VTCA Aggregate Producer Members account for 91% of all metal/nonmetal mineral production in the Commonwealth. Amendments to the General Permit for Nonmetallic Mineral Mining [9 VAC 5-510] (NMPGP) will have a widespread impact on Virginia’s aggregate producers.

As identified within section 3.3 of the UST guidance document, 

"...Containment sumps used for interstitial monitoring installed on or after January 1, 2018 must be tightness

tested at the time of installation and every three years thereafter unless the tanks are temporarily closed and empty. All other containment sumps used for interstitial monitoring must be tightness tested prior to January 1, 2021 and every three years thereafter. Containment sumps that were installed prior to September 15, 2010 that are not used for interstitial monitoring do not need to be tested every three years..."

This language essentially states that those older tanks that have necessary precautions installed to assist in detecting a leak, i.e. installed a sump fill sensor, need to perform hydrostatic testing on their sump while older tanks who have no additional interstitial leak detection equipment are not required to perform hydrostatic testing at all.  This seems incorrect - why wouldn’t facilities simply remove their sensors, amend their UST notification, and thus eliminate their need to perform hydrostatic testing every 3 years?  This guidance is confusing and seems counterintuitive.  Please confirm this guidance is correct.