Regulatory Update: Federal UST Regulations
The United States Environmental Protection Agency (EPA) defines an underground storage tank (UST) as “a tank and any underground piping connected to the tank that has at least 10 percent of its combined volume underground”. Most USTs contain petroleum products, which can be dispensed and sold (e.g. retail gas stations) or used in-house by an entity (e.g. municipality) for vehicle and machinery operations. Proper operation and monitoring are vital to ensure that UST systems do not leak and impact soil and groundwater.
The EPA’s July 2015 revisions to the 1998 UST regulations have been phased in over the past few years. Several key federal requirements will go into effect on October 13, 2018. These requirements include:
Updated methods of release detection
*Electronic and mechanical components of USTs must be tested for proper operation on an annual basis. Automatic tank gauges and alarms, probes, sensors, floats, the automatic leak line detector (ALLD), vacuum pumps, pressure gauges, and handheld equipment related to groundwater and vapor monitoring must be tested to ensure functionality.
Designation of Class A/B/C operators
*All facilities must designate Class A, B and C operators in accordance with 40 CFR 280 Subpart J: Operator Training. To become a Class A, B, or C operator on a federal level, you must either pass a comprehensive examination or receive training pursuant to Subpart J.
Class A and B operators both have responsibilities related to environmental compliance and spill prevention; however, Class B operators are those responsible for the “day-to-day” operation of the USTs. Class C operators are the persons on-site who are responsible for recognizing and reporting spill incidents related to on-site USTs.
Previously deferred UST systems are now covered under EPA regulations
*As of October 13, 2018, USTs that store fuel for use by portable generators that were installed on or before October 13, 2015 will be immediately subject to all monitoring and operator training requirements.
Although these regulations are new on a federal scale, Walden Environmental Engineering has been involved for several years with Class A/B/C operator training and release detection requirements on a statewide level to comply with similar NYSDEC UST regulations that went into effect in 2015. Walden has firsthand experience not only managing these UST systems, but also in design and construction. Please give us a call today at (516) 624-7200 to discuss any of your UST needs!