We recently received this important and useful email from Carolyn Hoskinson, Director of EPA’s Office of Underground Storage Tanks. It’s a great national recap of the one year anniversary of the new EPA rules. And we at UST Training have updated our Class A/B UST operator training courses to include the new rules. Please read and share.
Dear UST Community:
Etiquette guides will tell us that the traditional gift for a First Anniversary is paper…. Well, here’s an email instead! Maybe you could pretend you’re reading it on good, old-fashioned paper.
This past Sunday, October 13, 2019, marked the one year anniversary of the October 2018 deadline for meeting the major underground storage tank (UST) requirements in the 2015 federal UST regulation; see www.epa.gov/ust/revising-underground-storage-tank-regulation-revisions-existing-requirements-and-new. I am writing to thank you for your continued efforts in implementing this regulation, provide you with a few reminders, and share our observations about this past year.
For your dedicated efforts, I send an enormous thank you to state and tribal UST programs; owners and operators; testers; and others in the UST community who have been working hard to ensure compliance with these requirements, and, as a result, protecting human health and the environment! Whatever role you play in the UST community, whether you’re an owner or operator of USTs, or an UST contractor or manufacturer providing important services and products to help owners and operators comply, or a state or tribe or EPA region conducting critical compliance inspections, or some other role I haven’t named, we here at EPA appreciate your accomplishments!!
Also, I thank states who are working through the process of applying, or for the vast majority re-applying, for program approval. I acknowledge that progress may be slow—admittedly only 6 states are completely approved; see www.epa.gov/ust/state-underground-storage-tank-ust-programs#which—but we anticipate a surge in the number of states receiving program approval in 2020.
As tribes continue to implement the 2015 federal UST regulation and states implement their individual UST regulations, we are hearing many similar questions for regulatory clarifications. To help you deal with these recurring questions, we developed an online question and answer compendium about the 2015 federal UST regulation; see www.epa.gov/ust/underground-storage-tank-ust-technical-compendium-about-2015-ust-regulation. In addition, during 2020 we plan to improve the compendium by elaborating on and further clarifying several answers, as well as making the compendium easier to use.
For those handful of states who have not already revised their state regulations to reflect the 2015 federal UST regulation, please remember that as you finalize your state regulations, compliance deadlines must be effective by October 2021.
Since the October 13, 2018 deadline, we learned of anecdotal evidence suggesting compliance concerns related to timeliness of sump testing, spill prevention equipment testing, and overfill inspections. In March 2019, we issued a compliance advisory; see www.epa.gov/ust/compliance-advisories-about-2015-underground-storage-tank-regulation. And we are hearing this continues to be a compliance area that needs ongoing attention. Our mid-year data from states reporting the new compliance measures was that 48.4% of inspected facilities met the new Technical Compliance Measure. We are still compiling data for the end of year results. Clearly, we have more work to do together.
Again, we appreciate the continued dedicated effort and work by state and tribal UST programs; owners and operators; and others in the UST community in meeting all regulatory compliance requirements. As always, I thank you for all that you do to help us keep our environment safe from petroleum UST releases, which are a leading source of groundwater contamination.
If you have questions, ideas, or feedback on what EPA can do to better assist you in achieving compliance, please contact me or Tony Raia (firstname.lastname@example.org; 202-566-1021).
Carolyn Hoskinson, Director
Office of Underground Storage Tanks, US EPA
202-564-2564 or Hoskinson.email@example.com