Changes Coming to the Underground Storage Tank Regulations in PA by Steve J. Treschow, P.G., CPG
Changes Coming to the Underground Storage Tank Regulations in PA
In July of 2015, the United States Environmental Protection Agency (EPA) published the 2015 underground storage tank regulation and the 2015 state program approval regulation. The revisions strengthened the 1988 Federal Underground Storage Tank (UST) regulations which focused on requiring basic equipment and infrastructure. The 2015 revisions focused on properly maintaining, operating, and repairing the equipment, as well as addressing previously deferred tanks and updating for new technologies. The revisions will help prevent and detect UST releases, which are a leading source of groundwater contamination. The revisions will also help ensure all USTs in the United States, including those in Indian country, meet the same minimum standards. This is the first major revision to the federal UST regulations since 1988.
The 2015 UST regulation changes certain portions of the 1988 underground storage tank technical regulation in 40 CFR, part 280. The changes establish federal requirements that are similar to key portions of the Energy Policy Act of 2005. In addition, EPA added new operation and maintenance requirements and addressed UST systems deferred in the 1988 UST regulation. The 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; and,
- Making editorial and technical corrections.
The 2015 state program approval (SPA) regulation also updates SPA requirements in 40 CFR part 281 and incorporates the changes to the UST technical regulation listed above. In states with SPA (such as Pennsylvania), none of the new requirements will apply until the state adopts the federal requirements or if a state does not adopt the requirements, until EPA withdraws approval of SPA for that state. Owners and operators in states with SPA must meet the state UST requirements. States such as Pennsylvania have 3 years to submit a revised SPA application.
In summary, Pennsylvania has up to 3 years to adopt the new federal UST regulations. This 3 year window provides the owners and operators of USTs time to get their personnel trained and time for tank contractors to become familiar with the new regulations. P. Joseph Lehman, Inc., Consulting Engineers has personnel who are a member of the PA Storage Tank Advisory Committee (STAC) and are certified 
as UMR (UST removal), AMR (AST removal), and UMX (UST inspection). Therefore, we can assist you with maintaining compliance with the changing regulations.
Steve Treschow is a Professional Geologist at P. Joseph Lehman, Inc., Consulting Engineers working in the Environmental Department. He can be reached through email at streschow@lehmanengineers.com or by calling 814-695-7500.
