- UST owners and operators in states without UST state program approval (see below) must meet the remaining 2015 federal UST requirements on or before the federal deadlines.
- UST owners and operators in states with program approval must continue to follow their states' requirements, which may be different from the 2015 federal UST requirements.
There are four major regulatory requirements that all retail stations must prepare for:
Testing of sumps and under-dispenser containment systems must be performed every three years if the system uses interstitial monitoring of the piping as its primary form of leak deterrence;
Spill-bucket testing will be required every three years, unless the UST system is outfitted with double-wall spill buckets where the interstitial space is tested regularly;
Whenever any component in the spill-protection, overfill-containment and secondary-containment areas of the UST system needs to be repaired, compliance testing of the repaired system must be completed within 30 days, regardless of whether or not an actual product release occurred;
Overfill-prevention equipment inspections will be required every three years, except in states where they are already required annually.
It’s important for NATSO members to be aware that as many as 30 states have been working with EPA to draft UST regulations. State UST program's can tell truckstop and travel plaza members if and when a state’s requirements and associated compliance deadlines may change. EPA’s state UST program web page provides state contact information.
States that already have program approval are required to reapply by Oct. 13, 2018, to retain program approval status, either by adopting and receiving approval of the updated regulatory requirements.
EPA’s website provides further information about SPA and the October 2018 deadline.
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