This presentation, from the recent SIGMA Maintenance, Environmental & Safety Share Group, provides background on UST regulations and dives into the schedule, status, and requirements of the changes going into effect.

1. UST Regulations Update and Discussion
SIGMA Maintenance, Environmental & Safety Share Group
September 2018
New Orleans, Louisiana

2. Who has responsibility for tank system compliance?
Who has been tracking or involved in implementing the updated UST
regulations?
Who has commented on federal or state UST regulations during the rule
development process?
Who feels like their program complies with the new UST requirements now?
Introduction & Warm-up
UST Regulations Update and Discussion
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3. • Background & Overview
• Schedule
• Status
• Requirements
• Discussion Points
Agenda
UST Regulations Update and Discussion
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4. • In July 2015, EPA published revised underground storage tank
regulations, with the changes focused on:
• Operating and maintaining UST equipment and
• Preventing and detecting UST releases.
• This is the first major revision to the federal UST regulations since
1988.
• The 2015 changes to 40 CFR 280 incorporate the legislative changes to
UST programs from the Energy Policy Act of 2005. EPA also
incorporated new operation and maintenance requirements and
pulled in certain UST systems deferred in the 1988 UST regulation.
Background
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UST Regulations Update and Discussion

5. • Added secondary containment requirements for new and replaced tanks and piping
• Added operator training requirements
• Added periodic operation and maintenance requirements for UST systems
• Added requirements to ensure UST system compatibility before storing certain
biofuel blends
• Removed past deferrals for emergency generator tanks, field constructed tanks, and
airport hydrant systems
• Updated codes of practice
• Made editorial and technical corrections
Summary of Changes
UST Regulations Update and Discussion
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6. Primary Changes focused on testing and inspections via:
• Walkthrough inspections
• Overfill prevention equipment inspections
• Spill prevention equipment and containment sump testing
• Release detection equipment testing
These changes have an associated cost and may require implementation
of new internal processes/procedures/documentation
Regulations on Testing and Inspections
UST Regulations Update and Discussion
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7. • The 2015 State Program Approval (SPA) regulation also updated SPA
requirements in 40 CFR 281 and incorporated the changes to the UST
technical regulation under 40 CFR 280.
• Many states and territories currently have SPA but have to reapply in
order to retain their SPA status. Owners and operators in these states
must continue to follow their state requirements until the state
changes its requirements or until the state’s SPA status changes.
• Owners and operators in 16 non-SPA states and territories must meet
the federal requirements according to the schedule in the 2015 UST
regulation. In addition, owners and operators will need to follow any
additional state requirements.
State Led Programs
UST Regulations Update and Discussion
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8. March 2018
SPA Map
UST Regulations Update and Discussion
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9. • What does all that mean?
• Since 1988, state and territories have been required to adopt
regulations as stringent as the EPA regulations. EPA then approves
the state UST programs that are consistent with, but not
necessarily identical to, the federal regulations.
• Because of the changes in the federal UST regulations in 2015,
each SPA state that was approved under the 1988 regulations will
have to update their state regulations.
• The Deadline for complying with the new federal requirements
depends on the location/state of your facility .
State Led Programs
UST Regulations Update and Discussion
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10. • Each state is implementing their own program with their own
unique rollout dates, forms and procedures.
• There are states that will implement the major provisions simultaneously -
while other states will stagger the implementation of provisions
• There are several states where provisions are already in effect and some
states will not implement all until 2021.
• There are states that have not released their draft UST rules.
• The high variability in regulatory deadlines amongst the states means that
tank owners have to track state-by-state, month-by-month.
• The next slide highlights the dates for implementation of the four major
provisions by state….
Schedule
UST Regulations Update and Discussion
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State
Regulation
Effective Date Compliance
Deadlines
State
Regulation
Effective Date Compliance
Deadlines
Alabama 12/2017 10/2018 1 Missouri 5/2017 1/2020
Alaska Montana
American Samoa Nebraska
Arizona Nevada 12/2017 10/2018
Arkansas New Hampshire
California New Jersey 1/2018 10/2018
Colorado 1/2017 1/2020 New Mexico 7/2018 7/2021 4
N. Mariana Islands 4/2016 10/2018 New York
Connecticut North Carolina 1/2017 10/2018
District of Columbia North Dakota 4/2018 4/2021
Delaware Ohio 9/2017 10/2018
Florida 1/2017 10/2018 Oklahoma 9/2017 10/2018
Georgia 6/2017 12/2020 Oregon 6/2018 10/2020
Guam Pennsylvania
Hawaii 7/2018 7/2021 2 Puerto Rico 1/2018 7/2018
Idaho 3/2017 10/2018 Rhode Island
Illinois 6/2018 10/2018 South Carolina 5/2017 5/2020
Indiana South Dakota 6/2018 10/2021
Iowa Tennessee
Kansas Texas 5/2018 1/2021
Kentucky Utah 1/2017 10/2018 5
Louisiana Vermont
Maine Virginia 1/2018 1/2021
Maryland Virgin Islands
Massachusetts Washington 10/2018 3
Michigan West Virginia 6/2018 10/2018
Minnesota Wisconsin
Mississippi Wyoming 6/2018 10/2018
1 Spill Prevention Testing 8/2007
2 Spill Prevention Testing: Non FCT-
AHS Systems 8/2014; FCT-AHS 7/2019
3 Spill Prevention, Overfill Inspection,
Sump Testing: Facilities With Even ID
10/2020, Odd ID 10/2021;
Walkthrough Inspection 10/2019
4 Walkthrough Inspection 7/2018; Spill
Prevention, Overfill Inspection,
Sump Testing 7/2021
5 Walkthrough Inspection 1/2012
Compliance Deadlines For Major Provisions, i.e., Spill Prevention Testing; Overfill
Prevention Inspection; Sumps And UDC Testing; and Periodic Walkthrough Inspection
EPA Update – August, 2018

