Changes to the Underground Storage Tank Regulations
NEW! EPA’s final rules are now available here! Please note, this rule is NOT immediately effective in Missouri. We will soon begin our rulemaking process. As such, implementation dates included in EPA’s rule may not necessarily be the regulatory deadlines established in Missouri. Please check back soon for our updated information!
Click here to download the redline version of the proposed changes to the operational UST regulations, which include Missouri’s incorporation of the new federal requirements.
If you have questions regarding these regulations, contact Heather Peters of the Hazardous Waste Program at 800-361-4827 or 573-522-5665 or by email.
The upcoming rulemaking will try to address three primary goals:
- Include state specific requirements- resolve issues with 2011 rulemaking, address problems seen in Missouri, clarify vague or ambiguous language.
- Enact the secondary containment (double-walled) requirements, as mandated by EPA.
- Include the new EPA regulations, when finalized (expected Fall 2014).
For additional details on proposed changes, please check our current newsletter.
View details on proposed timeline of compliance dates.
View a recent presentation on these rules.
The State Specific Changes
These proposed changes are the state-specific proposals open to discussion.
These proposed changes can be enacted, modified or deleted completely.
We need your input!
- Reduce the new installation notification requirement from 30 days to 14 days.
- Require tie-downs on all new USTs.
- Require post-installation tank and line tightness testing (0.1gph) in accordance with NWGLDE and method certification requirements OR testing conducted with the automatic tank gauge testing at the 0.1gph certified threshold with the tank 95% full.
- Establish a section for marinas (require new marina systems to comply with PEI RP 1000-2009).
- Clarify that if either wall of a double walled system fails, the tank must be repaired and recertified or replaced.
- Establish a maximum throughput allowance for statistical inventory reconciliation (SIR) based on the third party testing and NWGLDE listing.
- Prohibit field-repair of a spill basin (only allowing manufacturer-constructed retrofits or upgrades).
- Metal piping that is not adequately protected from corrosion for more than 90 days must be replaced or closed.
- Interior lining work must be conducted by a NACE International or International Code Council (ICC) certified technician.
- Interior lining inspections must include photo or video documentation.
- Incorporate the new UL 1856 standard into the regulations.
- Waive the 5 year internal inspection for double walled interior linings that are continuously monitored interstitially.
- Move federal definitions currently “incorporated by reference” into the state regulations
- New USTs installed after July 1, 2017, must be double-walled.
- After July 1, 2017, new piping, or when 50 percent of a piping system is replaced, must be double-walled.
- Require interstitial space (the space between two walls of a tank or piping) be monitored in double-walled systems installed after July 1, 2017.
- Require containment sump testing every 3 years for new systems and new required sumps.
- Require dispenser sumps after July 1, 2017 when dispensers and piping are replaced.
Proposed EPA Regulations
- Regulation of previously deferred or exempted tanks- field constructed (e.g. concrete) tanks and airport fueling systems.
- Regular testing of spill basins and containment sumps (sump testing only on new systems installed after July 1, 2017) every 3 years or monthly using interstitial monitoring.
- Testing of overfill prevention equipment every 3 years.
- Annual testing of all release detection equipment- line leak detectors, ATG probes, sump sensors.
- Significant changes to continue of vapor and groundwater monitoring – state is proposing to sunset these methods instead by January 1, 2019.
- Required walkthrough inspection monthly of spill basins and electronic monitoring equipment.
- Required annual walkthrough inspections of all other equipment, tank top areas, containment sumps and dispensers.
UST Operator Training in Missouri
The Petroleum Storage Tank Insurance Fund Board of Trustees has created an on-line operator training program, which includes a “test only” option. This program is free to Missouri operators. The Fund has also promulgated regulations to enact the operator training program.
The Missouri operator training regulations:
- Require qualified Class A/B Operator for all in-use facilities by July 1, 2016.
- Require Class C Operators must be trained or pass a test no later than July 1, 2016.
- Accept operator certifications from adjacent states (except Nebraska).
- Require retraining when the Department determines a significant operational compliance violation (defined by EPA) has occurred.
Regulations and Training available now on-line: http://www.pstif.org/ust_operator_training.html
For more information about UST compliance requirements, visit the Tanks and Compliance Unit Web page.
Note: The Missouri Risk-Based Corrective Action (MRBCA) regulations for underground storage tanks were not part of this rulemaking process.