Synergy Environmental, Inc.
Robert J. May, P.E. CHMM
July 16, 2015
Late June, the USEPA published revisions to the Underground Storage Tank (UST) rules under 40 CFR 280 and 281. The entire rule (120 pages) recently became available on the EPA Office of Underground Storage Tanks website . Below is a brief summary of the rule changes that a motor fuel retailer should become aware.
- Walkthrough inspections every 30 days There is a heightened awareness for the operator to review spill prevention and release detection equipment on a routine basis. Spill bucket and overfill devices need reviewed to ensure proper operation.
This change will be implemented within three years. - Containment sumps – tank top and under dispensers – need tightness testing every three years. Spill buckets- the containment device at tank fill ports- will need to be hydrotested every three years. Electronic line leak detectors will now also be tested by a third party tester annually.
These changes will be implemented within three years. - Overfill prevention devices – ball floats will not be permitted to be replaced at current systems nor installed on new systems. It would be prudent to install the flapper type fill port overfill device, replacing the ball float, within the next three years since all overfill devices must be tested every three years.
This change is implemented immediately.
- Emergency power generators using fuel in USTs were previously exempt from the leak detection requirements. These systems will now be required to have tank and piping leak detection equipment.
The new regulations require leak detection within three years. - Operator training will be a requirement in all states and tribal nations. States like NY and NJ project to implement their programs by year end 2015.
This change will be implemented within three years. - USTs with >10% ethanol or >20% biodiesel will required 30 day notification to the state agency and documentation demonstrating that the UST system is compatible with those new biofuels.
This change will be implemented immediately. - An interstitial monitoring alarm from the UST system is considered an unusual operating condition under release reporting. It would be prudent to reprogram the ATM to perform tank testing with the interstitial monitoring. This will provide additional information for the release investigation for these sensor alarms.
This change is implemented immediately.
Robert May is a Senior Engineer with Synergy Environmental, Inc. As Director of Compliance, Bob’s group provides monitoring and compliance reporting for over 700 gas stations nationwide. He also provides Class A, B & C Underground Storage Tank Operator Training.
