I recently attended the National Institute for Storage Tank Management ( You may or may not know there’s an office in Washington DC that directs national UST policy and works with states, territories and tribes to help those agencies implement their tanks program at a local level.
EPA has been working since 2011 to add some enhancements to the national UST rules that would, if adopted, trickle down to states/territories/tribes over the next three years or so. Latest Official Word: Rules are supposedly getting their final reviews soon and could be adopted by fall of 2014. Some rule changes may or should include:
- Monthly Inspections. A trained Class A/B operator would be required to do a brief monthly site walk through to make sure nothing was out of compliance and release detection records were being properly stored. States like Colorado and Wisconsin already require this and many of our customers do this anyway plus we suggest it in our training.
- Equipment Testing. What’s still leaking? Sumps and spill buckets. What equipment can malfunction after a few years? Sensors and alarms. The proposed equipment testing rules using PEI RP 1200 should tackle nearly all the parts of the tank system that fail but currently don’t require testing.
- Deferred Tanks. Technically many tanks out there used for emergency power generation that don’t have to do release detection and the new rules would require it moving forward. Nearly all the generator tank operators we know do it anyway.
- Tribal rules. USTs on tribal lands would be updated to include what the rest of the states are mostly doing: operator training, delivery prohibition, and mandatory interstitial monitoring.
As soon as we get more updates about the proposed rule changes we’ll keep you updated.