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National EPA 2018 Deadline Stands - UST Training

August 10, 2018


TULSA, Oklahoma, Aug. 8, 2018/Petroleum Equipment Institute/ — U.S. owners of underground storage tanks (USTs) need not fear a contractor shortage after the Environmental Protection Agency’s (EPA’s) July 24 denial to extend by six years its Oct. 13 compliance deadline for portions of the 2015 federal UST regulations.

Several trade associations, 25 U.S. senators and 20 U.S. representatives requested the extension. The parties questioned the feasibility of testing and inspection requirements in the 2015 EPA regulations and the availability of qualified contractors.

“There are plenty of qualified PEI member companies and techs to perform the initial walk-through inspections, as well as the testing of sumps, spill buckets and overfill prevention devices,” said Rick Long, executive vice president and general counsel at PEI. “The fuel handling industry doesn’t live by deadlines — it lives by doing what’s right for the environment. PEI members are working hard and using solid, proven procedures to help tank owners and operators confirm the integrity of their underground fuel storage systems.”

The 2015 regulations specifically recognize two of PEI’s peer-reviewed documents as codes of practice that may be used to meet many of the inspection and testing requirements.

Brad Hoffman, vice president of engineering and R&D at Texas-based testing and compliance company Tanknology Inc., chairs the committee responsible for PEI/RP900: Recommended Practices for the Inspection and Maintenance of UST Systems.

RP900 is a comprehensive inspection program that can be used by conscientious tank owners and operators to meet the federal UST inspection requirements,” Hoffman said. “RP900 includes many key elements that are missing from the monthly and annual EPA inspections, and it provides a substantial reduction in risk compared with the minimum inspection requirements.”

In declining to extend the deadline, the EPA explained that the testing and inspection requirements in its 2015 UST regulations focus on the components most likely to leak or fail to detect leaks. Extending the compliance deadline, the EPA stated, “could result in releases not being identified and addressed for many years” and “could unintentionally do more harm than good.” The letters encourage tank owners to arrange testing and inspections as soon as possible.

Hoffman explained why some tank owners haven’t arranged testing and inspections.

“We’ve been performing inspections, testing and repairs for most of our major clients for many months now to ensure compliance with the upcoming deadlines,” he said, “but we’ll also be talking with tank owners who may have waited to take action in hopes that the deadline would be extended.”

Ed Kubinsky, director of regulatory affairs, training and certification at Crompco, a Pennsylvania-based UST testing and compliance company, chairs the PEI committee responsible for PEI/RP1200: Recommended Practices for the Testing and Verification of Spill, Overfill, Leak Detection and Secondary Containment Equipment at UST Facilities. The 2015 regulations state that the procedures in RP1200 may be used to satisfy the testing requirements for spill buckets, containments sumps and overfill prevention devices.

Kubinsky said testing companies will work with tank owners to meet the deadline, but owners need to schedule the work now.

“With the October deadline for the first round of spill bucket, containment sump and overfill equipment testing and inspections just a few weeks away in several states, Crompco and many other testing companies are extremely busy,” Kubinsky said. “As other states implement their regulations and due dates, tank owners should plan well ahead and schedule the required work. Don’t wait until the last minute to try to squeeze it in.”

To connect with qualified PEI member companies across the U.S. that can perform the required inspections and tests, visit

PEI recommended practices, including PEI/RP1200 and PEI/RP900, are printed on demand and are available immediately as downloadable PDFs. Prices are $40 for PEI members and $95 for non-PEI members. Visit for mor

e information.

To determine whether UST systems are located in states with state program approval (SPA), which may have different compliance deadlines than those set by the EPA, visit




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