The EPA has been working on revising the UST regulations. In a recent letter from Liz McDermott of the Environmental Protection Agency’s Office of Underground Storage Tanks, McDermott commented, “a revised version of the 'short list' which reflects the current thinking for potential changes to the UST regulations is now available. [These include] issues we plan to continue to move through the EPA regulatory process.“

This winter the final proposed rule changes are due to be published for public comment.
Until then, here are some items to keep on your radar that will likely be affected as part of these proposed changes:

Release Prevention
  • Operation and Maintenance (O&M) – includes overfill functionality testing, walk through checks, spill bucket testing and integrity testing for interstitial areas.
  • Ball Floats - Eliminate flow restrictors in vent lines as overfill device on new systems and when overfill is replaced.
  • Address Repairs in the following three areas:
    • Repairs and secondary containment
    • If fix primary or secondary wall, must verify structural integrity of the interstitial space before returning tank/piping to service
    • Revise repairs section to include non-release repairs and include requirements/testing. This will also require re-evaluating repair definition and disassociating repair from release.
Release Detection
  • O&M –walk through checks and periodic operational checks and periodic testing (automatic tank gauge, probes, sensors, line leak detectors, and alarms)
  • Incorporate new technologies with applicable performance standards - Statistical Inventory
  • Incorporate new technologies with applicable performance standards - Statistical Inventory Reconciliation (SIR), Continuous In Tank Leak Detection System (CITLDS)Address interstitial alarms with regard to section 280.50 “Reporting of Suspected Releases”
  • Phase out groundwater and vapor monitoring as leak detection methods 
  • Update Regulations to acknowledge 1998 deadline has passed.
  • Require closure of lined USTs that fail periodic inspection and cannot be repaired.
  • Update tank, piping sections for new technologies – include clad and jacketed tanks, flexpiping
  • Notification of ownership changes - Require revised notification forms when ownership changes at the facility
  • Technical Corrections – such as update standards and correct typos
  • Address alternative fuels and compatibility 
  • Exclude USTs containing Radioactive Substances
  • Exclude Emergency Generator USTs at nuclear power generation facilities regulated by NRC
  • Fully regulate Emergency Generator USTs
  • Regulate Airport Hydrant Systems with alternate Release Detection requirements
  • Regulate Field-Constructed USTs with alternate Release Detection requirements
  • Regulate Wastewater Treatment Tanks
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