Overview of the EPA’s 2015 Changes to UST Regulations

Here are Some of the Significant Changes to 40 CFR part 280

The EPA’s 2015 Final Regulations for USTs changes certain portions of the 1988 underground storage tank technical regulation in 40 CFR part 280. The changes establish federal requirements that are similar to key portions of the Energy Policy Act of 2005. In addition, EPA added new operation and maintenance requirements and addressed UST systems deferred in the 1988 UST regulation. Some major changes include:

  • Requiring secondary containment for new and replaced tanks and piping
  • Requiring operator training
  • Requiring periodic operation and maintenance requirements, mandatory equipment inspections/testing that is focused on the parts most likely to leak: 30-day walk through (look at spill prevention equipment and release detection equipment), annual testing/inspections (containment sumps and hand held release detection, release detection equipment testing – including LLDs testing) and triennial testing/inspections (spill prevention equipment testing, overfill prevention equipment inspections, containment sumps used for piping interstitial monitoring)
  • Requiring proof of UST system compatibility with certain fuels and biofuels
  • Including emergency power generator tanks (now requires owners and operators to perform release detection)
  • Making technical corrections to disregard older technologies and recognize new ones like clad and jacketed tanks, non-corrodible piping, continuous in-tank leak detection and statistical inventory reconciliation (SIR)
  • No more ball floats/flow restrictors in vent lines as a standalone method of overfill prevention
  • Close tanks using internal lining as the sole method of corrosion protection when the lining fails
  • Requiring Testing 30 Days after Repairs to spill or overfill equipment and secondary containment areas
  • State programs need to be re-approved

Contact us with questions you have about the new regulations and how they’ll affect you/your company.

How much time do you have to implement these changes?

There’s still time while we wait for them to be published in the Federal Register. Once they are, they will be required to be implemented at different time increments:

  • some will be required quickly – Secondary Containment (180 days), Elimination of ball floats/flow restrictors in vent lines as standalone overfill prevention (immediately) Close tanks using internal lining as the sole method of corrosion protection when the lining fails (immediately), 30 day Notification of UST Ownership Change (immediately) proof of compatibility of UST and product when storing >10% ethanol or >20% biodiesel (immediately), Testing 30 Days after Repairs to spill or overfill equipment and secondary containment areas (immediately)
  • some in a year, and
  • some in three years – Operator Training, 30-Day Walkthrough Inspections, Annual Inspections of Containment Sumps and Hand Held Release Detection equipment, Spill Prevention Testing, Overfill Prevention Equipment Inspection, Containment Sumps used for Piping interstitial monitoring, Emergency Generators require release detection, state programs have to be re-approved

More detailed blog entries will address each of these issues, and you can ask us any questions in the meantime. We have over 50 years experience with fueling systems – USTs, ASTs and piping and have a good understanding of how the regulations will be implemented and what that means to the UST owner/operators. Here are some related previous blogs: