New Underground Storage Tanks Rules-What You Need to KnowNovember 11, 2015
The U.S. Environmental Protection Agency has recently issued the 2015 revised underground storage tank (UST) regulation and the 2015 state program approval regulation. The revisions strengthen the 1988 federal underground storage tank (UST) regulations by increasing emphasis on properly operating and maintaining UST equipment. According to the EPA, the revisions are intended to help prevent and detect UST leaks and releases, the leading source of groundwater contamination. For our clients, including those in both NY and NJ, the revised federal regulations will have a significant impact for anyone owning and/or operating a UST.
Why did the EPA update the regulations?
This is the first major revision to the federal UST regulations since created in 1988. Since 1988, technology has advanced and improved significantly. Today, there are better methods available for installing, using and keeping track of USTs and the materials they store.
What was updated?
A number of areas of the regulations were evaluated and revised as needed. See updates below.
UST owners/operators shall designate at least one individual to be trained. Implementation: Within 3 Years
Secondary Containment & Interstitial Monitoring
The rule expands the existing secondary containment requirements in the EPAct and requires that owners/operators install secondary containment and interstitial monitoring for all new and replacement USTs, including petroleum USTs, and new and replacement piping, as well as under-dispenser containment for new dispenser systems. For piping, secondary containment and interstitial monitoring must be provided for the entire piping run when 50 percent or more of the piping is replaced. Implementation: 180 Days
Operation and Maintenance
UST owners/operators will face significantly-expanded operation and maintenance (O&M) requirements. Implementation: Within 3 Years
- Walkthrough inspections every 30 days, including visual checks for leaks, checking interstitial areas, removal of obstructions in fill pipes, and checking/testing release detection equipment.
- Annual inspections of containment sumps, removal of liquids and debris, and checking tank gauge sticks for service ability.
- Three year testing of overfill equipment and containment sumps.
- Annual testing on all electronic and mechanical components of the release detection
equipment (gauges, probes, sensors, controllers, etc.).
The EPA has eliminated previously-deferred UST systems, including those for emergency power generators, field-constructed tanks, and airport hydrant systems. Owners/Operators of these systems shall now meet the release detection requirements within three years.
When is compliance needed?
Compliance with the new regulations will begin immediately. The regulations for flow restrictors in vent lines, internal lining, notification, and compatibility should be addressed this year. Other requirements won’t be regulated until three years from now. Most state regulations will also take up to three years. Owners and operators will need to make the necessary changes for safety and environmental compliance.
Additional details can be found on the EPA’s comparison table of 1988 versus the new 2015 regulations.