EPA’s Proposed New Tank Regulations
health and the environment than the first two test
EPA proposes that an annual spill-bucket test
not be required for a double-walled spill bucket with
continuous interstitial monitoring.
EPA proposes that owners and operators meet the
requirements, a code of practice developed by a
nationally recognized association or independent test-
ing laboratory, or equally protective requirements de-
veloped by the implementing agency). In response to
this proposed regulation, EPA anticipates associations
or testing labs will develop codes of practice for overfill
EPA proposes that owners and operators test the proper operation of
overfill prevention equipment (automatic shutoff devices, flow restrictors
and high level alarms) at installation and at least once every three years.
spill-prevention equipment requirement within one
year of the effective date of the final UST regulations for
existing UST systems and at installation for UST systems
installed after the effective date of the final regulations.
Owners and operators must maintain records of spill-prevention equipment testing for three years.
EPA proposes that owners and operators test the
proper operation of overfill prevention equipment
(automatic shutoff devices, flow restrictors and high
level alarms) at installation and at least once every three
years. EPA proposes that the testing be in accordance
with a staggered implementation schedule based on
the installation date of the oldest UST at the facility.
EPA hopes the staggered phase-in approach will allow
overfill prevention equipment tests to be spread out,
reducing the last-minute rush of owners and operators
obtaining overfill prevention equipment tests at the end
of the initial three-year period.
EPA proposes that owners and operators use
the same three testing criteria for overfill prevention
devices as they would for spill buckets (manufacturer’s
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prevention equipment tests, and manufacturers will
develop testing requirements. If not, the “
implementing agency” option will provide another approach.
In §280.36, EPA proposes owners and operators
test secondary containment areas that use interstitial
monitoring at least once every three years on a staggered schedule similar to that required for overfill-prevention devices and cathodic-protection testing.
Secondary containment areas include tank and piping
interstitial areas, as well as containment sumps used as
part of the piping secondary containment and interstitial monitoring. EPA is proposing owners and operators
test interstitial integrity areas using a vacuum, pressure
or liquid method according to one of the three options
available to test spill- and overfill prevention equipment
listed above. Owners and operators using continuous
interstitial monitoring on their tanks, piping and/or
double-walled containment sumps will not have to
perform interstitial integrity tests.
The secondary containment requirement
proposed by EPA only applies to UST systems using