Underground Storage Tank Regulation Update

Underground Storage Tank Regulation Update

September 15 2021

Tom Guist, Todd McCollister and Steve Jarvis senior staff from our Illinois and Georgia office, exhibited at the Midwest Petroleum and Convenience Tradeshow (M-PACT) in Indianapolis, IN on September 8-10, 2021.  Additionally, Doug Klicman, who recently joined AKT Peerless after having managed the Cleveland office of SAS Environmental for the past 22 years, also attended the conference. The show, put on jointly by the Ohio Petroleum Marketers & Convenience Store Association (OPMCA), Indiana Food & Fuel Association (IFFA), Kentucky Petroleum Marketers Association (KPMA) and the Illinois Fuel and Retail Association (IFRA) draws top decision makers representing the leading energy and convenience companies in the Midwest.

At the conference, our team attended a presentation by Mr. Mark Barolo, Director of the United States Environmental Protection Agency’s (USEPAs) Office of the Underground Storage Tanks (UST) regarding updates to the federal UST regulations promulgated in 2015. The petroleum industry is accustomed with the changes that happened in 1988, but few are aware that additional changes have taken place since that time. The following revisions strengthen the 1988 federal regulations by increasing emphasis on properly operating and maintaining UST equipment:

  • Added secondary containment requirements for new and replaced tanks and piping;
  • Added operator training requirements;
  • Added periodic operation and maintenance requirements for UST systems;
  • Added requirements to ensure UST system compatibility before storing certain biofuel blends.

For many states, those regulations became effective in October 2018, with the second round of compliance testing due in October 2021. According to the 2015 EPA UST Regulations, tank compliance requirements include:

  • The testing of spill and overfill prevention equipment every 3 years:
  • Corrosion protection testing is conducted every 3 years unless a repair is made (tested within 6 months);
  • Automatic or manual tank gauging is performed every 30 days for inventory control; however, automatic tank gauging equipment must be tested annually to ensure proper performance, release detection equipment testing including tank and line tightness is performed annually;
  • All underground storage tanks and associated piping after April 2016 must have secondary containment (i.e. be double-walled) and the interstitial space between the walls be tested every 3 years including the containment sumps;
  • Walk-through inspections on a monthly and annual basis for release detection purposes.

For those states that have State Program Approval with the EPA, these requirements may be more stringent. For example, although Michigan, Illinois and Ohio are non-State Program Approval states they have updated their UST regulations to incorporate the revised 2015 federal UST requirements, whereas Indiana, Kentucky and Georgia are State Program Approved states having similar or more stringent requirements than the EPA and operate their own UST programs in lieu of the federal program.

AKT Peerless provides environmental support to fueling station/convenience store owners and operators primarily in the midwestern and southeastern portions of the country. Our technical team of engineers, geologists and environmental scientists are ready to answer environmental questions or concerns that you may have regarding your facility whether it be compliance related or assessing/remediating a suspect and/or confirmed release.

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