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EPA Proposes Revision to UST Regulations: Phasing out Groundwater and Vapor Detection

Author: The Author
Date: November 8, 2011

Contributed by Scott Wilson, President and CEO, REGENESIS

Last week the USEPA released proposed changes to the Underground Storage Tank (UST) Regulations.  While the revision is, by most accounts, long overdue a few of the proposed changes could be quite impactful for those involved in the sampling and analysis of groundwater.

The main thrust of the changes proposed by the EPA is to push UST owners to properly maintain and operate UST equipment.  As this is accomplished the emphasis for leak prevention and detection will be placed solely on equipment and not on the sampling of external media such as groundwater or vapors.

As currently proposed, the use of groundwater and vapor sampling to detect leaks will be phased out completely within the five year period following publication of the final regulation.   This move is in favor of using interstitial space sensors (all properly maintained of course!) along with inventory reconciliation techniques.  The EPA estimates that currently only 5% of operating USTs use groundwater and vapor sampling as part of their leak detection/prevention program—I’m not so sure this is the case.

Specifically the EPA’s proposal revises the UST technical regulation in 40 CFR part 280 by:

  • Requiring secondary containment requirements for new and replaced tanks and piping
  • Requiring operator training requirements for UST system owners and operators
  • Requiring periodic operation and maintenance requirements for UST systems
  • No longer allowing certain deferrals
  • Phasing out of groundwater and vapor monitoring in favor of new release prevention and detection technologies

To view a pre-publication version of the proposed UST regulations signed by EPA Administrator Jackson on October 25, 2011 go to this link: http://regenesis.com/regenesis-resource-center/developments/default.aspx   The section related to phasing out groundwater and vapor as a detection method is described in section IV.D.6

I’ll keep you posted.