How EPA’s Revised UST Regulations Affect Fuel Retailers

An in-depth review of the Environmental Protection Agency’s (EPA) revised Underground Storage Tank Regulations found that the final rule contains a number of improvements from the proposed rule that was released in 2011, many of which were proposed by NATSO.

These improvements come primarily in the form of requiring equipment testing and inspections to occur less frequently, and make compliance easier without seriously compromising EPA’s environmental objectives.

After completing its analysis of the 468-page regulation, NATSO has prepared a memorandum summarizing the new rules for NATSO members.

To obtain a copy of the complete summary, click here.

Key components include:

• Secondary Containment – New and replaced tanks and piping must be secondarily contained with interstitial monitoring systems, and new dispenser systems must be equipped with under-dispenser containment. Owners and operators must replace an entire piping run when 50 percent or more of piping is removed and other piping is installed. These requirements only apply to new and replaced systems – there are no retrofit requirements.

• Operation and Maintenance Inspections – The final rule requires periodic walkthrough inspections to prevent and quickly detect releases, as well as additional requirements for periodic spill, overfill, and secondary containment monitoring. 

• Spill Containment Testing – Under the final rule spill prevention equipment must be tested every three years to ensure that it will contain small drips and spills when the delivery transfer hose is disconnected from the fill pipe.

• Overfill Prevention – Flow restrictors, or ball float valves, in vent lines have been eliminated as an option for satisfying the overfill prevention requirements (a) for newly installed UST systems and (b) when flow restrictors in vent lines are replaced. (Ball float valves may be used in USTs that have already been installed before the final rule takes effect.)

• Secondary Containment Testing – The final rule requires double-walled containment sumps to be periodically monitored (generally every 30 days), or else undergo periodic testing. It further requires testing of containment sumps used for interstitial monitoring of piping at least once every three years.

• Release Detection Equipment – The final rule is designed to standardize the operation and maintenance requirements for release detection equipment by requiring owners and operators to follow a set of minimum operation and maintenance criteria for electronic and mechanical-based release detection equipment.

• Operator Training – The final rule requires owners and operators to designate at least one individual for each of three “classes” of operators, and such operators must be trained in certain areas within three years of the final rule taking effect.

• Tank Compatibility with Alternative Fuels – The final rule generally allows tank owners to demonstrate equipment compatibility with alternative fuels (e.g., blends containing greater than 10% ethanol or 20% biodiesel) (a) through a listing by a nationally recognized association (such as Underwriters Laboratories); or (b) based upon written equipment manufacturer approval.

• Repairs – The final rule contains a number of requirements pertaining to repairs of leaking UST systems.

• Emergency Generator USTs – The final rule includes requirements for release detection for UST systems that are storing fuel solely for use by emergency power generators.

• New Technologies – The final rule adds steel tanks that are clad or jacketed with a non-corrodible material to the list of specific new tank design and construction options for UST systems.

• Statistical Inventory Reconciliation – The final rule adds statistical inventory reconciliation as a permissible release detection method and provides performance criteria for its use.

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