12. • Because EPA proposed only a 3-year window to implement the changes, an
attempt was made by Petroleum Marketers Association of America (PMAA)
to persuade EPA to defer the October 13, 2018 effective date to 2024.
• That proposal to extend the deadline was DENIED by EPA on July 24.
Pushback
UST Regulations Update and Discussion
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13. • Testing and Inspection Requirements were highly impacted by
the regulatory changes.
• We’ll list EPA’s key changes in the next few slides and then talk
about some nuances with different states and pain points.
• Most importantly, the dates on the following slides are FEDERAL
dates. EACH STATE may have a different schedule.
Testing and Inspections
UST Regulations Update and Discussion
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14. By 10/13/15
• No new ball float valves.
• Tank lining no longer performing to specification and cannot be repaired =
tank must be removed
• Notify UST agency within 30 days of taking ownership of an UST.
• Test systems following any repair.
• Newly installed emergency generator USTs must have release detection.
• Demonstrate fuel/system compatibility.
• Notify your UST Agency at least 30 days prior to storing fuels greater than
E10 or B20.
Testing and Inspections
UST Regulations Update and Discussion
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15. By 4/11/16
• Secondary containment and interstitial monitoring required for new
installations.
• Under dispenser containment (UDC) required when changing
dispensers.
• Line leak detectors required on new pressurized lines – sump sensors
alone don’t qualify
Testing and Inspections
UST Regulations Update and Discussion
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16. By 10/13/18
• Class A, B and C UST operators trained.
• Class C employee must be onsite.
• Train new Class A/Bs within 30 days.
• UDCs/sumps must be liquid tight.
• Upgrade to double-walled piping if 50% of a single-walled pipe
run is replaced.
Testing and Inspections
UST Regulations Update and Discussion
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17. By 10/13/18 (continued)
• Keep testing/inspection records for at least 3 years
• Must respond to all sump alarms.
• Deferred field constructed USTs and airport hydrant systems fully
regulated.
Testing and Inspections
UST Regulations Update and Discussion
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18. • Tightness testing of systems following repairs or upgrades.
Components cannot be put back into operation until testing
demonstrates tight – failure to do this has caused NOVs. Make sure
you pay attention to what your state’s Rules require on this topic!
• How are components regulated? For example, underground piping
connected to ASTs in MT are considered “tanks” and subject to UST
regulations
• Ball float valves not allowed in many states. Grandfather what you
have but you cannot replace if defective.
Testing and Inspections: Discussion Points
UST Regulations Update and Discussion
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19. Tank system compatibility with emerging fuels – some states require
proof of compatibility, permitting, application, and/or signage to
demonstrate compliance with the new rules.
• E15 plus
• BioFuels
• Others
Testing and Inspections: Discussion Points
UST Regulations Update and Discussion
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20. Hydrostatic testing – Water used for hydrostatic testing is wastewater
and must be disposed according to wastewater discharge requirements.
• For example, Texas is allowing low volume of water for testing and
reuse of that same water for multiple hydrostatic tests – a
compromise that came through the comment period.
• PMAA worked through a testing protocol with EPA – a low liquid level
integrity test as an alternative method for containment sump testing.
Testing and Inspections: Discussion Points
UST Regulations Update and Discussion
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21. Recordkeeping for Operator Training, testing, or inspections varies
widely from state-to-state:
• Some states are requiring Operators to get retrained due to their new
regs, e.g., TX, SC, IL.
• Make sure your operator training vendor is providing CURRENT
training and not content under the previous regulation.
• Also, Operator Training is now required for facilities that have
emergency generators powered by USTs – not your C-store, but your
office/HQ generator’s UST may become subject to the regulations.
Testing and Inspections: Discussion Points
UST Regulations Update and Discussion
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22. Schedule: Discussion Point
UST Regulations Update and Discussion
• How are you keeping abreast of
the differences between states for
implementation and procedures?
• Get involved and comment!
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STATES THAT ARE STILL IN COMMENT
PERIOD INCLUDE:
• In Progress: PA, SD
• Rule Finalization Pending: AK, IL
(final 10/13/18), WA (final
10/13/18)
• Waiting on Draft Rule (Comment
Period in future): CT, DC, IA, MD,
MA, MI, WI

23. Additional Resources
UST Regulations Update and Discussion
• https://www.epa.gov/ust/revising-underground-storage-tank-
regulations-revisions-existing-requirements-and-new
• https://www.epa.gov/ust/underground-storage-tank-ust-contacts
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24. Question or Comments?
UST Regulations Update and Discussion
Regarding the Presentation:
Bill MacDonald
Oil & Gas Segment Leader
Antea Group
801.560.3160
Bill.Macdonald@anteagroup.com
Regarding UST Operator Training:
Angela Dunn
Consultant
Antea Group
636.442.4758
Angela.Dunn@anteagroup.com
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