EPA’s Proposed New Tank Regulations
maintenance and operation of equipment, which
plagues the entire UST system—from spill buckets to
overfill equipment to release detection equipment.
Most states have passed requirements that go far
beyond the original federal regulations. Many state
regulations already fully implement provisions of the
EPAct and improve important aspects of the existing
requirements for periodic spill, overfill, secondary
containment and release detection testing, along
with periodic walkthrough inspections.
As part of operating and maintaining UST systems, EPA proposes that owners
and operators conduct walkthrough inspections at least once every 30 days.
and outdated federal regulations. It was time for the
federal government to catch up. What follows is a
discussion of the changes proposed by EPA that are the
most relevant to PEI members.
The most significant of EPA’s proposed revisions
focus on ensuring equipment is properly maintained
and operated so releases are prevented and detected
early in order to avoid or minimize potential soil and
The 1988 UST regulations required owners
and operators to install improved UST system
equipment to detect and prevent releases, but did
not require significant equipment operations and
maintenance activities. It was apparent soon after
the UST systems were upgraded that purchasing
and installing improved equipment alone would not
prevent and quickly detect releases. Equipment also
needed to be properly operated and maintained.
EPA recognizes this in its proposal by adding
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the effectiveness of walkthrough inspections. California
UST officials indicated that the monthly inspections
decreased the number of violations found, reduced
the frequency and duration of leak detection alarms,
prompted better recordkeeping, and resulted in overall
better operations at UST facilities.
As part of operating and maintaining UST
systems, EPA proposes that owners and operators
conduct walkthrough inspections at least once
every 30 days. Owners and operators would have the
option of hiring a third party to conduct walkthrough
inspections instead of performing the inspections
themselves. The walkthrough inspections are designed
to verify proper function or operating condition of
easily accessible UST system components and to
ensure required records are current. Equipment subject
to walkthrough inspections includes spill-prevention
equipment, sumps, dispenser cabinets, monitoring/
observation wells, cathodic-protection equipment and
release detection equipment.
EPA used PEI/RP900, Recommended Practices
for the Inspection and Maintenance of UST Systems,