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September 16th, 2015

EPA issues new UST regulations for the first time in more than 25 years

U.S. Environmental Protection Agency (EPA) has updated its underground storage tank (UST) regulations for the first time since 1988.epa_logo2

Changes include:

  • Adding secondary containment requirements for new and replaced tanks and piping
  • Adding operator training requirements
  • Adding periodic operation and maintenance requirements for UST systems
  • Adding requirements to ensure UST system compatibility before storing certain biofuel blends
  • Removing past deferrals for emergency generator tanks, airport hydrant systems, and field-constructed tanks
  • Updating codes of practice
  • Making editorial and technical corrections

These changes will be effective October 13, 2015.

EPA estimates that these updated regulations will result in fewer releases of petroleum into the surrounding soil and groundwater, leading to savings for UST owners for avoiding environmental remediation, vapor investigation, and product loss.  Overall, after taking the costs for compliance into account, EPA estimates the net cost savings to UST owners across the U.S. to be more than $160 million annually.

Since the State of Illinois is not part of the EPA’s SPA (State Program Approval), UST owners in Illinois must meet the federal requirements in addition to the Illinois requirements.

In Illinois, the Office of the State Fire Marshal (OSFM) regulates USTs.  According to the Division of Petroleum & Chemical Safety, Illinois has already implemented many of these requirements with the 2010 rewrite of tank regulations and 2012 Part 176 Subpart F Operator Training addition.

Some of the bigger changes in Illinois will be:

  • 30-day walk through inspections instead of the current quarterly inspections
  • 3-year containment testing for sumps and spill buckets
  • 3-year inspection of overfill equipment
  • Elimination of ball float valves in vent lines as flow restriction devices for new tanks

Most of these changes above have a 3 year implementation requirement, so Illinois will update its rules by 10/13/18 to include these revisions.  The ball float valve elimination is effective 10/13/15, but only for new tanks.  Existing devices may remain as long as they are working.

“For the most part, there will be little if any noticeable adjustment needed to be made by retailers in the short term,” said Fred M. Schneller, Division Manager of Petroleum & Chemical Safety.  OSFM continues to review the new regulations and will issue guidance to tank owners/operators in the coming months.

For more information on the EPA’s changes, visit the EPA’s “2015 Revised Underground Storage Tank Regulations” website.

If you have questions about the implementation of these regulations in Illinois, phone/email contact information for the Office of the State Fire Marshal can be found on their website.

April 11th, 2014

3 Things To Know About the New Phase I Standard

ASTM finalized E1527-13, the latest Phase I Environmental Site Assessment  standard on November 6, 2013.  EPA subsequently approved E1527-13 as being compliant with All Appropriate Inquiry (AAI) regulations on December 30, 2013.
Here’s the top 3 things you need to know about these updated regulations:

VAPOR

ASTM updated the definition of a REC (Recognized Environmental Condition) to specifically include vapor as a potential concern. Previously, it was left to the Environmental Professional’s discretion or their client to determine if vapor should be considered when performing a Phase I.  Environmental Professionals (EPs) must now consider solid, liquid and vapor releases of hazardous substances or petroleum products.

Bottom Line:  You may see more RECs now that include vapor issues.

CREC

ASTM added the term CREC (Controlled Recognized Environmental Condition) to better define sites which have past releases that have been properly addressed but still have a required control (eg: commercial/industrial land use restriction, engineered barrier, etc).

Bottom Line:  If you see a CREC, don’t panic.  A CREC is a “good REC.”  Gabriel can advise you and your client about any site-specific requirements regarding the continuing obligations.

FILE REVIEWS

ASTM states that agency file reviews should be conducted if the subject property or adjoining property is identified in any of the standard environmental records sources.  Previously, some EPs would review these government records during their Phase I assessments but many would not.  Now, these reviews must be included unless records are not reasonably ascertainable.

Bottom Line:  Other firms might increase their prices to include this additional work.  Gabriel has always done file reviews for these types of sites, so you will not see an increase in our prices to add in the file review.