To help facility owners and operators comply with US EPA’s extensive Underground Storage Tank (UST) requirements—including changes
that take effect in October 2018—Lion Technology launched a new online course:
Underground Storage Tanks. Designed for owners and operators, EH&S professionals, and environmental consultants, the
new online course will help you identify the tanks and chemical substances subject to changing EPA UST regulations in 40 CFR Part 280.
The Original EPA Underground Storage Tank Rules
Initially crafted between 1984 and 1988, the original underground storage tank regulations were created in response to the first generation of buried tanks—constructed of steel and other metals—leaking and corroding after decades underground, releasing their contents and wreaking environmental havoc.
The major program areas of EPA’s UST regulations reflect these concerns. They are: - Design requirements for USTs;
- Methods for detecting spills and leaks from USTs;
- Corrective measures following a UST leak; and
- Financial liability and closure costs associated with UST systems
What’s Changing for UST Owners and Operators in 2018?
EPA’s 1988 UST regulations carved out several exclusions and deferrals for different types of Underground Storage Tanks.
In 2015, EPA eliminated some of these deferrals in a Final Rule. As of October 13, 2018, the following types of tanks will no longer be deferred from regulation under the underground storage tank requirements:
- USTs for emergency power generators;
- Airport hydrant fuel distribution systems; and
- Field-constructed tanks.
For the most part, USTs constructed
after October 13, 2015 are already subject to the bulk of the UST requirements. Now, some
older tanks that were previously deferred or excluded from UST regulation must meet EPA standards including rules for UST operation, UST operator training, release detection, release reporting, closure, financial responsibilities, EPA notification, and closure.
What is an Underground Storage Tank?
To understand how EPA regulates underground storage tanks, we can look to definitions in 40 CFR Part 280. Remember, terms like “tank” or “underground” can have different meanings across different statutes and regulations, and relying on a dictionary definition won’t help much. As you will see below, what we typically think of as “underground” does not necessarily match up to EPA’s definition.
A “tank” is
“a stationary device designed to contain an accumulation of regulated substances constructed of non-earthen materials (concrete, steel, plastic, etc.) that provide structural support.”
An “underground storage tank” is:
“any one or combination of tanks including any underground pipes connected to the tanks used to accumulate a regulated substance(s), and the volume of which (including the volume of pipes connected thereto) is 10% or more is beneath the surface of the ground" (40 CFR 280.12).
You read that right. If 10% or more of your tank, including the piping, is underground, you’ve got an underground storage tank. In other words, a tank that’s 90% above ground is still regulated by EPA as an underground storage tank.
Have questions about USTs? Ask us on LinkedIn or email info@Lion.com.
Underground Storage Tank (UST) Training
Find out what you need to know to manage underground storage tanks—including previously deferred USTs—in the new Underground Storage Tanks Online Course at Lion.com. Compliance with EPA’s UST rules is critical to prevent releases, protect the environment, and costly EPA fines.