What Requirements Apply To New Hazardous Substance USTs?
New hazardous substance USTs are those installed after
December 22, 1988. These USTs have to meet the same requirements described earlier for new
petroleum USTs concerning correct installation, spill, overfill and corrosion protection,
corrective action, and closure.
In addition, new hazardous substance USTs must have
secondary containment and interstitial monitoring for leak detection, as described below.
Secondary Containment
All new hazardous substance USTs must have "secondary
containment." A single-walled tank is the first or "primary" containment.
Using only primary containment, a leak can escape into the environment. But by enclosing
an UST within a second wall, leaks can be contained and detected quickly before harming
the environment.
There are several ways to construct secondary containment:
- Placing one tank inside another tank or one pipe inside
another pipe (making them double-walled systems).
- Placing the UST system inside a concrete vault.
- Lining the excavation zone around the UST system with a
liner that cannot be penetrated by the hazardous substance.
Interstitial Monitoring
The hazardous substance UST must have a leak detection
system that can indicate the presence of a leak in the confined space between the first
and the second wall. Several devices are available to monitor this confined
"interstitial" space. ("Interstitial" simply means "between the
walls.") The UST regulations describe these various methods and the requirements for
their proper use.
You can apply for an exception, called a variance,
from the requirement for secondary containment and interstitial monitoring. To obtain a
variance you must demonstrate to the regulatory authority that your alternative leak
detection method will work effectively by providing detailed studies of your site,
proposed leak detection method, and available methods for corrective action.
What About Existing Hazardous Substance USTs?
Existing UST systems are those installed before December
22, 1988. In addition to immediately starting tank filling procedures that prevent
spills and overfills, you will need to meet the following requirements for existing USTs.
Leak Detection
Deadlines for compliance with leak detection requirements
were phased in according to the age of the UST. By December 22, 1993, all existing USTs
were required to have leak detection. Pressurized piping must meet the requirements
for new pressurized piping.
You can meet the leak detection requirements in one of the
following three ways:
- Until December 1998, you can use any of the leak detection
methods described on page 19 but only if the method you choose can
effectively detect releases of the hazardous substance stored in the UST.
- After December 22, 1998, your UST must meet the same
requirements for secondary containment and interstitial monitoring that apply to new
hazardous substance USTs.
- After December 22, 1988, a variance can be granted if
you meet the same requirements described above for receiving a variance for a new
hazardous substance UST.
Spill, Overfill, and Corrosion Protection
By December 22, 1998, you must improve your USTs:
- By using devices that prevent spills and overfills.
- By adding corrosion protection to steel tanks and
piping.
Although the regulatory deadline is in 1998, you should
make these improvements as soon as you can to reduce the chance that you will be liable
for damages caused by your unimproved UST.
What If You Have A Hazardous Substance Release?
You must follow the basic actions described below for
petroleum releases, with the following two exceptions.
- First, you must immediately report hazardous substance
spills or overfills that meet or exceed their "reportable quantities" to the
National Response Center at 800 424-8802 or 202 267-2675.
- Second, you must also report hazardous substance spills or
overfills that meet or exceed their "reportable quantities" to the regulatory
authority within 24 hours. However, if these spills or overfills are smaller than their
"reportable quantities" and are immediately contained and cleaned up, they do
not need to be reported. You can get information on the "reportable quantities"
by calling the EPA RCRA/CERCLA Hotline at 800 424-9346.
Warning signals indicate that your UST may be leaking and
creating problems for the environment and your business. You can minimize these problems
by paying careful attention to early warning signals and reacting to them quickly before
major problems develop.
You should suspect a leak when you discover the following
warning signals:
- Unusual operating conditions (such as erratic
behavior of the dispensing pump). Check first to see if this problem results from
equipment failure that can be repaired.
- Results from leak detection monitoring and testing that
indicate a leak. What at first appears to be a leak may be the result of faulty
equipment that is part of your UST system or its leak detection. Double check this
equipment carefully for failures.
You need to call your regulatory authority and report
suspected leaks. Then find out quickly if these suspected leaks are actual
leaks using the following investigative steps:
- Conduct tightness testing of the entire UST system.
- Check the site for additional information on the presence
and source of contamination.
If these system tests and site checks confirm a leaking
UST, follow the actions for responding to confirmed leaks described below.
You must also respond quickly to any evidence of leaked
petroleum that appears at or near your site. For example, neighbors might tell you they
smell petroleum vapors in their basements or taste petroleum in their drinking water. If
evidence of this type is discovered, you must report this discovery immediately to the
regulatory authority and take the investigative steps and follow-up actions noted above.
In response to a release, you should:
Take immediate action to stop and contain the release.
- Report the release to the regulatory authority within 24
hours. However, petroleum spills and overfills of less than 25 gallons do not have to be
reported if you immediately contain and clean up these releases.
- Make sure the release poses no immediate hazard to human
health and safety by removing explosive vapors and fire hazards. Your fire department
should be able to help or advise you with this task. You must also make sure you handle
contaminated soil properly so that it poses no hazard (for example, from vapors or direct
contact).
- Remove petroleum from the UST system to prevent further
release into the environment.
- Find out how far the petroleum has moved and begin to
recover the leaked petroleum (such as product floating on the water table). Report your
progress and any information you have collected to the regulatory authority no later than
20 days after confirming a release.
- Investigate
to determine if the release has damaged or might damage the environment. This
investigation must determine the extent of contamination both in soils and groundwater.
You must report to the regulatory authority what you have learned from an investigation of
your site according to the schedule established by the regulatory authority. At the same
time, you must also submit a report explaining how you plan to clean up the site.
Additional site studies may be required.
Based on the information you have provided, the regulatory
authority will decide if you must take further action at your site. You may need to
develop and submit a Corrective Action Plan that shows how you will meet requirements
established for your site by the regulatory authority. Make sure you implement the
corrective action steps approved by the regulatory authority for your site.
EPA’s RCRA/Superfund/UST Hotline, at (800)
424-9346, responds to questions and distributes guidance regarding all RCRA regulations.
The RCRA Hotline operates weekdays from 8:30 a.m. to 7:30 p.m. ET, excluding Federal
holidays.
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