Chemicals, Special Topics in Environmental Management

EPA Proposes Changes to UST Regs

The comment period has closed and EPA is in the process of meeting with stakeholders and reviewing comments in preparation of a final rule to be published in late 2013.

Proposed changes include:

  • Adding secondary containment requirements for new and replaced tanks and piping
  • Adding operating training requirements
  • Adding periodic operation and maintenance requirements for UST systems
  • Removing certain tank deferrals
  • Adding new release prevention and detection technologies
  • Updating codes of practice
  • Updating state program approval requirements to incorporate these federal  rule changes
  • Making editorial and technical corrections

Now is the time to determine if you are in compliance with the most recent UST regulations! Join us for an in-depth webinar on July 29. Learn More

Secondary Containment

The Energy Policy Act of 2005 (EPAct) required states to implement additional measures to protect groundwater as a condition of receiving money from EPA. The EPA proposes to implement secondary containment and under-dispenser containment (UDC) to meet this provision. The proposed change will ensure secondary containment and UDC are required for all new and replaced UST systems across the country, including those in Indian country and in state without additional measures to protect groundwater requirements.

Federal regulations require secondary containment and interstitial monitoring for hazardous substance tanks only.

Operator Training

The EPAct required operator training in states that receive money from EPA. The proposed change will ensure that all operators across the country, including those in Indian country and in states without operator training requirements, are trained to prevent releases.

There are no current federal operator training requirements ~ only EPA guidelines in compliance with the EPAct.  EPA’s proposed operator training requirements include:

  • Owners and operators designated at least one individual for each of three classes of operators. Designated operators must be trained on minimum defined areas and may need to be retrained if the UST system is not in compliance.
  • Owners and operators retain a list of designated operators trained at each facility and proof of training or retraining.
  • EPA adds definitions for Class A operator, Class B operator, Class C operator, and training program.

Implementation of the federal operator training program would be phased in over three years based on tank installation date.

Get the latest updates on the recent 2012 UST regulatory changes and learn effective strategies for complying with those requirements. Join us for an in-depth UST webinar on July 29. Register Now

Operation and Maintenance

The 1988 UST regulations required equipment to be in place to reduce and prevent releases to the environment. Current rules require triennial cathodic protection testing, periodic internal lining inspections, annual line leak detector testing, and release detection equipment operation and maintenance according to manufacturer’s instructions.


The proposed regulations require UST owners and operators to conduct monthly walkthrough inspections which look at:

  • Spill prevention equipment
  • Sumps and dispenser cabinets
  • Monitoring/observation wells
  • Cathodic protection equipment
  • Release detection equipment

The proposed rule changes will ensure owners and operators are looking regularly at their equipment to catch problems early and prevent releases.


  • Comparison of 1988 UST Regulations and Proposed UST Regulations (October 2011) (Document 138745)
  • Federal Register Notice – Proposed UST Regulations (November 18, 2011)

See tomorrow’s Advisor to find out more details on the remaining proposed UST rules.

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