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Issue link: https://read.dmtmag.com/i/54942
MARKETING & SUPPLY BY DEBRARESCHKE SCHUG The EPA describes the differences between the current and proposed regulations PROPOSED REVISIONS TO UST REGULATIONS F • • • • • • • • OR THE FIRST TIME SINCE THE ENVIRONMENTAL Protection Agency came out with the federal underground storage tank regulations in 1988, the agency is now proposing significant revi- sions. EPA Administrator Lisa P. Jackson signed the proposed rule on October 25, 2011. On November 18, 2011, the EPA published the proposal in the Federal Register. The following breaks down the EPA's pro- posed revisions to the UST technical regulation in 40 CFR 280. ADDING PERIODIC OPERATION AND MAINTENANCE REQUIREMENTS Walkthrough inspections: Would be required of UST systems at least once every 30 days. Spill prevention equipment testing: Would be required at installation and performed at least once annually. Overfill prevention equipment: Testing would be required at installation and every three years. Secondary containment areas: Testing would be required every three years. Release detection equipment: Testing would be required annually. ADDING SECONDARY CONTAINMENT REQUIREMENTS Owners and operators would be required to install sec- ondary containment and interstitial monitoring for new or replaced tanks and piping installed after the effective date of the final UST regulation. Remove the option for owners and operators to use a release detection method other than interstitial monitor- ing for hazardous substance USTs (those installed after the final UST regulation). Install under-dispenser containment for all new dis- penser systems. ADDING OPERATOR TRAINING REQUIRE- MENTS FOR UST SYSTEM OWNERS AND OPERATORS State implementing agencies, as a condition of receiving federal Subtitle I money, would be required to develop • 12 JANUARY/FEBRUARY 2012 state-specific training requirements for three classes of UST system operators. REMOVING CERTAIN DEFERRALS The EPA would remove the deferral of UST systems storing fuel for use by emergency power generators and would require owners and operators to perform release detection. Deferrals would be removed from field-constructed tanks (FCT), airport hydrant systems (AHS) and waste- water treatment tank systems. • • ADDING NEW RELEASE PREVENTION AND DETECTION TECHNOLOGIES The proposal would: Eliminate flow restrictors in vent lines as an overfill prevention option for all new tanks and when overfill devices are replaced. Require closure of lined tanks that cannot be repaired. Provide notification of UST ownership change to the implementing agency within 30 days. Require testing within 30 days after repairs to spill or over- fill prevention equipment and secondary containment areas. Owners and operators demonstrate compatibility for UST systems storing greater than 10 percent ethanol or greater than 20 percent biodiesel. Clarify the responsibilities of UST owners and operators regarding interstitial alarm monitoring results. Eliminate groundwater and vapor monitoring as release detection options. • • • • • • • UPDATING The proposal includes technologies developed since the 1988 UST regulations were issued such as: allowing UST owners and operators to be able to use clad and jacketed tanks, noncorrodible piping, continuous in-tank leak detection, and statistical inventory reconciliation. The EPA would add newer codes of practices, update titles of codes of practices, and remove those that are not applicable or no longer exist. • NPN Magazine n www.npnweb.com