Getting The Most Out Of Release Detection Testing

National Tanks Conference 2015

Phoenix, Arizona

September 15, 2015

 

 

 

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Why did EPA make this particular change to the UST regulation?

• No specifics provided in the 1988 UST regulation on minimum O&M requirements to ensure adequate operation and maintenance

• Wide variation of O&M requirements by manufacturers, even among similar types of equipment

• Many manufacturers specified recommended O&M testing, few required testing

• Level playing field by establishing core testing requirements

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What are the important dates regarding release detection testing?

• October 13, 2015 – The effective date of the 2015 revised UST regulation

• October 13, 2018 – The date by which owners and operators must conduct their first release detection equipment tests

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What do these new requirements mean for owners and operators?

• In states without state program approval (SPA) and in Indian country– the new requirements will apply according to time frames

specified in the 2015 UST regulation

• In states with SPA– none of the new requirements will apply until the state

adopts the federal requirements or if a state does not adopt the requirements, until EPA withdraws approval of SPA for that state. Owners and operators in states with SPA must continue to meet the state UST requirements

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States with Approved UST Programs (SPA States)

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New Operation and Maintenance Requirements

• Annual release detection equipment testing to make sure release detection equipment is operating properly

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New Operation and Maintenance Requirements

§280.40 (a)(3) Electronic and mechanical components are tested for proper operation, in accordance with one of the following:• Manufacturer’s instructions;• A code of practice; or• Requirements determined by the implementing agency to be no

less protective of human health and the environment

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New Operation and Maintenance Requirements

At a minimum, as applicable to the facility, tests must cover the following components and criteria;• Automatic tank gauge (ATG) systems and other

controllers– Verify system configuration– Test alarm– Test battery back-up

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New Operation and Maintenance Requirements

• Probes and sensors– Inspect for residual build-up– Ensure floats move freely– Ensure shaft is not damaged– Ensure cables are free of kinks and breaks– Test alarm operability and communication with controller

• Automatic line leak detector (ALLD)– Simulate leak which determines capability to detect a leak

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New Operation and Maintenance Requirements

• Vacuum pumps and pressure gauges– Ensure proper communication with sensors and controller

• Handheld electronic sampling equipment associated with vapor and groundwater monitoring– Ensure proper operation

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New Operation and Maintenance Requirements

Records Maintenance• Keep results of annual testing for three years• At minimum, results must:

– List each component tested– Indicate whether each component tested meets criteria specified in the

regulation or needed to have corrective action taken– Describe any action taken to correct an issue

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Additional Information

• OUST Website on Revised Regulationshttp://www.epa.gov/oust/fedlaws/revregs.html

• OUST Release Detection ContactTim Smith at smith.timr@epa.gov or

703-603-7158

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