The EPA published revised regulations on underground storage tanks that affect many facets of petroleum storage. Some of the changes include regular inspections of petroleum storage tank sites, added secondary containment, regulation of some previously exempt USTs, operator training and compatibility requirements for UST components. STP, Transition and UDC sumps are affected by the new rule as well. The purpose of this document is to help convey necessary information for compliance with new sump regulations and standards.
Regulatory Background:
The new federal rules became effective on 10/13/2015 and require compliance with the performance standards within the regulations no later than 10/13/2018 for sumps. EPA has long recognized that the size and diversity of the regulated tank community makes regulation on the state and local level preferable. For that reason, EPA encourages states to seek approval of their own program. Approved state programs will not be less restrictive than the federal program, so the federal requirements provide a good minimum standard to simplify the compliance discussion. States can have more restrictive requirements and tank owners/operators should check their local state regulations to make sure that additional requirements or earlier deadlines are not in place. The most recent information on approved state programs provided by EPA shows that 38 states, the District of Columbia (DC) and Puerto Rico all have achieved program approval as of September 2016. Many other states, such as Florida, are currently in the process of getting their programs approved.
States without program approval must enforce both federal UST regulations and state UST regulations.
The states with approved programs are: Alabama, Arkansas, Colorado, Connecticut, Delaware, Georgia, Hawaii, Idaho, Indiana, Iowa, Kansas, Louisiana, Maine, Maryland, Massachusetts, Minnesota, Mississippi, Missouri, Montana, Nebraska, Nevada, New Hampshire, New Mexico, North Carolina, North Dakota, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Utah, Vermont, Virginia, Washington, and West Virginia.
Sump Requirements:
The EPA relies heavily on industry practices. For sump compliance, the industry standard which can be used to comply with the federal testing requirements for sumps is PEI Recommended Practice 1200, Testing and Verification of Spill, Overfill, Leak Detection and Secondary Containment Equipment at UST Facilities.
The new federal regulations have four basic requirements related to sumps:
Sumps must be maintained in a water-tight condition and be inspected monthly to assure they do not have a water and/or product accumulation within the sump. The deadline for the implementation of these monthly “walkthrough inspections” is October 13, 2018, but many states already require monthly inspections.
Sumps used on systems storing biofuels and petroleum-biofuel blends must be proven compatible with the stored product.
UDCs (under dispenser containment sumps) must be installed after April 11, 2016 on all new dispenser systems.
Sumps must be tested in accordance with a recognized standard of practice (PEI RP 1200) at the time of installation for sumps installed after the effective date of the rule (already passed) and no later than October 13, 2018 for existing sumps. For single wall sumps, the testing must be repeated at least once every three years.
Our Recommendations:
Choose a contractor that you trust to do the work using approved components. Armor Shield of America, LLC has been site manufacturing sumps for more than 10 years. Our materials have been UL tested for use with modern fuels and we have numerous state approvals. Third party review by an independent testing laboratory is crucial to ensuring that you get what you pay for.
Plan in advance, especially if you have a large number of sites. As we have seen in the past, prices go up and availability of your desired contractor goes down as the deadline approaches. Don’t get stuck with your second or third choice at a price higher than your first choice would have been if you planned ahead. Remember, the deadline for compliance is just around the corner – October 13, 2018. Don’t let the deadline sneak up on you.
Armor Shield of America, LLC hydrostatically tests the sumps to the full capacity of the sump. Compliance standards referenced under federal regulations only require the test to be conducted 4 inches above the highest penetration of the sump wall, but this is an area where it is likely that some states will be more stringent than the federal rule. It doesn’t take any longer to perform and ensures that the entire sump is performing the way you want and need it to perform.
Armor Shield of America’s Sump Program
We will repair or use our insitu manufacturing process to ensure a water-tight sump meeting the requirements of regulation.
We will provide you with information and certification that your new/repaired sump is compliant with the regulations requiring UST components to be compatible with the fuel stored.
We will make sure that your sumps comply with federal, state and local requirements and let you know if there is a deficiency at your site.
We will meet or exceed the minimum testing requirements for testing your sumps. By doing an initial visual inspection and let you know if there are any problems which need to be addressed before the test.
For customers with a large number of sites we can:
Flat cost to repair a UDC Based on 100 sites or more
Flat cost to repair a STP Based on 100 site or more
Flat Hydro Test cost per UDC and STP.
More Information:
The EPA has developed a brochure to answer basic questions on tank top appurtenances such as sumps –
https://www.epa.gov/sites/production/files/2014-03/documents/sumps-manual-042805.pdf
You can get more information about and pricing on Armor Shield of America, LLC sump solutions by calling us at (513) 708-6200. We also have developed information on state programs and requirements. We update the information regularly as information becomes available and make it available to our customers.
Armor Shield of America, LLC has a long list of satisfied customers which we can provide upon request.
Make Armor Shield of America, LLC you sump solution contractor.
(513) 708-6200