Basic UST Release Detection Requirements
Written by: Brian Pottebaum, Director of Training Services
Underground storage tank (UST) regulations were nationally enforced by the EPA in 1988, including a 10-year phase-in period that required all operators to upgrade their USTs. As part of these federal regulations, USTs were required to monitor petroleum storage tanks for leaks to reduce environmental contamination.
There have been very few modifications over the years, but recently more requirements have been added as a result of the EPA Energy Policy Act of 2005. Make sure you understand these and stay in compliance!
Size of tank
Underground tanks that are 110 gallons or less in total capacity are exempt from these regulations. Tanks containing a regulated petroleum product that exceed 110 gallons in capacity are regulated and must stay in compliance with all applicable State and Federal regulations, specifically 40 CFR Part 280.
Date of Installation
All tanks specified above are regulated regardless of when they were installed. However, the date of installation or upgrade can affect which regulations apply to that system. Make sure to keep track of records documenting when and what components were affected. One date to make special note of is April 11, 2016. That date marks when all federally regulated UST systems being installed or replaced must meet new EPA Secondary Containment Rules.
Secondary Containment
The secondary containment regulations have state specific deadlines and enforcement that may be different than the EPA deadlines. You will need to become familiar with the regulations that are being enforced in the state where your facility operates. Like many other states, Iowa began working on these new regulations that are part of the EPA Energy Policy Act of 2005 . Consequently, all tank systems installed or replaced in Iowa after November 28, 2007 must be secondarily contained, i.e. double-walled. This includes double-wall tanks and piping, as well as containment sumps under dispensers and at all piping connections, such as junction, transition, and tank top connection.
Additionally, this Federal regulation requires these affected systems to use secondary containment (or interstitial) monitoring as the primary method of tank and piping release detection. There are other operational and maintenance requirements that stem from the Energy Policy Act.
Release Detection Options
Originally, there were eight release detection options allowed by EPA. That list includes:
- Inventory Control (with tank tightness testing)
- Manual Tank Gauging
- Automatic Tank Gauging
- Vapor Monitoring (Well)
- Groundwater Monitoring (Well)
- Interstitial Monitoring
- Statistical Inventory Reconciliation (SIR)
- Other (something approved by the authority having jurisdiction)
As part of the secondary containment rule that was mentioned earlier, each state has a specific date that secondarily contained systems are required. Additionally, secondary containment (interstitial) monitoring must become the primary method of release detection. In Iowa, again that date is November 28, 2007.
Recordkeeping Requirements
Documentation of “passing” release detection monitoring is required every month to demonstrate compliance with state and federal regulations. Additionally, these records must always be maintained for 12 months and readily available to regulators. For example, if automatic tank gauging (ATG) is the primary method of tank release detection, the operator must retrieve a passing tank test report or printout from the monitor every 30 days for each tank. They must maintain that passing test for a full year.
This is very similar to secondary containment (interstitial) monitoring. The operator must document every 30 days that the monitor is not in alarm or indicating a leak from the primary tank wall. Unless the operator is checking and logging the interstitial space manually, the monitor (usually the ATG) will provide a printout, such as the sensor status report.
NEW Functionality Testing Requirements
Another recent change to UST regulations that was mentioned above is functionality testing of the release detection equipment. As of October 13, 2018 operators must test electronic and mechanical components of their release detection equipment for proper operation at least annually. Specifically, this requires testing and inspection by a knowledgeable person, typically a service provider. Monitors and controllers must be checked for proper system programming, functional alarms, and battery backup. Additionally, all probes and sensors (as part of primary release detection method) must be inspected for residual buildup, floats move freely, shafts are not damaged, cables are free of kinks and breaks, and the alarm system must be tested for proper operability and communication with the monitor/controller.