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Underground Storage Tanks and the EPA's Final Rule

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How Does This Affect You?

In the first major revision to the federal Underground Storage Tanks (UST) rules since 1988, the Environmental Protection Agency (EPA) published its [final rule]1 on the subject last summer. The new standard passed on July 15, 2015 and includes new containment, training, maintenance, and other requirements. The deadlines for meeting the new requirements are starting to pass for those who fall under the federal regulations.

The Key Dates for the EPA Requirements

  • October 13, 2015 - first phase of new requirements
  • April 11, 2016 - second phase of new requirements
  • October 13, 2018 - deadline for all remaining changes

Different requirements and timeframes will apply, depending on the location of your business, specifically whether or not your state has a State Program Approval (SPA). [Nationwide]3, 38 states (plus DC and PR) have SPA, and 16 do not. 

In the west, California, Arizona and Wyoming do not have SPA. Owners and operators in those states must meet both the 2015 UST regulation and their state requirements. UST SPA are in place in the remaining states in the western half of the continental US. Owners and operators in Indian country must meet the 2015 UST requirements. 

Because owners and operators in non-SPA states must comply with two sets of regulations, the EPA suggests meeting the more stringent requirements. 

Operators in SPA states need to be aware of possible changes to their SPA as various states move to bring their SPA in line with the new EPA standards. The EPA expects that many states with SPA will exceed the federal requirements, and may even impose shorter time frames.

Play it Safe and Plan Ahead

Although many operators have nearly three years to comply with the new requirements, we urge you to start planning now to make sure you are in compliance sooner, rather than later. Costs will always be a factor, and starting sooner will let you spread many of the costs out over multiple years. 

Contact your Shields Harper representative to make sure your site is compliant before the EPA deadlines. Being compliant earlier will also let you 'beat the rush' so to speak, and avoid possible delays in materials and staff as less ready outfits scramble at the last-minute.

The EPA has released an FAQ document for quick reference, and contacts are available for those who need specific information.