Explaining the Revised UST Regulations

How will the new regulations affect me?

The Environmental Protection Agency (EPA) is proposing revisions to strengthen the 1988 federal underground storage tank (UST) regulations by increasing emphasis on properly operating and maintaining UST equipment. The EPA website presents the planned regulations plus extra information to help UST stakeholders understand the proposed changes: http://www.epa.gov/oust/fedlaws/proposedregs.html. Additionally, this PDF
explains how the proposed revisions differ from the 1988 regulations: http://www.epa.gov/oust/fedlaws/Crosswalk.pdf.

The proposed changes will impact secondary containment systems, operation and maintenance procedures, as well as a host of other areas. One particularly notable change is that the proposed regulations will no longer allow flow restrictors (a.k.a. ball float valves) in vent lines. Section IV.D.1 states: “This proposed change no longer allows flow restrictors in vent lines for new and replaced systems. Owners and operators must use one of the other overfill prevention methods listed in 40 CFR part 280.”

While some of the regulation changes will be introduced with implementation delays, the amendment to flow restrictors in vent lines is planned for immediate implementation, and will affect all new and replaced systems.

The new regulations also specify new provisions for the operation and maintenance of USTs, including testing and detection requirements. Section IV.B.3 specifically deals with
Overfill Prevention Valve (OPV) testing and states that owners and operators must “test every three years to ensure equipment is set to activate at the appropriate level in the tank and will activate when regulated substances reach that height.”

As well as testing requirements for OPVs, the new regulations also suggest testing requirements for Spill Prevention Equipment [Section IV.B.2], Secondary Containment Areas [Section IV.B.4] and Release Detection Equipment (including Leak Line Detectors) [Section IV.B.5].

For more information on the recommended practice for testing, see the Petroleum Equipment Institute (PEI) recommended practice PEI/RP1200 Recommended Practices for the Testing and Verification of Spill, Overfill, Leak Detection and Secondary Containment Equipment at UST Facilities.

With flow restrictors soon to be disallowed, service station owners need an alternative overfill prevention solution. Thankfully, Franklin Fueling Systems can offer the Defender
Series™ Overfill Prevention Valve. The Defender Series™ OPV prevents the overfill of a UST during a gravity-fed product delivery by employing a revolutionary magnetically-coupled actuator system to provide positive shutoff.

This unique method of shutoff eliminates any penetrations in the valve, making it both vapor and leak tight. Minimal flow path obstructions accommodate high flow drops while the magnetically-coupled actuator system also provides reliable positive shutoff for low flow drops.

Additionally, the Defender Series™ OPV features a remote testing tool which will make compliance with new testing regulations much easier. The magnetically coupled actuator system along with the testing tool allows for primary functionality testing of the OPV without having to remove the entire assembly from the riser. Fast visual inspection can be conducted by a single person.

The Defender Series™ OPV is fully compatible with gas, gas/alcohol blends, diesel and biodiesel, as well as compatible with industry standard 4” drop tubes allowing retrofit into existing installations.

Download the PDF of this Ask A Product Manager here.