Overview of Revisions to

Regulations for Formerly Deferred

Underground Storage Tank (UST)

National Tanks Conference

September 14, 2015
 When will the requirements start in your state?

• In states without state program approval (SPA) and in Indian country,

the new requirements will apply according to timeframes specified in the
2015 UST regulation.
• In states with SPA, none of the new requirements will apply until the state
adopts the federal requirements or if a state does not adopt the
requirements, until EPA withdraws approval of SPA for that state. Owners
and operators in states with SPA must continue to meet the state UST
requirements.
Does my state have SPA?
 What are these tanks and why were they
deferred in the 1988 UST regulations?
Tank category
• Emergency generator tanks
• Wastewater treatment tanks
(not covered by the Clean Water Act)
• USTs containing radioactive
materials
• NRC emergency generator
tanks
• Field-constructed tanks
• Airport hydrant systems
Reason for deferral
 Release detection not
available for some sites
 Uncertainty of the universe and
appropriateness of some UST
regulations
 Sufficient information and
technology (release detection
and prevention equipment) not
readily available
 Emergency Generator Tanks
1988 Regulation 2015 Regulation

• Deferred from subpart D. • Removed the deferral and

requires release detection for
EGTs.
• Release detection required
October 13, 2018 for systems
installed on or before October 13,
2015.
• Release detection required
immediately for systems installed
after October 13, 2015.
Wastewater Treatment Tank Systems, USTs Containing
Radioactive Materials, and Emergency Generator USTs
at NRC facilities

1988 Regulation 2015 Regulation

• Deferred tanks from subparts B,
C, D, E, G, and J.
• Reclassified tanks as partially
excluded.
• Will continue to regulate tank
installation under subpart A and
cleanup of releases under subpart
F.
Field-Constructed USTs and Airport Hydrant Systems
1988 Regulation 2015 Regulation
• Tanks deferred from subparts B, C, • Provided more specific requirements.
D, E, G, and J. –Created subpart K
–Defined FCT and AHS
–Provides exceptions to secondary
containment and walkthrough inspections
requirements
–Provides options for meeting release
detection requirements
–Implementation date depends on
requirement
– October 13, 2015
– April 11, 2016
– October 13, 2018
–Partially excludes aboveground
components associated with these systems
 Is Your Airport Hydrant System a Regulated UST?
REMEMBER

• These systems are unique.

• Perform the calculations.
• Only components that fuel
aircraft are part of the airport
hydrant system.
 Additional Information
• OUST Website on Revised
Regulations
http://www.epa.gov/oust/fedlaws
/revregs.html

• OUST Contacts
Erin Knighton at
Knighton.erin@epa.gov
or 703-603-8774

Elizabeth McDermott at
mcdermott.elizabeth@epa.gov
or 703-603-7175