EPA Clarifies New Testing Requirements for Certain Petroleum Storage Tank (PST) Facilities
May 2020 – Testing Requirements for Spill Prevention Equipment and Containment Sumps Used for Interstitial Monitoring of Piping
The Texas Commission on Environmental Quality’s Petroleum Storage Tank rules in 30 Texas Administrative Code (TAC) §334.48(g) have certain requirements for spill prevention equipment and containment sumps used for interstitial monitoring of piping. The rules state that these components can either be tested for tightness every three years or be double-walled and inspected every 30 days. EPA clarified the tightness testing requirements in its guidance, EPA’s Underground Storage Tank (UST) Technical Compendium about the 2015 UST Regulation .
In March 2020, EPA notified owners and operators of UST systems that they cannot use the ASTM E3225-20 standard to meet the federal testing requirements for spill buckets and sumps. Spill prevention equipment and containment sumps used for interstitial monitoring of piping must be tested to ensure that the equipment is liquid tight by using vacuum, pressure, or liquid testing per 40 Code of Federal Regulations (CFR) §280.35(a)(1)(ii) . ASTM E3225-20 (Standard Practice for Performing a Liquid Test of Spill Prevention Equipment and Containment Sumps Used for Interstitial Monitoring of Piping by Visual Examination) is a visually-based standard practice that does not use vacuum, pressure, or liquid testing procedures. Therefore, this standard cannot be used to meet the federal requirements of 40 CFR §280.35(a)(1)(ii) or the state requirements in 30 TAC §334.48(g) . If owners and operators follow ASTM E3225-20 and do not perform the correct testing requirements, they will be in violation of the regulatory requirements, and subject to appropriate enforcement.
Additional guidance to assist you with UST compliance can be found at the links below:
- Search for UST Contractors on the TCEQ website
- This is a list of PEI Contractors by State (from the Petroleum Equipment Institute website)
- Petroleum Storage Tank Spill and Overfill Prevention and Control (RG-475e)
- UST Systems: Inspecting and Maintaining Sumps and Spill Buckets – Practical Help and Checklist (EPA website)
More information can be found on the PST Compliance Resources webpage or in the PST Super Guide (RG-475). If you have questions, you may contact the Small Business and Local Government Assistance section at (800) 447-2827.