Are your Storage Tank Systems in compliance?

The new 2015 Federal EPA Regulations go into effect October 13, 2018

Major Revisions to UST Regulations

July 15, 2015, the Federal EPA announced revisions to the 1998 Underground Storage Tank (UST) regulations.  You must comply with the new revisions by October 13, 2018. The revisions will help better detect UST releases and provide a minimum standard to all USTs in the United States and Indian country.  State Program Approval (SPA) also updated the SPA requirements to incorporate the new revisions.

Currently 38 SPA states plus the District of Columbia and Puerto Rico have a SPA and have three years to reapply in order to retain their SPA status.  Owners and operators with UST systems located in a state with a SPA may have different requirements from the federal UST regulation.  Visit your state’s UST regulation website for details.

If your UST systems are located in a state without SPA, both the federal and state requirements apply.

If your UST systems are located in Indian country, the federal UST regulation apply.

 

The newly added/revised operation and maintenance requirements include:

Revised UST Regulation Overview

The deadline is drawing near! This is an overview of the new EPA UST regulation beginning no later than October 13, 2018.  Some of the regulations may already be required in your state. For specific details regarding the new regulations, please visit the EPA site or the specific state’s website where the UST is located.  Indian country is not regulated by SPA.  Owners and Operators of UST systems in Indian country must follow the Federal EPA requirements.

Release Detection
  • Tanks and piping installed or replaced after April 11, 2016 must have secondary containment with interstitial monitoring, except for piping that is considered safe suction piping.
  • Keep records demonstrating compatibility of release detection components if regulated substances containing greater than 10 percent ethanol or greater than 20 percent biodiesel or other regulated substance identified by the implementing agency.
  • Keep results for annual ATG system operation tests for at least three (3) years.
  • Keep periodic walkthrough inspection records for at least one year.
  • Test any repaired secondary containment areas for tightness within 30 days after repair.
  • Keep annual release detection system operation test results for at least three (3) years.
  • Keep records of the walkthrough inspection for at least three (3) years for containment sump and secondary containment equipment inspections that are part of the periodic walkthrough inspection.
  • Test all containment sumps used for piping interstitial monitoring every three (3) years for liquid tightness or use a double-walled containment sump with annual interstitial monitoring.
  • For containment sump and secondary containment equipment inspections that are part of the periodic walkthrough inspection requirement, keep records of the walkthrough inspection for at least one year.
  • For containment sumps used for interstitial monitoring of piping, keep records of containment sump testing for three years or keep documentation showing the containment sump is double-walled and the integrity of both walls is periodically monitored for as long as containment sump testing is not performed.
  • Keep records demonstrating compatibility for as long as the UST system stores the regulated substance if the regulated substances stored contains greater than 10 percent ethanol or greater than 20 percent biodiesel or any other regulated substance identified by the implementing agency.
  • The temporary method combining monthly inventory control with periodic tank tightness testing may no longer be used after April 11, 2026 because tanks and piping installed or replaced after April 11, 2016 must have secondary containment and interstitial monitoring.
  • The temporary method combining manual tank gauging with periodic tank tightness testing may no longer be used after April 11, 2016 because tank and piping installed or replaced after 11, 2016 must have secondary containment and interstitial monitoring.

No Later Than October 13, 2018

  • Conduct first annual test of release detection equipment for proper operation.
  • Conduct first periodic walkthrough inspection of release detection equipment.
  • Demonstrate proper installation and performance trough a site assessment if groundwater or vapor monitoring is used for release detection.
  • Inspect and test the Automatic Tank Gauge System (ATG) every year.
  • Begin performing periodic walkthrough inspections
  • Must have designated and trained operators.
  • Begin inspecting and testing release detection system every year.
  • Begin testing all containment sumps used for piping interstitial monitoring every three years for liquid tightness or use double-walled containment sump with annual interstitial monitoring.
  • Keep results from annual release detection system operation tests for at least three (3) years.
  • Demonstrate proper installation and performance through a site assessment if vapor monitoring is used for release detection.
  • If ground water monitoring is used for release detection, proper installation and performance must be demonstrated through a site assessment.  A site assessment must be maintained for as long as the groundwater monitoring is used for release detection at the facility.
  • Keep results for annual release detection system operation test for at least three years.
  • Demonstrate proper installation and performance through a site assessment if groundwater is used for monitoring release detection.
Spill and Overfill Protection
  • Operability testing of spill buckets and inspections of overfill prevention equipment once every three (3) years.
  • Test or inspect, as appropriate, equipment within 30 days after spill or overfill prevention equipment repairs.
  • Keep records of spill bucket testing for three (3) years or keep documentation showing the spill bucket is double-walled and the integrity of both walls is periodically monitored for as long as spill bucket testing is not performed.
  • Keep record of periodic walkthrough inspection for one year.
  • Keep delivery records for one year if walkthrough inspections of spill bucket are less frequent than every 30 days.
  • Keep records demonstrating compatibility of all UST system components in contact with the regulated substance, including spill buckets, for as long as the UST system stores the regulated substance if regulated substance stored contains greater than 10 percent ethanol or greater than 20 percent biodiesel (or any other regulated substance identified by the implementing agency).
  • Ball float valves may not be installed or replaced for use as overfill protection after October 13, 2015.
  • Maintain all records of shutoff devices inspections for three (3) years.
  • Keep records demonstrating compatibility of all UST system components in contact with the regulated substance, including overfill prevention equipment, for as long as the UST system stores the regulated substance if regulated substance stored contains greater than 10 percent ethanol or greater than 20 percent biodiesel (or any other regulated substance identified by the implementing agency).

No Later Than October 13, 2018

  • Conduct first 30 day walkthrough inspection.  If deliveries received less frequently than every 30 days, spill bucket may be checked before each delivery.
  • Conduct spill bucket test at least once every three (3) years.
  • Inspect overfill prevention equipment at least once every three (3) years.
Corrosion Protection
  • Owners and operators must permanently close tanks using internal lining as the sole method of corrosion protection, if the internal lining fails the periodic inspection and cannot be repaired according to a code of practice.
Walkthrough Inspections
No Later Than October 13, 2018
  • Must conduct first walkthrough inspection.  If UST system receives deliveries at intervals greater that 30 days, spill prevention equipment may be checked prior to each delivery.

Every 30 Days

  • Check spill prevention equipment for damage and remove liquid or debris.
  • Check and remove obstructions in the fill pipe.
  • Check fill cap to ensure it is securely on the fill pipe.
  • For double-walled spill prevention equipment with interstitial monitoring, check for leak in the interstitial area.
  • Check release detection equipment to ensure it is operating with no alarms or unusual operating conditions present.  Release detection equipment in containment sumps do not have to be checked.  The equipment in this ares is tested annually.

Annually

  • Check containment sumps for damage and leaks to the containment area or releases to the environment.
  • Remove liquid in contained sumps or debris.
  • For double-walled containment sumps with interstitial monitoring, check for leaks in the interstitial area.
  • Check hand-held release detection equipment, such as groundwater, bailers and tank gauge sticks, for operability and serviceability.

 

How can JMM Help?

We know storage tank systems; from managing alarms to improving the manual inspection process.  JMM has a solution that will help keep your tanks compliant and free up time for you to focus on other aspects of your business.

Are you ready for the new EPA Underground Storage Tank Regulations?

Have questions? We are here to help!

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