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May 16, 2016
Knowing your UST release detection system
By Emily Remmel, JD, Legal Editor

Last summer, the U.S. Environmental Protection Agency (EPA) updated its underground storage tank (UST) regulations for the first time in over 2 decades. With this update, owners and operators of UST systems have additional compliance requirements—including new obligations for release detection.

The EPA and states require tanks to have release detection in order to discover leaks swiftly before tank product contamination migrates beyond the UST site. UST systems storing petroleum must have some form of release detection system installed. Common release detection methods include tank tightness testing, statistical inventory reconciliation, secondary containment with interstitial monitoring, groundwater or vapor monitoring, manual tank gauging, or use of an automatic tank gauging (ATG) system.

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What’s new?

In a significant deviation from the previous UST rules, the revised regulations require that tanks and piping installed or replaced after April 11, 2016 be secondarily contained and use interstitial monitoring. The only exception is if a tank uses safe suction piping.
In another consequential regulatory change, the release detection requirements now extend to USTs storing fuel solely for emergency power generators.

These tanks were once deferred but are now required to meet release detection requirements. These UST systems must provide a release detection method or combination of methods that can detect a release, must be installed and calibrated according to manufacturer’s instruction, must be operated and maintained, and must have annual tests conducted to assess for any released product.

Common release detection problems

It is not out of the ordinary for owners and operators with release detection systems to witness system errors or electronic glitches or to run into manual complications. Although operating deviations from the norm may simply be a harmless hiccup and not an actual release to the secondary containment or the environment, operators should immediately respond and investigate any audible alarms or flashing lights.

These problems can include:

  • ATG systems are improperly programmed or probes are disconnected.
  • Printer paper is jammed or not replaced.
  • Product level is at an insufficient level in tank for sensor to detect.
  • Interstitial monitor is not installed, or sensor is malfunctioning.
  • Vendor reports for statistical inventory reconciliation are not obtained in a timely manner.
  • Inventory control for tank is not gauged daily, water is not observed monthly, and deliveries are not recorded.
  • Calculations and reconciliation of inventory control data is not calculated properly at the end of the month.
  • Annual tightness tests are not conducted.

Get to know your release detection system

Regardless of the type of release detection system your facility uses, knowing the tricks to release detection can keep your business in compliance with the regulations. This most critical compliance trick is knowing that your release detection system is installed, calibrated, operated, and maintained according to the manufacturer’s instructions.

Locate the owner’s manual or manufacturing instructions for your UST system’s release detection equipment. These resources contain a wealth of information, such as identifying the equipment type and the vendor, determining leak rates, and providing detailed testing guidelines. Some manuals even provide sample test reports that are identical representations of the tests your device will produce when you run a test.

It is vital for UST operators to properly operate and maintain their release detection systems because the failure to do so may result in a release to the environment or harm to human health. Getting familiar with your release detection system is one step toward helping your facility stay in compliance.

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