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s: <br /> 4) Of the estimated 78,000 HLTS, very few cases of HLT leaks to <br /> ground water have been reported, and only five that reached <br /> groundwater potentially affected a drinking water supply <br /> 5) Most local implementing agencies lack resources to regulate this <br /> segment of the UST universe, given the many demands on their <br /> fee-supported programs. <br /> 6) The public health and environmental benefits of complying with <br /> the UST leak prevention and corrective action requirements do <br /> not appear to Justify the expense to the regulated community. <br /> 7) Most HLTS store a much smaller liquid volume of fluid than <br /> other petroleum USTs. Added to this is the fact that when a <br /> significant leak occurs, the equipment stops working. <br /> Therefore, the likelihood of sizeable HLT leaks relative to fuel <br /> tank leaks is much lower. <br /> . 8) Regional Water Quality Control Boards retain their authority <br /> under the Water Code to require cleanup of HLT leaks where <br /> beneficial uses of water are adversely affected or threatened. <br /> B. BEST MANAGEMENT PRACTICES FOR HLTS <br /> The following three management practices are recommended to the <br /> DIR and the HLT industry to encourage leak prevention and prompt, <br /> appropriate response to leaks that do occur. <br /> 1) Encourage industry to emphasize the need to repair systems <br /> that are found to leak small amounts of fluid continually <br /> 2) Encourage the use of alternative fluids that do not contain any <br /> hazardous materials. For example, Mobil Oil Company has <br /> developed a vegetable-based hydraulic fluid that they think is <br /> environmentally friendly. Testing of this product, in its virgin <br /> and used states, is under way, using California standards for <br /> hazardous waste and threat to water quality. <br /> 3) Encourage industry to develop and install secondary <br /> containment on new HLTS systems, where feasible The <br /> feasibility of retrofitting existing HLT systems as part of a major <br /> overhaul or repair should also be investigated. <br />