EPA’s New Information for Emergency Power Generator UST Systems Just Released

Big news from our friends at the EPA for emergency power generator UST operators: The EPA published a number of new documents to help emergency power generator tank operators with all aspects of UST compliance.

Here’s our favorite:

Federal UST Requirements for Emergency Power Generator UST Systems

Dear UST Colleagues,

I am pleased to announce several regulatory compliance and implementation assistance resources for emergency power generator UST systems are now available on the Office of Underground Storage Tanks (OUST) web site – https://www.epa.gov/ust/release-detection-underground-storage-tanks-usts-introduction#:~:text=003).%20May%202022.-,Emergency%20generator,-tanks

As most of you know, the federal UST regulation did not require release detection for UST systems that store fuel for use by emergency power generators (EPG) until the promulgation of EPA’s 2015 UST regulation. EPG UST systems contain unique features that are not typically characteristic of UST systems installed at conventional retail gas stations or convenience stores including aboveground day tanks, return product piping, and sometimes long complex pipe runs that begin underground and then go aboveground running within walls and extending through multiple stories of building structures. Prior to 2015, many EPG UST systems were understandably installed without consideration for meeting federal UST system release detection requirements. In addition, various fire code requirements are applicable to emergency power generator systems that may complicate complying with the release detection requirements.

This combination of unique features and complexities led OUST, with substantial assistance/input from state and industry UST experts, to develop the following important resources to assist owners & operators, regulators, service providers and other stakeholders with EPG regulatory compliance and implementation:

• Federal UST Requirements for Emergency Power Generator UST Systems: https://www.epa.gov/system/files/documents/2022-05/epg-ust-system-requirements.pdf
• • This booklet summarizes the full gamut of federal UST requirements for EPGs – installation, reporting, spill and overfill prevention, corrosion protection, release detection, walkthrough inspections, compatibility, operator training, repairs, financial responsibility, release response, and closure.

• • This also covers Spill Prevention Control and Countermeasures (SPCC) related regulatory requirements specific to emergency power generator UST systems.
• Owner and Operator Introduction: Automated Interstitial Monitoring Systems for Underground Pressurized Piping on EPG UST Systems: https://www.epa.gov/system/files/documents/2022-05/aim-systems-owner-operator-intro.pdf
• • This document describes a new option for EPG UST system owners and operators to use interstitial monitoring to meet the line leak detector requirement of the federal UST regulation. EPA has determined this option, termed “automated interstitial monitoring (AIM) system,” may be used to meet the dual release detection requirements for pressurized piping systems at EPG UST systems. This document provides basic information and introduces EPG UST system owners and operators to AIM systems.

• • The document also contains forms and checklists to assist with verifying AIM system compliance with UST implementing agencies and for complying with periodic testing requirements for AIM systems. AIM systems are optional, and UST implementing agency requirements may differ. UST system owners and operators should contact their UST implementing agency to determine whether they allows the use of an AIM system, and whether the forms and checklists meet the agency’s documentation requirements.

• • In Indian Country, where the federal UST regulation applies and AIM systems are allowable, UST owners and operators should submit forms to the applicable EPA regional office.
• In-Depth Discussion: Automated Interstitial Monitoring Systems for Underground Pressurized Piping on Emergency Power Generator UST Systems: https://www.epa.gov/system/files/documents/2022-05/aim-systems-in-depth-discussion.pdf
• • This document contains a more complete discussion about AIM systems (the introduction document does not address all issues). This includes background and technical information on the EPA’s recognition of using automated interstitial monitoring systems to meet federal release detection requirements for underground pressurized piping systems on EPG UST systems.

• • This document can also assist UST system installers, fuel system designers, and other qualified professionals when installing or modifying fuel storage systems to meet federal UST regulatory requirements for underground pressurized piping systems.
• Fillable PDFs for Certification of Compliance and Periodic Testing and Inspections of AIM Systems: https://www.epa.gov/ust/certification-inspections-and-testing-forms-automated-interstitial-monitoring-systems
• • These PDFs are fillable versions of the Certification of Compliance Forms and AIM Systems Inspection and Testing Checklists (these are the forms contained in both AIM documents above).

In addition to these new documents, a reminder that EPA previously provided responses to questions on several important issues regarding EPG UST systems.  EPA made these responses available to the public in our UST Technical Compendium about the 2015 Federal UST Regulations under the subject Emergency Power Generators: https://www.epa.gov/ust/underground-storage-tank-ust-technical-compendium-about-2015-ust-regulation. Q&A topics include:

·      Determining if emergency power generator systems must comply with federal UST regulation.
·      Release detection requirements for piping operating at atmospheric pressure.
·      Complying with National Fire Protection Association 110 to meet the federal UST regulation.
·      Visual-based assessments for above ground tanks (e.g. day tanks) that are part of EPG UST systems.

If you have questions regarding any of this material/information, please feel free to contact me directly at [email protected] (202) 566-1021 or Tim Smith at [email protected] (202) 564-0643.

Thank you to all in whatever role you play in successfully implementing, and meeting environmental compliance requirements for UST regulations across the nation. And a special thank you to those who directly contributed to the development and review of these new important resources towards that end.

Tony Raia

Director, Release Prevention Division
Office of Underground Storage Tanks (OUST)
U.S. Environmental Protection Agency
Office Number:  (202) 566-1021
Cell Number:  (202) 567-1647