Materials Performance Supplements

TANK 2018

Materials Performance is the world's most widely circulated magazine dedicated to corrosion prevention and control. MP provides information about the latest corrosion control technologies and practical applications for every industry and environment.

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22 MAY 2018 W W W.MATERIALSPERFORMANCE.COM TANK CORROSION CONTROL SUPPLEMENT TO MP Kathy Riggs La R sen and Ben d uBose, Materials Performance 2018 Deadline Nears for New U.S. Underground Storage Tank Rules The third and final deadline for under- ground storage tank (UST) owners and oper- ators to meet new federal requirements from the U.S. Environmental Protection Agency (EPA) (Washington, DC, USA) for spill, over- fill, and corrosion protection is October 13, 2018. By that date, UST managers must fully comply with the agency's latest UST regula- tions, which were effective on October 13, 2015. The final deadline of the three-tiered process comes after two prior due dates of October 13, 2015, and April 11, 2016. 1 The exact steps UST owners and opera- tors must take—and additionally, who they must report to in 2018 as part of the compli- ance process—vary based on location. In general, EPA says that because of the size and diversity of UST assets, it recognizes that state and local authorities are in the best position to oversee because they are closer to each individual situation and can set appropriate priorities. Once state legisla- tures enact statutes, and state agencies develop UST regulations in accordance with EPA requirements and put other compo- nents of a program in place, states may apply for formal approval , and the EPA must respond within 180 days. Each state plan is approved if it meets a range of criteria, which include the establishment of standards for eight performance criteria that are no less stringent than federal rules; provisions for adequate enforcement; and regulation of at least the same USTs that are regulated under federal standards. Once approved, states have the lead role in UST program enforce- ment, and UST owners and operators in states with an approved program do not have to deal with two sets of statutes and regulations (state and federal) that may be conflicting. In states without an approved program, EPA works in tandem with state officials in coordinating UST compliance. As of September 2017, 38 states, the Dis- trict of Columbia, and the Commonwealth of Puerto Rico have approved state pro- grams. Those states must reapply to retain their approved program status by October 13, 2018. As part of that application process, th e stat e must demonstrat e "adequat e enforcement" procedures and show how it enforces the technical regulations to any asset owner or operator not in compliance. In those states, UST owners and operators Tank Protection Articles work with state authorities to show compli- ance for their asset(s). In states and U.S. ter- ritories without program approval, owners and operators must work with both state and federal authorities. In both cases, new requirements that owners and operators must comply with by October 13, 2018 include site assessment records for groundwater and vapor moni- toring, along with enhanced operator train- ing. UST owners and operators must also conduct the first test or inspection on areas that include spill prevention equipment, overfill prevention equipment, containment sump testing for sumps used for piping interstitial monitoring, release detection equipment, and walkthrough inspections. Further details on these subject areas and others pertaining to the new UST regula- tions can be found at the EPA web site, www.epa.gov/ust. UST Regulatory Background In the United States, according to the EPA, petroleum or hazardous substances are stored in ~566,000 USTs. These USTs are located at hundreds of thousands of facili- ties across America . Contamination of groundwater, the drinking water source for almost half of all Americans, is the greatest potential threat from leaking USTs, which are one of the leading sources of ground - water contamination. 2 U.S. UST regulations require owners and operators to design, construct, and properly install UST systems in accordance with industr y codes and standards, and according to the manufac- turer's instructions. UST owners and opera- tors must follow correct filling practices and protect their USTs from spills, overfills, and corrosion. Additionally, owners and operators must report the existence of new UST systems, suspected releases, UST sys- tem closures, and keep records of operation and maintenance. As part of the 2015 revision, all USTs States in green have UST regulatory programs approved by the EPA. Image courtesy of EPA.

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