EPA Regulations and Petroleum Equipment Institute RP-900
The EPA has released updated requirements for the operation and maintenance of UST systems effective October, 2018. According to Mathy Stanislaus, Assistant Administrator of the EPA’s Office of Solid Waste and Emergency Response, “These changes will better protect peoples’ health and benefit the environment in communities across the country by improving prevention and detection of underground storage tank releases.”
The EPA reached out to the industry affected by these guidelines, including NACS. John Eichberger, NACS Vice President of Government Relations, said, “NACS has been engaged with the EPA regarding these rules for nearly five years in order to ensure that the EPA took the concerns of the retail community into consideration throughout the process.”
The UST revisions 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;
Removing past deferrals for emergency generator tanks, airport hydrant systems, and field-constructed tanks;
Adding new release prevention and detection technologies;
Updating codes of practice;
Updating state program approval requirements to incorporate these new changes.
Many states already have these requirements in place and their practices will not have to change. However, other states will have new standards to adopt prior to the October, 2018 deadline or else face penalty.
But what does this mean for our customers—the station owners with three tanks, retailer chains with more than 500 stations, and everyone in between—how do these regulations affect them?
Beginning three years after the effective date, October, 2021, walk-through inspections will be conducted every 30 days to ensure EPA compliance. There are three options for these walk-throughs including:
Following the EPA checklist provided and composed by the EPA itself;
Following a standard code of practice developed by a nationally recognized association or testing laboratory, i.e. the American Petroleum Institute’s (PEI) RP-900;
Or through following your state’s guidelines set forth by the EPA.
The EPA requirements for these monthly walk-throughs include:
Checking the spill prevention equipment;
Release detection equipment;
Handheld release detection equipment (i.e. tank gauge sticks or groundwater bailers).
Overfill Prevention Equipment Inspections
Additionally, every three years owners and operators must have their overfill prevention equipment inspected. New equipment installed after the effective date must be inspected at time of installation and every three years following date of installation. These inspections must be performed in accordance with either:
The manufacturer’s guidelines;
The code of practice developed by a nationally recognized association or testing laboratory (again, API);
Or the requirements developed by your state, assuming they are no less stringent than that of the manufacturer’s recommendations.
Spill Prevention Equipment and Containment Sump Testing
When it comes to inspecting this equipment, there are two options:
Option One: The equipment is double walled and the wall integrity is checked at least as frequently as the walkthrough inspections—every 30 days for spill buckets and every year for containment sumps. If you stop this method of inspection, you have 30 days to conduct the test in Option Two.
Option Two: Spill prevention equipment and containment sumps used for interstitial monitoring of piping must be tested every three years—either by vacuum, pressure, or liquid testing. The test requirements are determined either by the manufacturer; a code of practice developed by a nationally recognized association or testing laboratory; or the regulations set forth by your governing state agency, assuming they are no less stringent than that of the manufacturer’s guidelines. Records of these tests must be kept on file for three years.
For equipment being monitored monthly, tank owners and operators must keep documentation that the equipment is double walled and that both walls are being checked for integrity.
Release Detection Equipment
Also beginning three years after the effective date, October, 2021, all electronic and mechanical components of the release detection equipment must be checked annually. These checks must be in accordance with either the manufacturer’s guidelines, a code of practice developed by a nationally recognized association, or the state requirements.
The following components must be inspected:
Automatic tank gauges;
Probes and sensors;
Automatic line leak detectors;
Vacuum pumps and pressure gauges;
Handheld electronic sampling equipment associated with groundwater and vapor monitoring.
Records of these inspections must be kept on file for at least three years. For complete details, visit the EPA website: http://www.epa.gov/oust/ustsystm/omreqs.html.
The Petroleum Equipment Institute has updated their Recommended Practices for the Maintenance of UST Systems: RP-900. The EPA is utilizing RP-900 as a code of practice that may be used to meet the EPA’s walk-through inspection requirements. RP-900 provides a consolidation of information ranging from equipment manufacturers; service and installation contractors; petroleum marketers; as well as regulatory agencies, regarding proper inspection and maintenance of UST systems. These recommendations apply to UST systems and ancillary equipment intended to store and dispense fuel at vehicle fueling locations. Covered equipment include all below grade, liquid and vapor handling components accessible from grade over or near the top of the tank and below the emergency shutoff valve at the dispensers.
Moreover, the EPA has listed RP-900 as an acceptable guideline to follow for these inspection requirements as it both meets and exceeds federal EPA requirements. While the EPA requirements do not specifically outline what qualifications are required for the individual performing the inspections, RP-900 has three different classifications which outline the types of inspections appropriate for each training level.
By utilizing the checklists and schedules provided by PEI’s RP-900, a station owner or operator will have written records of the inspections and an approved guide for any future inspections. Keeping an eye on tank accesses and equipment will help identify potential problems and weaknesses in the integrity of a system before disaster strikes. Nobody likes those kind of surprises—ever.
Having a list of routine inspections at regular intervals allows for continuity across sites and the peace of mind that comes with thorough monitoring. The goal is release prevention, equipment protection and liability reduction. In the end, it saves money, protects your reputation and safeguards your fuel supply. If you have questions or would like to discuss how Clean Fuels National can better assist you with the roll-out of the RP-900 program, please contact us at 260-346-2500. We look forward to hearing from you.