1. Getting The Most Out Of Release Detection Testing National Tanks Conference 2015 Phoenix, Arizona September 15, 2015 1

2. Why did EPA make this particular change to the UST regulation? No specifics provided in the 1988 UST regulation on minimum O&M requirements to ensure adequate operation and maintenance Wide variation of O&M requirements by manufacturers, even among similar types of equipment Many manufacturers specified recommended O&M testing, few required testing Level playing field by establishing core testing requirements 2

3. What are the important dates regarding release detection testing? October 13, 2015 – The effective date of the 2015 revised UST regulation October 13, 2018 – The date by which owners and operators must conduct their first release detection equipment tests 3

4. What do these new requirements mean for owners and operators? 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 the state adopts the federal requirements or 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 4

5. States with Approved UST Programs (SPA States) 5

6. New Operation and Maintenance Requirements Annual release detection equipment testing to make sure release detection equipment is operating properly 6

7. New Operation and Maintenance Requirements §280.40 (a)(3) Electronic and mechanical components are tested for proper operation, in accordance with one of the following: Manufacturer’s instructions; A code of practice; or Requirements determined by the implementing agency to be no less protective of human health and the environment 7

8. New Operation and Maintenance Requirements At a minimum, as applicable to the facility, tests must cover the following components and criteria; Automatic tank gauge (ATG) systems and other controllers –Verify system configuration –Test alarm –Test battery back-up 8

9. New Operation and Maintenance Requirements Probes and sensors –Inspect for residual build-up –Ensure floats move freely –Ensure shaft is not damaged –Ensure cables are free of kinks and breaks –Test alarm operability and communication with controller Automatic line leak detector (ALLD) –Simulate leak which determines capability to detect a leak 9

10. New Operation and Maintenance Requirements Vacuum pumps and pressure gauges –Ensure proper communication with sensors and controller Handheld electronic sampling equipment associated with vapor and groundwater monitoring –Ensure proper operation 10

11. New Operation and Maintenance Requirements Records Maintenance Keep results of annual testing for three years At minimum, results must: –List each component tested –Indicate whether each component tested meets criteria specified in the regulation or needed to have corrective action taken –Describe any action taken to correct an issue 11

12. Additional Information OUST Website on Revised Regulations http://www.epa.gov/oust/fedlaws/revregs.html OUST Release Detection Contact Tim Smith at smith.timr@epa.gov orsmith.timr@epa.gov 703-603-7158 12