2015 Additions to Federal UST Regulations

Are you in compliance with
the new EPA requirements?

In 2015, EPA issued major additions to the landmark 1988 federal UST regulations. The primary emphasis of the new rules was on the proper operation and maintenance of UST equipment, and you must be in full compliance by October of 2018.

In addition, an expansion of the geographic reach of the regulations ensures that all USTs in the US, including in Indian Country, are now required to meet the same minimum standards.

The new rules pertaining to operations and maintenance requirements
include these major additions:

  • Secondary containment requirements for new and replaced tanks and piping
  • Operator training requirements
  • Periodic operation and maintenance requirements for UST systems
  • Requirements to ensure UST system compatibility before storing certain biofuel blends

Notably, the 2015 EPA rules also removed the previous deferrals for emergency generator tanks, field constructed tanks and airport hydrant systems as EPA determined that the technology now exists for
economical testing of tanks and fuel lines in these categories.

The specific requirements in these new regulations can be found here on our website.

When do you have to comply?

The timing of compliance depends upon the state in which the tanks are operated. The new regulation made updates in the area of the 1988 regs pertaining to the State Program Approval (SPA) process. SPA is the process through which individual states can set their own criteria for UST programs, so long as they are at least as stringent as EPA's regulations.

Currently, 38 states, plus District of Columbia and Puerto Rico have approved SPA's in place with EPA and have three years to reapply in order to retain their SPA status. Operators in these states must continue to comply with their existing state requirements until the state changes its requirements or the state's SPA status changes.

There are 16 states and territories currently without Federal SPA status. Operators in these states must meet the federal EPA compliance timetable. Indian Country UST operators must meet the federal EPA requirement, as SPA does not apply to USTs in Indian Country.

Tanknology can help you assess the
applicability of these new regulations
to your facilities and determine
your compliance dates.
Contact us via this web form  
or call 1-800-964-1250.

Request a quote or more information for your site.

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At A Glance
Here are some key elements of the new EPA UST regulations.

Some items may already be required in your state. If that is the case, the existing requirement supersedes this schedule.

Starting 10/13/2015
Starting 4/11/2016
  • Secondary containment and interstitial monitoring required for new installations
  • Under dispenser containment (UDC) sumps required when changing dispensers
  • Line leak detectors required on new pressurized lines (sump sensors alone don't qualify
Starting 10/13/2018
  • Class A, B and C UST operators trained, including all designated Class Cs
  • Class C employee must be on-site
  • Train new Class A/Bs within 30 days
  • UDCs/sumps must be liquid tight
  • Upgrade to double wall piping if 50+% of single wall pipe run is replaced
  • Keep testing/inspection records for at least 3 years
  • Must respond to all sump alarms
  • Deferred field constructed USTs and airport hydrant systems fully regulated
  • Every 30 Days

  • Must perform walkthrough inspections (recommend using
    PEI RP 900)
  • Must look for water in tanks
  • Must do release detection for emergency generators
  • Must do release detection for field constructed USTs and airport hydrant systems
  • SIR results due within
    the month tested
  • Every Year

  • Inspect sumps
  • Check handheld release detection equipment
  • Function test release detection equipment (probes, sensors, floats, tank gauges, alarms, vacuum pump and gauges, etc.)
  • Function test all electronic line leak detectors for 3 GPH plus 0.2 and 0.1 GPH if used for compliance
  • Every Three Years

  • Hydrostatic or vacuum test spill buckets (Unless double-walled and periodically monitored and only applies if utilizing interstitial monitoring. A more restrictive regulation applies in Florida.)
  • Inspect overfill equipment (flapper, ball valve, high level alarm)
  • Hydrostatic test piping sumps

Upcoming Events

CAL-CUPA  February 5-8, San Francisco, CA
WPMA  February 20-22, Las Vegas, NV
PACE  February 22-23, Kansas City, MO
SE-PETRO  March 7-8, Myrtle Beach, SC
M-PACT  March 13-15, Indianapolis, IN

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