Detailed Regulations: 2015 EPA UST Updates

Tanknology technician conducts part of a secondary containment inspection

Secondary Containment Requirements
for New and Replaced Tanks and Piping

Secondary Containment

Beginning on April 11, 2016 owners and operators must install secondarily contained tanks and piping when installing or replacing tanks and piping. Owners and operators 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.

  • Secondary containment means the tank and piping have an inner and outer barrier with an interstitial space that is monitored for leaks and includes containment sumps when those sumps are used for interstitial monitoring of the piping.
  • Replaced for a tank means to remove a tank and install another tank.
  • Replaced for piping means to remove 50 percent or more of piping and install other piping. Piping does not include the connectors used to connect the piping to the tank or dispenser. This definition applies to each piping run connected to a single tank. Owners and operators of tanks with multiple piping runs must apply this definition independently to each piping run.
  • Owners and operators do not have to meet the secondary containment requirement for new or replaced piping under the following conditions:
    • piping is European or safe suction piping
    • piping is associated with airport hydrant systems
    • piping is associated with field-constructed tanks greater than 50,000 gallons in size

Under-Dispenser Containment (UDC)

Beginning on April 11, 2016 owners and operators must install under-dispenser containment for all new dispenser systems.

  • A dispenser system is considered new when both the dispenser and the equipment needed to connect the dispenser to the UST system are installed at an UST facility. Examples of equipment needed to connect the dispenser to the UST system include check valves, shear valves, unburied risers, flexible connectors or other transitional components underneath the dispenser which connect the dispenser to the underground piping.
  • Under-dispenser containment or UDC is containment underneath the dispenser system designed to prevent leaks from the dispenser and piping within or above the UDC from reaching soil or groundwater. UDC must be liquid-tight on its sides, bottom, and at any penetrations. It must allow for visual inspection and access to the contained components or be periodically monitored for leaks from the dispenser system.
  • A dispenser is the equipment located aboveground that dispenser regulated substances from the UST system.
  • A dispenser system includes the dispenser and the equipment necessary to connect the dispenser to the UST system.

Operator Training Requirements

EPA established the following minimum training requirements for designated Class A, Class B, and Class C operators. Operators must be trained by October 13, 2018. After this date, 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.

Class A Operators

Each designated Class A operator must either be trained or pass a comparable examination that provides general knowledge of the following requirements:

  • Spill and overfill prevention
  • Release detection
  • Corrosion protection
  • Emergency response
  • Product and equipment compatibility and demonstration
  • Financial responsibility
  • Notification and storage tank registration
  • Temporary and permanent closure
  • Related reporting, recordkeeping, testing, and inspections
  • Environmental and regulatory consequences of releases
  • Training requirements for Class B and Class C operators

At a minimum, the training program must evaluate Class A operators to determine if they have the knowledge and skills to make informed decisions regarding compliance and determine whether appropriate individuals are fulfilling the operation, maintenance, and recordkeeping requirements for UST systems.

Class B Operators

Each designated Class B operator must either be trained or pass an examination about the regulatory requirements and typical equipment used at UST facilities; or site-specific requirements which address only the regulatory requirements and equipment specific to the facility:

  • Operation and maintenance
  • Spill and overfill prevention
  • Release detection and related reporting
  • Corrosion protection
  • Emergency response
  • Product and equipment compatibility and demonstration
  • Reporting, recordkeeping, testing, and inspections
  • Environmental and regulatory consequences of releases
  • Training requirements for Class C operators

At a minimum, the training program must evaluate Class B operators to determine if they have the knowledge and skills to implement applicable UST regulatory requirements on the components of either: typical UST systems or site-specific equipment used at their UST facility.

Class C operators

Each designated Class C operator must either: be trained by a Class A or Class B operator; complete a training program; or pass a comparable examination. The training option chosen must teach or evaluate the Class C operator's knowledge to take appropriate actions (including notifying appropriate authorities) in response to emergencies or alarms caused by spills or releases resulting from the operation of the UST system.

Training program

This term covers the minimum requirements listed for the classes of operators described above and includes an evaluation through testing, a practical demonstration, or another approach acceptable to the implementing agency. A comparable examination must, at a minimum, test the knowledge of the Class A, Class B, or Class C operators in accordance with the requirements for each class listed above.

Retraining

Class A and B operators at UST systems determined to be out of compliance must be retrained within 30 days of the determination of noncompliance. For retraining, the training program or comparable examination must be developed or administered by an independent organization, the implementing agency, or a recognized authority. Retraining must, at a minimum, cover those areas found to be out of compliance. Retraining is not required if:

  • Class A and B operators take annual refresher training.
  • The implementing agency waives retraining.

Records

Owners and operators must maintain a record identifying all currently designated operators at the facility. The record must include the operator name, operator class, date assumed duties, and training or retraining dates. In addition, owners and operators must have records verifying completion of training or retraining. This record must have the trainee name, date trained, operator training class completed, name of training company or examiner, and the training company's name, address and telephone number.

Site inspection includes photography

Periodic Operation and Maintenance Requirements
for UST Systems

Walkthrough Inspections

Beginning on October 13, 2018 owners and operators must conduct walkthrough inspections at their UST facility. The walkthrough inspection must meet one of the following:

OPTION 1: Every 30 days (except spill prevention equipment at UST systems receiving deliveries at intervals greater than every 30 days may be checked prior to each delivery), check your spill prevention equipment and release detection equipment. Annually, check your containment sumps and any hand held release detection equipment. When conducting the walkthrough inspection, check the following:

Spill prevention equipment
  • Check for damage
  • Remove any liquid or debris
  • Check for and remove any obstructions in the fill pipe
  • Check the fill cap to make sure it is securely on the fill pipe
  • Double walled spill prevention equipment with interstitial monitoring check for a leak in the interstitial area
Release detection equipment
  • Ensure it is operating with no alarms or other unusual operating conditions present
  • Ensure records of release detection testing are reviewed and current
Containment sumps
  • Check for damage, leaks into the containment area, or releases to the environment
  • Remove any liquid or debris
  • Double walled containment sumps with interstitial monitoring check for a leak in the interstitial area
Hand held release detection equipment (for example tank gauge sticks or groundwater bailers)
  • Check for operability and serviceability

OPTION 2: Conduct walkthrough inspections according to a standard code of practice developed by a nationally recognized association or independent testing laboratory. The code of practice must check equipment comparable to option 1 above.

