By Angela Wisdom, Insite360, a Veeder-Root Company
The U.S. Environmental Protection Agency (EPA) new underground storage tank (UST) fuel site compliance regulations which place the full responsibility for compliance, inspection, and documentation onto the fuel site convenience store and commercial fueling site operators are now live.
These revisions include several new actions that site owners and operators must take. The changes are intended to ensure all UST’s in the United States conform to minimum standards of operation and environmental protection against fuel spills. Some of these 2015 EPA regulatory changes for improved groundwater protection were adopted immediately, and some were phased in over a three-year timeline. The final set became mandatory in October 2018.
7 Required Inspection Action Items for Fuel Site Owners and Operators
1 — Conduct monthly operations and maintenance site walk-through inspections (Every 30 Days): This new inspection requires site owners and operators personally walk their site checking every 30 days for damage and ensure proper operability of all fuel spill prevention equipment, release detection equipment and containment sumps. The results must be documented and filed either electronically or onsite for one year.
2 — Review release detection equipment testing records (Every 30 Days): All electronic and mechanical components of fuel release detection equipment must be tested annually to ensure it is operating properly. These test records must be verified every 30 days as part of the site walk-through.
3 — Monitor spill prevention equipment and containment sumps used for interstitial monitoring of piping (Every 30 Days): For UST’s installed or replaced after April 11, 2016, secondary leak containment units must be installed and monitored for all new pumps and piping for all fuel types, including gasoline, diesel and fuel blends. These interstitial monitors monitor the area between the fuel storage tank (UST) and the barrier and must be inspected every 30 days and these results must be kept for three years.
4 — Test containment sumps upon initial installation and annually (Yearly): Commercial fueling site and retail fueling site owners and operators must maintain records of containment sump testing for at least three years. Documentation must show the equipment is double walled and the integrity of both walls is checked at least every 30 days. Double-walled spill buckets with periodic interstitial monitoring between the spill bucket walls are not required to meet the testing requirement
5 — Test release detection equipment annually (Yearly): Fuel site owners/operators must have release or leak detection monitoring equipment that will detect a leak from any portion of the UST system; and that leak detection equipment is installed and calibrated per the manufacturer’s instructions. Records of equipment testing must be kept for at least three years and must include every component tested, whether each component passed the test or needed to have action taken, and any action taken to correct an issue.
For internally lined USTs, please note that if the periodic internal lining inspection shows that the lining fails and cannot be repaired according to a code of practice, then that UST system must be permanently closed.
6 — Inspect overfill equipment (Every 3 Years): Site owners/operators are required to have a type of overfill protection. Overfill protection devices either shut off flow, restrict flow or alert the delivery operator when the tank is close to being full. These devices trigger an alarm if the regulated substances reach a certain level in the tank.
The three types of overfill protection are automatic shutoff devices, overfill alarms and flow restrictors. Flow restrictors in vent lines (ball floats) are no longer an approved method for overfill protection for UST systems. Existing units may remain; however, they must be replaced when they are no longer functioning properly.
Overfill protection devices must be tested to ensure they are operating as intended at least once within a three year period and records must be kept for three years.
7 — Review Class A, Class B and Class C Operators Certifications (Yearly): Certified Class A, Class B, and Class C operators must be designated for each retail or commercial/fleet fueling facility. A Class A operator is required to operate and maintain the UST system, a Class B operator is required to implement the UST regulations and the Class C operator must be trained to take appropriate actions in response to emergencies or alarms caused by spills or releases from the UST.
Class A and Class B operators must be formally trained and pass an examination by a recognized authority. The Class C operator can either be trained by a Class A or Class B operator; complete a training program; or pass an examination.
Recordkeeping is required for as long as the operator is assigned to the facility and retraining is required for Class A and B operators at facilities determined to be out of compliance.
Get to Know Your State Level Regulations & Enforcement Rules
State-by-state, regulations and compliance around UST’s are essentially the same, but enforcement of those regulations varies across the country. There are 38 states which are labeled as SPA (State Program Approval) states. SPA states meet or exceed federal requirements and regulations are enforced on the state level rather than the federal level. As for the remaining twelve states that are non-SPA states which include Alaska, Arizona, California, Florida, Illinois, Kentucky, Michigan, New Jersey, New York, Ohio, Wisconsin, and Wyoming, non-SPA states must work directly with the EPA to enforce the regulations.
Get Organized and Be Prepared
The new EPA regulations, documentation and record keeping standards for UST systems can appear to be a bit daunting and it may even be a little tempting to procrastinate – but don’t do that. Instead, start establishing and documenting the detailed processes and procedures sooner than later which will put proactive owners and operators ahead of the game. Whether it’s using a checklist found online or engaging an alarm and compliance monitoring service, the time is now to get organized.
Angela Wisdom, Senior Director at Insite360, a Veeder-Root Company. Wisdom is recognized as a leading authority in downstream petroleum process automation and operational excellence. Insite360 is the analytics business unit of Gilbarco Veeder-Root, a leading international fueling equipment and solutions provider. With over 20 years of fuel and environmental decision support experience, Insite360 helps optimize commercial and retail operations with inventory, purchasing, logistics and environmental compliance. Our portfolio of market leading products includes: Alarm and Compliance Management, HALO, Advanced Variance Analysis and Fuel Center. https://www.insite360suite.com/