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July 15, 2015
Summer mUSTs: sunshine and compliance scheduling
By Emily Remmel, JD, Legal Editor

Summer is the perfect season for outdoor adventures, getting together with friends and family, and a great time to soak up some good ol’ rest and relaxation. So why get started this early with compliance scheduling? Even though there is plenty of time for summertime fun, if you or your facility is impacted by the recently revised federal underground storage tank (UST) regulations, you should consider utilizing a little poolside free time this summer and put together a simple compliance schedule.

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The U.S. Environmental Protection Agency (EPA) recently revised the 1988 UST regulations. Not only do these new regulations set the minimum requirement standards for operator training and secondary containment, but they also place an emphasis on the proper operation and maintenance of UST systems and equipment.

The rule is effective October 13, 2015. Many, but not all, of the 2015 UST requirements set a 3-year compliance deadline for owners and operators (O/Os) of existing USTs subject to the federal requirements. For new tanks installed after the October 13, 2015 effective date, O/Os must meet the requirements at installation. The compliance clock begins ticking this October. The deadlines are:

  • Any new or replaced tank or piping—install secondary containment by April 10, 2016
  • Switching tank contents to a regulated substance containing greater than 10 percent ethanol or greater than 20 percent biodiesel—30 days to notify the implementing agency
  • Class A, Class B, Class C operator training—designate and train by October 13, 2018
  • Monthly and annual walk-through inspections—implement by October 13, 2018
  • Spill prevention equipment—test by October 13, 2018 and at least once every 3 years thereafter
  • Overfill prevention equipment—test by October 13, 2018 and at least once every 3 years thereafter
  • Containment sumps—test by October 13, 2018 and at least once every 3 years thereafter
  • Release detection equipment—test by October 13, 2018 and annually thereafter
  • Notification for tank existence and demonstration of financial responsibility (only applies to airport hydrant distribution systems and field constructed tanks)—submit and demonstrate to implementing agency by October 13, 2018

But wait, for the most part, EPA’s new 2015 UST regulations require compliance by 2018. That's 3 years from now. Why would anyone get started this early?

The answer: It is never too early.

Operator training. The best place to start may be with operator designation and training. You should identify, if you have not already done so, who will be designated as an operator for each class and what trainings will be necessary. It is best to research operator training programs or examinations early because they may not be offered year-round. Also, you should determine whether you will keep your current operator designations and training records in paper or electronic format.

Walk-through inspections. Once you have designated and researched training programs, the next planning step may be to preliminarily schedule your walk-through inspections. O/Os must conduct monthly inspections for spill prevention and release detection equipment. Annually, O/Os must inspect containment sumps and handheld release detection equipment. Outlining a calendar and sharing it with your operators early may avoid any future scheduling conflicts.

Equipment testing. While you have the calendar out, you should consider scheduling equipment testing (operation and maintenance) for your UST system. The new regulations require equipment testing for spill and overfill prevention equipment as well as for containment sumps and release detection equipment. You may need specific equipment or certain personnel present to conduct each test. Having a testing plan scheduled may again avoid time conflicts.

If you have some downtime this summer, it’s not a bad idea to get out the calendar and start planning how and when your facility will begin implementing the new federal UST regulations. An easy first step is to designate operators and look into scheduling operator training. Then, schedule walk-through inspections and operation and maintenance testing for all your UST equipment.

The benefit for starting early reduces the inevitable stress spent worrying over looming compliance deadlines. Even though these deadlines seem distant, once you put together a compliance schedule that charts your facility’s UST requirements, that summertime feeling can be felt year-round.

Final UST rule

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