['Tank Systems']
['Underground Storage Tanks', 'Tank Systems', 'Release Detection']
04/26/2024
Copyright 2024 J. J. Keller & Associate, Inc. For re-use options please contact copyright@jjkeller.com or call 800-558-5011.
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Post-deadline use of the combination release detection method
Can the owner and operator use this method after December 22, 1998, or is it limited to tanks upgraded or installed before the deadline?
An underground storage tank (UST) owner and operator installed a new tank at their facility one month after the December 22, 1998, deadline for upgrading, replacing, or closing substandard USTs. The owner and operator would like to employ the combination leak detection method specified in 40 CFR Section 280.41(a)(1): inventory control (or manual tank gauging) combined with tank tightness testing.
The alternative combination leak detection method, monthly inventory control (or manual tank gauging) combined with tank tightness testing performed at least every five years, is available to owners and operators who install their tank systems after December 22, 1998.
In developing the combination method, EPA studied the likelihood of leaks from new or newly upgraded tanks in relation to the effectiveness of the prescribed release detection methods. EPA determined that few new or upgraded tanks leak during the 10 years after installation or upgrading (53 FR 37082, 37150;September 23, 1988). The Agency further determined that inventory control can provide “nearly continuous (daily) release detection that can reliably detect larger releases” (53 FR 37150), and that manual tank gauging is as effective as inventory control for tanks smaller than 2,000 gallons (53 FR 37158). EPA also determined that tank tightness testing reliably detects smaller leaks and, in combination with manual tank gauging or inventory control, serves as an effective release detection method for new or newly upgraded tanks (53 FR 37150).
EPA allows owners and operators of new or fully upgraded UST systems to use this combination method until December 22, 1998, or until 10 years after the tank is installed or upgraded, whichever is later (Section 280.41(a)(1)). Therefore, owners and operators who install tanks after the deadline can use the method for 10 years from the date of installation. Similarly, owners and operators of existing tanks who temporarily closed on or before the deadline can employ the combination method when they reopen their compliant UST systems. Owners and operators cannot use this combination method to satisfy the release detection requirements for their UST piping.
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['Tank Systems']
['Underground Storage Tanks', 'Tank Systems', 'Release Detection']
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Copyright 2024 J. J. Keller & Associate, Inc. For re-use options please contact copyright@jjkeller.com or call 800-558-5011.