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2018 UST Regulations Update: What You Need to Know

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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.

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2018 UST Regulations Update: What You Need to Know

  1. 1. UST Regulations Update and Discussion SIGMA Maintenance, Environmental & Safety Share Group September 2018 New Orleans, Louisiana
  2. 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 1Antea USA, Inc.
  3. 3. • Background & Overview • Schedule • Status • Requirements • Discussion Points Agenda UST Regulations Update and Discussion 2Antea USA, Inc.
  4. 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 3Antea USA, Inc. UST Regulations Update and Discussion
  5. 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 4Antea USA, Inc.
  6. 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 5Antea USA, Inc.
  7. 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 6Antea USA, Inc.
  8. 8. March 2018 SPA Map UST Regulations Update and Discussion 7Antea USA, Inc.
  9. 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 8Antea USA, Inc.
  10. 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 9Antea USA, Inc.
  11. 11. 10Antea USA, Inc. 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. 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 11Antea USA, Inc.
  13. 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 12Antea USA, Inc.
  14. 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 13Antea USA, Inc.
  15. 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 14Antea USA, Inc.
  16. 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 15Antea USA, Inc.
  17. 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 16Antea USA, Inc.
  18. 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 17Antea USA, Inc.
  19. 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 18Antea USA, Inc.
  20. 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 19Antea USA, Inc.
  21. 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 20Antea USA, Inc.
  22. 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! 21Antea USA, Inc. 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. 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 22Antea USA, Inc.
  24. 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 23Antea USA, Inc.
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