new storage tank rules & ust requirements storage tank rulesskogman...• new and replaced...
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New Storage Tank Rules & UST Requirements
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Overview
• Brief Overview of the UST Regulation• Summary of State Approval Program• Review Key Requirements
UST Regulations - So why is a 2015 Rule Important Today?• EPA published technical requirements for USTs containing
petroleum or hazardous substances in 1988 - 40CFR Part 280, 281 and 282-50 through 282-105
• In 2015, EPA published revisions to the UST regulation and the state program approval regulation
• The 2015 UST regulation changed certain portions of the 1988 underground storage tank technical regulation in 40 CFR Part 280. The changes established federal requirements that are similar to key portions of the Energy Policy Act of 2005.
State Approval Program
• 38 states plus the District of Columbia and Puerto Rico currently have a State Approval. Owners and operators in these states must continue to follow their state requirements until the state changes its requirements or until the state’s SPA status changes.
• 16 states and territories do not have a State Approval Program. They must meet the federal requirements according to the schedule in the 2015 UST regulation in addition to following their state requirements.
as of March of 2019
State and Territorial
Compliance Deadlines
StateRegulationEffectiveDate Compliance
Deadlines StateRegulationEffectiveDate Compliance
DeadlinesAlabama 12/2017 12/2020 Missouri 5/2017 1/2020Alaska 9/2018 10/2018 Montana 10/2018 10/2021AmericanSamoa NebraskaArizona Nevada 12/2017 10/2018Arkansas 9/2018 10/2018 NewHampshire 10/2018 10/2021California 10/2018 10/2018 NewJersey 1/2018 10/2018Colorado 1/2017 1/2020 NewMexico 7/2018 7/2021 MarianaIslands 4/2016 10/2018 NewYorkConnecticut NorthCarolina 1/2017 6/2020DistrictofColumbia
NorthDakota 4/2018 4/2021
Delaware Ohio 9/2017 10/2018Florida 1/2017 10/2018 Oklahoma 9/2017 10/2018Georgia 6/2017 12/2020 Oregon 6/2018 10/2020Guam Pennsylvania 12/2018 12/2021Hawaii 7/2018 7/2021 PuertoRico 1/2018 7/2018Idaho 3/2017 10/2021 RhodeIsland 11/2018 10/2021Illinois 6/2018 10/2018 SouthCarolina 5/2017 5/2020Indiana 6/2018 6/2021 SouthDakota 6/2018 10/2021Iowa Tennessee 10/2018 10/2021Kansas Texas 5/2018 1/2021Kentucky Utah 1/2017 10/2018 Louisiana 9/2018 9/2021 Vermont 9/2018 9/2020Maine 9/2018 9/2018 Virginia 1/2018 1/2021Maryland VirginIslandsMassachusetts Washington 10/2018 10/2020 or 10/2021Michigan 11/2018 10/2018 WestVirginia 6/2018 10/2018Minnesota WisconsinMississippi 10/2018 10/2021 Wyoming 6/2018 10/2018
Important Changes
• Added secondary containment requirements for new and replaced tanks and piping
• Added operator training requirements• Added periodic operation and maintenance requirements for UST
systems• Added requirements to ensure UST system compatibility before
storing biofuel blends• Removed past deferrals for emergency generator tanks, field
constructed tanks, and airport hydrant systems• Updated codes of practice• Made editorial and technical corrections
Added Secondary Containment Requirements
• You must install secondarily contained tanks and piping when installing or replacing tanks and piping. You must use interstitial monitoring as release detection for these new or replaced tanks and piping. Automatic line leak detectors are still required for new and replaced pressurized piping
• You must install under-dispenser containment for all new dispenser systems
Added Operator Training Requirements
• EPA established minimum training requirements for designated Class A, Class B, and Class C operators. New Class A and Class B operators must be trained within 30 days of assuming duties. Class C operators must be trained before assuming duties
Periodic Operation & Maintenance Requirements
• Spill prevention equipment• Containment sumps• Release detection equipment
You must conduct walkthrough inspections!
Examples for importance of scheduled walkthroughs: no records for four months to show compliance. It was simple reason but no one was conducting the walkthroughs
Periodic Operation & Maintenance Requirements: Overfill Prevention Equipment• Overfill Prevention Equipment Inspections Every Three Years• Document, Document, Document!
Periodic Operation & Maintenance Requirements - Spill Bucket Testing• Spill Bucket Testing Every Three Years• Or double walled and inspected with walkthrough inspections
Periodic Operation & Maintenance Requirements -Secondary Containment Testing• Secondary Containment Testing Every Three Years• Or double walled and inspected with walkthrough inspections
Periodic Operation & Maintenance Requirements - Annual Inspections• Release Detection Equipment Inspections Every Year
Past Deferrals - Emergency Generators
• USTs for Emergency Generators• Must meet release detection
requirement on tanks and piping
Past Deferrals - Field Constructed Tanks and Airport Hydrant Systems• UST systems for field-constructed tanks and airport hydrant fuel
distribution systems are now regulated• New and replaced piping associated with airport hydrant systems
does not have to be secondarily contained and• New and replaced piping associated with field-constructed tanks
greater than 50,000 gallons does not have to be secondarily contained.
• field-constructed tanks with a capacity greater than 50,000 gallons must meet either the release detection requirements in subpart D (except groundwater monitoring and vapor monitoring must be combined with inventory control as described below) or use one or a combination of alternative methods
Summary
• 2015 UST Regulations are in effect• Compliance dates vary by state• Include spill prevention testing, overfill prevention inspection, and
periodic walkthrough inspections
