contamination, thereby protecting the public through lowering the potential for adverse health effects from contaminants in their drinking water. It is expected that the implementation of the practice will also result in a reduction in long-term costs to the water suppliers in Nassau County incurred by the need to remove petroleum contaminants from the public water supply.

The Department has learned that the implementation of the practice provides an essential method of assuring that all petroleum tanks in Nassau County are installed, repaired, tested, and operated in a manner that will protect the public health by preventing the release of petroleum into the sole source aquifer.

The success of this practice was based heavily on providing clear and concise written guidance and then working with and meeting with the contractors in the industry to discuss and resolve any questions related to the practice.

There was no cost benefit analysis performed as it would be difficult to attempt to place a monetary cost on the value of this practice which helps protect the public health and the environment from the discharge of petroleum products into the sole source aquifer. The implementation of the practice is supported by the collection of fees for the initial testing and renewal of the licenses. The fees have been set at a point that directly covers any and all administrative cost involved in the review of applications and, ultimately, the issuing of the licenses themselves. Adjustments to these fees can be made in the future in order to compensate for a change in the administrative strains of this practice.

The stakeholders, predominantly the contractors themselves, have a direct incentive to ensure that this practice remains sustainable. As the NCPHO specifically states that those companies performing installation, removal and testing work must be properly licensed, those companies that would like to remain competitive in this particular niche of the industry have a need to remain licensed. Additionally, many of the contractors have stated that the licensing requirements keep contractors who cut costs by cutting corners out of the market. As almost all licensed contractors comply with the tank procedures, they feel that this helps keep the prices relatively stable across the County.

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