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In states without state program approval (SPA) and in Indian country the new requirements will apply according to time frames specified in the 2015 UST regulation. In states with SPA none of the new requirements will apply until state adopts the federal requirements if a state does not adopt the requirements, until EPA withdraws approval of SPA for that state. Owners and operators in states with SPA must continue to meet the *state* UST requirements.
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2015 Federal UST Regulation Changes
BY:Winston G. Smith
Environmental EngineerUST/PCB & OPA Enforcement & Compliance Section
EPA Region 4
2015 Federal UST Regulation Changes
EPA Administrator, Gina McCarthy, signed the final rule on 6/19/2015
Effective October 13, 2015
What do these new requirements mean for owners and operators?
• In states without state program approval (SPA) and in Indian country• the new requirements will apply according to time frames specified in
the 2015 UST regulation.
• In states with SPA• none of the new requirements will apply until state adopts the federal
requirements• if a state does not adopt the requirements, until EPA withdraws
approval of SPA for that state. Owners and operators in states with SPA must continue to meet the *state* UST requirements.
States with Approved UST Programs(SPA States)
• Operator Training
Implementation: Within 3 years (October 2018)
• Secondary Containment w/ interstitial monitoring
• Applies to new and replaced tanks & piping• Includes interstitial monitoring (and sumps if they are used for
interstitial monitoring)• Includes under-dispenser containment for new dispenser systems
Implementation:180 Days (after April 11, 2016)
2015 “Energy Policy Act of 2005” Requirements
Implementation: Within 3 years (October 2018)
Walkthrough Inspections:
• Owners and operators conduct walkthrough inspections every 30 days for spill prevention and release detection equipment.
• Annually for containment sumps and hand held RD equipment.
• Records kept for 1 year
New Operation and Maintenance Requirements
Implementation:
- New installations: after October 13, 2015
- Installs on or prior to October 13, 2015: within three years (October 2018)
Spill Prevention Test Requirement:
• Owners and operators test at least every 3 years for liquid tightness or use a double-walled spill bucket with periodic interstitial monitoring.
• Records kept for 3 years
New Operation and Maintenance Requirements
Overfill Test & Inspection Requirement
• Owners and operators inspect every 3 years to ensure overfill operates as intended
• Records kept for 3 years
New Operation and Maintenance Requirements
Implementation:
- New installations: after October 13, 2015
- Installs on or prior to October 13, 2015: within three years (October 2018)
Containment Sump Test Requirement:
• Containment sumps used for piping interstitial monitoring - owners and operators test every 3 years for liquid tightness
or • use a double-walled containment
sump with periodic interstitial monitoring.
• Records kept for 3 years
New Operation and Maintenance Requirements
Implementation:
- New installations: after October 13, 2015
- Installs on or prior to October 13, 2015: within three years (October 2018)
Implementation:
- Beginning October 13, 2018
Release Detection Test Requirement:
• Owners and operators test annually to ensure equipment is operating properly.
• Keep records for 3 years
Overfill Alarm
Product Level Float
Water Level Float
New Operation and Maintenance Requirements
Emergency Generator USTs:
• Deferral status is removed• Requires owners and
operators to perform release detection.
Implementation:
- New installations: required immediately for installs after October 13, 2015
- Installs on or prior to October 13, 2015: within three years (October 2018)
Addressing Deferrals
Implementation depends on requirement:
- October 13, 2015: release reporting, response, and investigation; financial responsibility; closure, notification (except one-time )
2015 UST regulation removes the deferral
• EPA created more specific and appropriate requirements for these systems
• Provides unique options for meeting release detection requirements
• One-time notification by October 13, 2018 for these systems
• Partially excludes aboveground tanks associated with these systems
Field-Constructed USTs and Airport Hydrant Fuel Distribution Systems
Implementation depends on requirement (cont):
- October 13, 2018: Spill and overfill prevention, corrosion protection, general operating requirements (including compatibility and repairs), release detection, and operator training
Field-Constructed USTs and Airport Hydrant Fuel Distribution Systems
Implementation:
- October 13, 2015
• Notification - Owners and operators must notify the implementing agency at least 30 days before switching to a regulated substance containing greater than 10 percent ethanol, 20 percent biodiesel, or any other regulated substance identified by the implementing agency
• Product compatibility - must be demonstrated
• Recordkeeping - Owners and operators must maintain compatibility records for as long as the biofuel blend is stored
Product Compatibility
Implementation:
- Record of site assessments by October 13, 2018
Vapor and groundwater monitoring still allowed as release detection options.
• Requires owner or operator to have a record of site assessment for as long as they use groundwater or vapor monitoring for release detection.
Groundwater and Vapor Monitoring
Implementation: - Immediately on new installations and replacements
Flow Restrictors:
• flow restrictors in vent lines (ball floats) are no longer an option for overfill protection in new UST systems and when these devices need to be replaced
Additional Requirements
Implementation:
- October 13, 2015
Internal Lining:
• If the internal lining of a UST fails the periodic inspection and cannot be repaired according to a code of practice, owners and operators must permanently close tanks using internal lining as the sole method of corrosion protection
Additional Requirements
Implementation:
- October 13, 2015
Notification:
• New owners must notify the implementing agency within 30 days of becoming an UST owner
• EPA adds a requirement that,
within three years, owners submit a one-time notification for previously deferred FCTs and AHSs.
Additional Requirements
Implementation:
- October 13, 2015
Repairs:
• 1988 regulations linked a repair to a release to the environment
• 2015 UST regulation removes this link so that fixes not associated with releases are also repairs
• Added testing after repairs to spill, overfill, and secondary containment equipment
Additional Requirements
Implementation:
- October 13, 2015
Interstitial monitoring results:
• Interstitial alarms are added as an example of an unusual operating condition and have been added as part of release investigation and confirmation
Additional Requirements
General Reg Updates
• Added newer technologies to the rule• Updated codes of practice• Removed references to old compliance
deadlines• Made editorial and technical corrections
Additional Information
OUST Website on Revised Regulationshttp://www.epa.gov/oust/fedlaws/revregs.html
Contact Info:
Winston G. Smith at [email protected] or 404-562-9467
Questions?