Underground Storage Tank Regulations – New Inspections Required by October 13, 2018
The EPA Underground Storage Tank Regulations (40 CFR Part 280) were revised in 2015 which require new testing and maintenance inspections for all federally regulated USTs.
By October 13, 2018, all operators of federally regulated USTs (includes motor fuels such as gasoline and diesel fuel) are required to perform the following inspections:
Spill Prevention Equipment Annual Operability Testing
Overfill Prevention Equipment Inspections
Containment Sump Testing for Sumps Used for Piping Interstitial Monitoring
Release Detection Equipment Testing
Monthly Walkthrough Inspections (by Owner/operator)
Many of these inspections may require a specialty tank contractor to complete, so if you have not already, now is a good time to get these scheduled before their schedules fill up.
Please also note that the UST Operator Training Requirements are also currently in effect which requires all federally regulated USTs to have a trained and certified UST operator designated.Several states, including New York, also have operator training requirements for state-only regulated tanks.
Several excellent EPA resources include:
EPA Implementation Time Frames for 2015 Underground Storage Tank Requirements Brochure:
EPA Musts for USTs 2015: https://www.epa.gov/sites/production/files/2015-12/documents/musts_for_usts.pdf
EPA Release Detection Guidance Straight Talk on Tanks 2016: https://www.epa.gov/sites/production/files/2016-05/documents/stot_5-2-16_final_508.pdf
These requirements are not the same as the NYSDEC petroleum Bulk Storage Regulations that were also revised on 2015, meaning that New York facilities are required to comply with these federal requirements in addition to the state level regulations. Other states that have federally approved UST programs are required to update their regulations to be at least as stringent as the EPA regulations revised in 2015.
Please contact Jeffrey J. Reed, P.E., Sr. Managing Engineer at Barton & Loguidice, at (315) 457-5200 or firstname.lastname@example.org for assistance navigating the new EPA Underground Storage Tank Regulation requirements.