2015 UST Rules to Begin Full Implementation

September 24, 2018

The 2015 Revised Underground Storage Tank (UST) Regulations will begin full implementation in some states and 16 non-program approved states on October 13, 2018.  The revisions strengthen the 1988 federal UST regulations by increasing emphasis on properly operating and maintaining UST equipment. The revisions will help prevent and detect UST releases, which are a leading source of groundwater contamination.

In addition, EPA added new operation and maintenance requirements and addressed UST systems deferred in the 1988 UST regulation. Below is a summary of five key operational changes:

  • Overfill Prevention Equipment Inspections Overfill protection equipment must be tested and operationally inspected once every three years, and the owner must demonstrate that the equipment operates properly. In addition, owners must inspect automatic shut-off devices, flow restrictors, and alarms.
  • Spill Bucket Testing Spill prevention equipment must be tested once every three years. The spill bucket must be liquid tight and in proper operational condition.
  • Sumps and Under Dispenser Containment (UDC) Integrity Testing Once every three years, tank owners must test all sumps used for interstitial monitoring, and the test must show that the equipment is liquid tight using either vacuum, pressure, or liquid testing methods.  If you have double-walled sumps and/or automatic alarm shut-off sensors, your requirements may be different.
  • Sumps, UDC and Release Detection Equipment Inspection Visual Once a year, tank owners must visually check the sumps for damage, releases, and leaks.  Also probes and sensor tests must be conducted annually to ensure they are in operational condition.
  • Monthly Spill Bucket and Release Detection Walk Through Inspections Every 30 days, tank owners must conduct monthly UST system walkthrough inspections for spill buckets, fill caps, release detection equipment, alarm conditions, check/remove obstructions in fill pipe, and check interstice of double-walled spill buckets (if present).

Several resources are available through EPA and your state websites, such as guidance, summaries and forms.  EPA’s resources can be found here, https://www.epa.gov/ust/revising-underground-storage-tank-regulations-revisions-existing-requirements-and-new#compliance.

Be sure to go to the EPA and your state website and regulators for more specific information about the requirements in your state. If you need additional information or have any questions, please feel free to reach out to me at todd.perry@ppmco.com or Zane Hood at zane.hood@ppmco.com.

 

Contributed by L. Todd Perry, Principal