BY: Winston G. Smith Environmental Engineer UST/PCB & OPA Enforcement & Compliance Section EPA Region 4

EPA Administrator, Gina McCarthy, signed the final rule on 6/19/2015 Effective October 13, 2015

In states without state program approval (SPA) and in Indian country the new requirements will apply according to time frames specified in the 2015 UST regulation. In states with SPA none of the new requirements will apply until state adopts the federal requirements if a state does not adopt the requirements, until EPA withdraws approval of SPA for that state. Owners and operators in states with SPA must continue to meet the *state* UST requirements.

Operator Training Operator Training Implementation: Within 3 years (October 2018) Secondary Containment w/ interstitial monitoring Secondary Containment w/ interstitial monitoring Applies to new and replaced tanks & piping Applies to new and replaced tanks & piping Includes interstitial monitoring (and sumps if they are used for interstitial monitoring) Includes under-dispenser containment for new dispenser systems Implementation: 180 Days (after April 11, 2016)

Walkthrough Inspections: Owners and operators conduct walkthrough inspections every 30 days for spill prevention and release detection equipment. Owners and operators conduct walkthrough inspections every 30 days for spill prevention and release detection equipment. Annually for containment sumps and hand held RD equipment. Annually for containment sumps and hand held RD equipment. Records kept for 1 year Records kept for 1 year

Implementation: Implementation: - New installations: after October 13, Installs on or prior to October 13, 2015: within three years (October 2018) Spill Prevention Test Requirement: Owners and operators test at least every 3 years for liquid tightness or use a double-walled spill bucket with periodic interstitial monitoring. Owners and operators test at least every 3 years for liquid tightness or use a double-walled spill bucket with periodic interstitial monitoring. Records kept for 3 years Records kept for 3 years

Overfill Test & Inspection Requirement Owners and operators inspect every 3 years to ensure overfill operates as intended Records kept for 3 years Implementation: ) Implementation: - New installations: after October 13, Installs on or prior to October 13, 2015: within three years (October 2018)

Containment Sump Test Requirement: Containment sumps used for piping interstitial monitoring - owners and operators test every 3 years for liquid tightness or use a double-walled containment sump with periodic interstitial monitoring. Records kept for 3 years Implementation: - Implementation: - New installations: after October 13, Installs on or prior to October 13, 2015: within three years (October 2018)

Implementation: - Beginning October 13, 2018 Release Detection Test Requirement: Owners and operators test annually to ensure equipment is operating properly. Keep records for 3 years Overfill Alarm Product Level Float Water Level Float

Emergency Generator USTs: Deferral status is removed Requires owners and operators to perform release detection. Implementation: - Implementation: - New installations: required immediately for installs after October 13, Installs on or prior to October 13, 2015: within three years (October 2018)

2015 UST regulation removes the deferral EPA created more specific and appropriate requirements for these systems Provides unique options for meeting release detection requirements One-time notification by October 13, 2018 for these systems Partially excludes aboveground tanks associated with these systems

Notification - Owners and operators must notify the implementing agency at least 30 days before switching to a regulated substance containing greater than 10 percent ethanol, 20 percent biodiesel, or any other regulated substance identified by the implementing agency Product compatibility - must be demonstrated Recordkeeping - Owners and operators must maintain compatibility records for as long as the biofuel blend is stored

Vapor and groundwater monitoring still allowed as release detection options. Requires owner or operator to have a record of site assessment for as long as they use groundwater or vapor monitoring for release detection.

Flow Restrictors: flow restrictors in vent lines (ball floats) are no longer an option for overfill protection in new UST systems and when these devices need to be replaced

Internal Lining: If the internal lining of a UST fails the periodic inspection and cannot be repaired according to a code of practice, owners and operators must permanently close tanks using internal lining as the sole method of corrosion protection

Notification: New owners must notify the implementing agency within 30 days of becoming an UST owner EPA adds a requirement that, within three years, owners submit a one-time notification for previously deferred FCTs and AHSs.

Repairs: 1988 regulations linked a repair to a release to the environment 2015 UST regulation removes this link so that fixes not associated with releases are also repairs Added testing after repairs to spill, overfill, and secondary containment equipment

Interstitial monitoring results: Interstitial alarms are added as an example of an unusual operating condition and have been added as part of release investigation and confirmation

Added newer technologies to the rule Updated codes of practice Removed references to old compliance deadlines Made editorial and technical corrections

OUST Website on Revised Regulations Contact Info: Winston G. Smith at or