Regulatory Watch: Four New UST Program Initiatives

The United States Environmental Protection Agency (EPA) has identified four underground storage tank (UST) program initiatives which will guide the future underground storage tank work that remains to be completed across the nation. The Agency will work closely with State regulatory agencies to continue the dialogue to develop additional details necessary to carry out the initiatives. The four initiatives are:

1. Improving Compliance - to bring all UST systems into operational compliance and keep them in compliance in accordance with leak detection, spill overfill, and corrosion protection requirements.
2. Evaluating UST System Performance - to determine whether UST regulations and systems are working effective and what, if any, changes should be made.
3. UST fields for Abandoned Tanks - to assess and remediation abandoned or closed UST systems at Brownfields sites.
4. Faster Cleanups - to expedite the remediation (clean-up) of approximately 160,000 petroleum releases into the environment that have already occurred but have not yet been cleaned up.

What Are The Requirements

Release Detection
Long-term "Monthly Monitoring" methods: These methods include interstitial monitoring, automatic tank gauging systems, groundwater monitoring, vapor monitoring, and other methods approved by implementing state agencies to work equally well, such as statistical inventory reconciliation (SIR).

Temporary release detection methods: For 10 years following installation of a new UST or the upgrading of an old UST (prior to December 22, 1998), you can often use a combination of periodic tank tightness testing with either inventory control or manual tank gauging.

Don't forget about the additional requirements for your UST's piping. Pressurized piping and suction piping have different requirements. In addition, electronic line leak detectors for pressurized systems can be difficult to interpret.

Corrosion Protection
All tanks and piping must be protected from corrosion, but USTs installed before December 22, 1988 can use some retrofit approaches not allowed for USTs installed on or after December 22, 1988. Be sure you know the corrosion protection requirements for each of your USTs.

Spill Protection
All USTs must be protected from spills by having devices such as "spill buckets" or catchment basins that can contain spilled product.

Overfill Protection
All USTs must be protected from overfills by using such devices as automatic shutoff devices, overfill alarms, or ball float valves.

Record keeping
As a rule of thumb, keep records of reports, tests, repairs, and other actions at your facilities, or know where these records are kept at an off-site location. In some cases, such as closure reports or site assessments, records may be kept by implementing agencies.

Notification
You should have filed a notification form with your implementing agency for all USTs at your facility. Notification forms for USTs installed after December 22, 1988 must include a certification of correct installation.

Closing USTs
You can temporarily close an UST by meeting the requirements for temporary closure, which, at a minimum, can involve continuing operation of release detection and corrosion protection methods. Permanent closure of an UST requires several steps intended to ensure the safety of those closing or removing tanks and determine if your UST is present in the surrounding environment.

Financial Responsibility
You must demonstrate your financial responsibility for the cost of cleaning up a leak and compensating other people for bodily injury and/or property damage. Financial responsibility types depend, in part, on the number of USTs you have and if you are a marketer or non-marketer.

Corrective Action
The steps you need to take in responding to an UST leak is usually dictated by site-specific conditions and the procedures established by the implementing agency. Be sure to check with the implementing agency in your State or your U.S. EPA Regional contact to determine the appropriate steps to take.See our FAQ / Links page to get you started.