Client AlertsTime to Revisit Your UST Protocols!

August 16, 20150

On July 15, the Environmental Protection Agency (“EPA”) published final revisions to its Underground Storage Tank (“UST”) regulations. This publication represents the first time in 27 years that the EPA has significantly revised these rules.  The changes reflect improved technologies, address outdated requirements, and place a stronger emphasis on UST operations and maintenance.  For example, the regulations require that designated operators be trained in certain areas of operation (depending on the operator class) and possibly retrained if the UST system is found incompliant.  That requirement, in addition to the requirements for routine UST inspections and testing, must be implemented within three years of the effective date (October 13, 2015) of the regulations.  Within 180 days of the effective date, owners and operators must install secondary containment and under-dispenser containment for all new and replaced UST systems (with certain limited exceptions).  Other requirements, such as updating technology for vent lines and internal lining and notifying implementing agencies of UST ownership changes, are effective immediately on October 13, 2015.


Notably, the rule gives all states with a state UST program (and RI and MA each have a UST program) three years after the effective date to incorporate the new federal standards into their state regulations.  In the meantime, owners and operators in these states (such as in RI and MA) are subject to state and revised federal regulations.

The EPA’s UST page provides a link to the full Federal Register publication and a detailed chart comparing the revised 2015 UST Regulations with the earlier 1988 UST Regulations.  For more information on how these revised regulations may impact your business or UST protocols, feel free to give us a call.

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