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EPA issues compliance advisory for USTs

Document highlights owner, operator responsibilities, compliance concerns

Posted March 15, 2019

EPA has issued a compliance advisory for facilities that are required to comply with its underground storage tank (UST) regulation. EPA says the focus of the compliance advisory is on UST owners and operators in states without state program approval (SPA) and in Indian Country, but notes that owners and operators in states both with and without SPA must meet their state UST regulatory requirements.

EPA says it has observed several compliance concerns when implementing its 2015 UST regulation, including failure to complete the following requirements on time:

  • Sump testing
  • Spill prevention equipment testing
  • Overfill inspection

The advisory reminds UST owners and operators of the testing and inspection requirements in 40 CFR 280.35, and notes that they must test their spill prevention equipment every three years to ensure it works as intended and is able to hold liquid.

In addition, UST owners and operators who use interstitial monitoring must test their containment sumps every three years to ensure the release detection is working and will contain product that escapes their USTs.

The requirement also includes inspecting overfill equipment every three years to ensure it is working as intended. EPA says owners and operators were required to complete the first tests and inspections under this requirement by October 13, 2018.

Toxic Release Inventory (TRI Form R) Reporting ServiceJ. J. Keller's Environmental Compliance for the Workplace Manual addresses major environmental issues, including permitting, planning, and training.


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