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Time is Running Out to Comply with the 2015 EPA UST Rule

October 17, 2017


underground_storage_tank-1-3-2.jpgIt is amazing how time flies when it comes to complying with the 2015 Federal Underground Storage Tank (UST) rule promulgated by 40 CFR Part 280.   We outlined key provisions for you in this 2015 blog post. If you recall, the EPA established a three-year compliance window for many of the provisions that apply to your underground tank operation, such as containment testing, release detection monitoring, and overfill prevention.

With less than 12 months to go before the October 2018 compliance deadline, qualified resources who can perform the proper inspections for you are growing scarcer each month. As a result, waiting much longer could lead to you overpaying for services or missing the EPA deadline altogether.

But that does not mean you should rush off and spend your valuable budget on one-off inspections. Instead, there is a better way: incorporate compliance into the course of your normal business operations.

Gain Compliance During Your Next Annual Tank Inspection

It makes great budgetary sense to hire for EPA UST rule inspection services as a tie-in with your annual tank inspection. The right tank inspection contractor should have the capabilities and certifications required to help you get ahead of the EPA requirements, by incorporating the following activities in their upcoming inspections:

  • Hydrostatic Testing of Pump Sumps and Spill Buckets
  • Overfill Prevention Inspection
  • Containment Sump Inspections
  • ATG Operability Testing

Of course, if your annual tank inspection is too far off or has just occurred, then you should consider taking care of the required testing well in advance of the October 2018 deadline, and before contractor resources dry up. The right contractor should also be able to advise you on the broader set of EPA provisions and associated exceptions/quirks to the rules (and there are many of them). For example, there’s a good chance you will need to perform varied types of testing and reporting, depending on the state(s) in which you operate. That’s because, under the UST rule, states that receive federal monies from the EPA are required to meet the delivery prohibition, operator training, and groundwater protection requirements contained within the Energy Policy act of 2005.

By enlisting the help of a well-experienced contractor with a multi-state customer base, you can gain insights into inspection criteria and recommended remedial actions that are based on best practices from numerous sites across multiple states.

The bottom line is this: taking care of the required testing now or during your next regularly scheduled annual inspection will ensure that you stay one step ahead of your compliance requirements and avoid any business interruption.

Contact us if we can be of assistance.

Topics: Tanks

About this blog

Welcome to our postings on the environment and regulatory impact.  We strive to keep you informed with the latest changes in regulations and with lessons learned from our time in the field


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