OPTION 3: Conduct walkthrough inspections according to requirements developed by your implementing agency. These requirements must be comparable to the requirements described in option 1 above.

In addition to these requirements, owners and operators must inspect the following additional areas for airport hydrant systems at least once every 30 days if confined space entry according to the Occupational Safety and Health Administration is not required or at least annually if confined space entry is required.

  • Hydrant Pits – Check for any damage; remove any liquid or debris; and check for any leaks
  • Hydrant Piping Vaults – Check for any hydrant piping leaks

Owners and operators must maintain the most recent year's walkthrough inspection records. Records need to include a list of each area checked, whether each area checked was acceptable or needed action taken, a description of any actions taken to correct issues, and delivery records if spill prevention equipment is checked less frequently than every 30 days due to infrequent deliveries.

Ethanol prep includes removing sediment from previous products

Requirements to Ensure UST System Compatibility
Before Storing Certain Biofuel Blends

EPA's underground storage tank (UST) regulations require that tank systems are compatible with the substances stored in them. The use of alternative fuels in the United States is growing, and federal mandates require a significant increase in biofuels production. Many retail facilities, such as gas stations, and private fueling facilities already store and dispense ethanol and biodiesel in their UST systems. Ethanol and biodiesel are commonly blended with gasoline and diesel, respectively, and are referred to by their biofuel percentage of the blend: E10, E15, or B20. These fuels are also available in some retail markets as non-blended biofuels E98 or B100. The development and availability of other alternative fuels, such as isobutanol, are growing rapidly.

Each alternative fuel or alternative fuel blend has unique chemical characteristics that may be different from those of purely petroleum derived gasoline or diesel fuel. Those chemical characteristics may affect how the fuel interacts with UST system materials. Some materials in some USTs may actually not perform as intended if storing certain fuels or blends and may be incompatible with those fuels. If UST materials are not compatible with substances stored in USTs, releases to the environment can occur. Prior to storing alternative fuels, UST owners and operators should be aware of potential issues and regulations to ensure fuels are stored safely in USTs.

2015 Compatibility Requirements

In 2015, EPA revised the underground storage tank (UST) regulations. See below for the 2015 requirements.

EPA's UST System Compatibility with Biofuels booklet provides additional information on the 2015 compatibility requirements.

Owners and operators must use an UST system made of or lined with materials that are compatible with the substance stored in the UST system.

Compatibility is the ability of two or more substances (for example the tank or piping material and petroleum) to maintain their respective physical and chemical properties upon contact with one another. These substances need to remain compatible for the design life of the tank and under conditions likely to be encountered in the UST.

Beginning on October 13, 2015 owners and operators must notify their implementing agency at least 30 days prior to switching to one of the following:

  • Regulated substances containing greater than 10 percent ethanolv
  • Regulated substances containing greater than 20 percent biodiesel; or
  • Any other regulated substance identified by the implementing agency.

This notification gives the implementing agency an opportunity to inquire about the compatibility of the UST system before the owner and operator begins storing the regulated substance.

In addition, owners and operators storing one of these regulated substances must meet one of the following:

  • Demonstrate compatibility of the UST system (this includes the tank, piping, containment sumps, pumping equipment, release detection equipment, spill equipment, and overfill equipment) by using one of the following options:
    • Certification or listing of UST system equipment or components by a nationally recognized, independent testing laboratory for use with the regulated substance stored
    • Equipment or component manufacturer approval – this approval must be in writing, indicate an affirmative statement of compatibility, specify the range of biofuel blends the equipment or component is compatible with, and be from the equipment or component manufacturer
  • Use another option determined by the implementing agency to be no less protective of human health and the environment than the two options above.

Owners and operators must maintain records that document compliance with the compatibility requirement if they store regulated substances containing greater than 10 percent ethanol, greater than 20 percent biodiesel, or any other regulated substance identified by the implementing agency. These records must be maintained for as long as the UST system is used to store one of these regulated substances.

2011 Guidance on Demonstrating Compatibility

EPA's 2011 guidance provides options for UST owners and operators to use in complying with the federal compatibility requirement for UST systems storing gasoline containing greater than 10 percent ethanol or diesel containing greater than 20 percent biodiesel.

 

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 us at 1-800-964-1250.

 

EPA logoLearn More



Upcoming Events

NECSEMA  Mar. 20, Worcester, MA
M-PACT  Mar. 26-28, Indianapolis, IN
UMCS Energy  Apr. 8-10, Saint Paul, MN
WPMCA  Apr. 16-17, Green Bay, WI
NISTM FL  Apr. 24, Orland, FL

Register for TANCS

Username:
Password:

New EPA UST Federal Regulations
Will you be ready by October 2018?

Our customers have 24/7 Online Access
to key data related to their facilities.
Register for TANCS.

By using TANCS, you agree to our
Terms and Conditions.


Contact Us

Call 1-800-964-1250 today to discuss specific compliance needs for your site. Who are we? Learn more.

Careers for Veterans

If you are a Veteran, we invite you to learn about your next career with us.