On July 15, 2015, the United States Environmental Protection Agency (US EPA) revised the underground storage tank (UST) regulations. According to the EPA, the regulation was revised because, “Many USTs currently in the ground were upgraded to meet the spill, overfill, corrosion protection, and release detection requirements in the 1988 UST regulation. As these USTs continue to age, it is vital that we ensure they are still working as intended.”
Federal UST Regulation Changes
The revisions to the Federal regulation are substantial and primarily impact operator training and inspection requirements for regulated UST systems. However, Michigan owner/operators appear to be ahead of the game since many of these revisions are already in place under State rules.
Michigan UST Regulations Changes
Michigan enacted operator training and inspection rule revisions in 2009. As a result, those Michigan owners and operators that complied with the 2009 revisions by the August deadline back in 2012 will now be very close to meeting the new Federal regulations.
A comparison of the new Federal regulations to the Michigan regulations is provided in the following file: Comparison 211 vs 280 July 2015
Owners and operators of USTs need to comply with the new rules (Photo Credit: Dragun Corporation).
Regulatory Deadlines
The new Federal regulation becomes law on October 13, 2015. However, owners and operators have a three-year period (until October 13, 2018) to begin implementing the new Federal regulations for existing UST systems. For newly-installed UST systems (after October 13, 2015), owners and operators must immediately begin performing the new regulatory inspections. States also have three years to bring their programs into compliance with Federal regulation.
Now is the time to begin evaluating the impact from the new Federal regulations for training, inspection, and documentation requirements.
If you have any questions about these requirements or any other questions relating to USTs (including removal, responding to releases, etc.) please feel free to contact me (mresch@dragun.com) at 248-932-0228, ext 133.