EPA Proposed UST Regs – Part 2 of 8

Secondary Containment

EPA has proposed changes to established regulations related to secondary containment. They are “established” because they were originally set forth in the Energy Policy Act of 2005 and implemented by the states. 54 out of 56 states implemented secondary containment as part of the federal funding requirements of the Energy Policy Act of 2005.
Summary: EPA is proposing that new systems installed after the effective date of the rule must be upgraded to equipment with an inner and outer barrier with an interstitial pace that is monitored.
Tank – If a tank is removed and replaced. New tank must have secondary containment
Piping – If 50% or more of a piping run must be repaired, then the entire piping run must be upgraded to secondary containment.
Under Dispenser Containment (UDC)– Must be installed on all “new systems”, must be liquid tight and must be able to be monitored or visually inspected.
  • “New” means: both the dispenser system and equipment needed to connect the dispenser system to the UST system are installed at an UST facility.
  • Safe suction piping systems; and
  • Piping systems associated with:
    • Field constructed tank systems
    • Airport hydrant fuel distribution systems
Operational Requirements:
  • Monitoring of the interstitial space required on a 30-day basis
  • Pressurized piping must have an automatic line leak detector.
Discussion: Like the proposed changes to operator training regulations, these changes should only be news and an increased regulatory (and financial) burden to those owners and operators who have systems located:
  • On tribal lands or
  • In states that have rejected the grant money from the Energy Policy Act of 2005. (few and far between)
  • In states that Implemented less stringent definitions of “replace” for piping runs – (about 25% of the states)
All other owners and operators should be implementing these upgrade requirements as well as having proper interstitial monitoring and testing.
If you are not sure if your system is in compliance with the current secondary requirements or plan to upgrade any tank or piping component in the near future, contact 7G.
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